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.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System
Eneris has a set of E&S policies applicable to all its subsidiaries, articulating the company’s commitment to legal compliance, environmental protection, sustainability, circular economy, OHS, human rights, and stakeholder engagement.
Eneris identifies and manages E&S risks and impacts associated with its operations by complying with applicable European Union (EU) directives and Polish E&S legislation, and permits during the design, construction, and operational phases. At the corporate level, Eneris has developed E&S management procedures to handle its operational E&S risks in line with national and relevant EU requirements. Most operational plants are certified ISO 14001:2015 (Environmental Management). E&S management systems are implemented at each operational plant to identify and manage environmental, health and safety (EHS) risks and impacts. All plants and facilities have valid operational permits.
As part of this investment, Eneris will enhance its existing corporate E&S management system (ESMS) to strengthen its identification process of E&S risks and impacts and align it with IFC PSs' requirements. The ESMS will be applied to all existing and future operations (including sub-projects). The enhancement will include: (i) developing an M&A policy, land acquisition policy, biodiversity policy, supply chain policy and a standalone sexual harassment policy, (ii) developing an E&S risk and impact screening procedure for future developments including taking ownership of a concession/asset, M&As and new developments to screen for high risk factors (e.g., historical contamination, retrenchment, land acquisition, cultural heritage and biodiversity risks) ahead of potential investments; (iii) developing and implementing a Change Management Procedure; (iv) developing a procedure to ensure consistent contractor management across projects and facilities (such as the development of project / asset specific Contractor Management Plans(CMP); (v) updating the E&S monitoring procedure for its operations including activities carried out by contractors and sub-contractors (during construction and operational phases); (vi) developing a supply chain risk assessment and evaluation procedure; (vii) developing and implementing corporate and asset level stakeholder engagement plans (SEP) and community grievance mechanism; and (viii) developing and implementing a road safety management procedure. Additionally, to enhance the E&S risks and impacts identification process in line with IFC Performance Standards at corporate level, for future greenfield developments, Eneris will carry out and document social risk and impact assessment for internal use in line with IFC’s PSs and the WBG EHS Guidelines including stakeholder analysis and management (stakeholder engagement plans and grievance mechanisms) commensurate with the E&S risks and impacts of the project. The corporate management system will include the relevant technical standards, management procedures and plans and work instructions for E&S risk assessment and management and performance monitoring including an inspection/audit program. Eneris internal audit/risk committee will track non-compliant items and will report to management/Board (ESAP#1).
Eneris conducts EIAs for new developments and expansions as required by Polish laws/regulations. At the early development stages of the sub-projects and in the process of identifying potential M&A targets, the company assesses the E&S aspects as part of legal compliance due diligence. As indicated above, for greenfield developments and M&As, Eneris will develop an E&S risk and impacts screening procedure to consistently identify and assess potential E&S risk and impacts associated with the greenfield development or any past or existing operation or asset prior to investment in line with IFC PSs requirements (ESAP#2).
The planned sub-projects, financed under the proposed investment, will be designed and operated in accordance with good international industry practice (GIIP) and to meet the requirements of the EU directives and Polish national requirements. For the sub-projects, the company carried out the local EIA or Project Information Card (PIC) in accordance with the local regulation’s requirements, with the support of external consulting firms, except, as indicated, for the HW Landfill sub-project, which is in the early stages of development. The local EIA decision was obtained for EECU, ZGOK sorting plants and the biogas plant. The permitting process is ongoing for HW treatment plant and composting plant. While a typical local EIA is aligned with IFC PS1 in many aspects, the review of the local EIA indicated that the assessment of potential social risks and impacts is limited compared to IFC PS1 requirements. Therefore, as part of this investment and in line with IFC PS1 requirement, Eneris will conduct a supplemental social risk and impact assessment for its sub-projects for which the local EIA has already been conducted, commensurate with the potential risks and impacts (ESAP#3).
For the biogas plant, the company prepared a PIC as per the local EIA requirements, that is not fully aligned with IFC PS1. The environmental decision was obtained in 2023 based on PIC. The biogas plant project is within the boundaries of a Natura 2000 site, a Special Protected Area (SPA) designated under the EU Birds Directive. There are also residential areas at a distance of around 500 m from the site. To ensure adequate E&S risks and impact assessment, Eneris will carry out PS-compliant ESIAs for biogas plant and HW landfill, including a PS6-compliant biodiversity risk assessment (as needed in the form of an Appropriate Assessment per EU requirements) for biogas plant as discussed under PS6. The ESIAs will include odor, noise and air emissions modelling and impact assessment with consideration of the baseline conditions and project design features (ESAP#4).
Management Programs and Organizational Capacity and Competency
The company regularly monitors its E&S performance through a central EHS management database, which is developed to record and monitor plant-level EHS performance, incidents (e.g., vehicle accidents, OHS and emergency incidents) and non-conformities with respect to the E&S policies, procedures, and standards. Moreover, a periodical review of the company’s policies and procedures effectiveness, applicability and adequate implementation is undertaken by the internal audit department, and findings are reported to the Board. Eneris will update its existing monitoring procedure by including the EHS related key performance indicators (KPIs) aligned with WBG General EHS Guidelines and the EHS Guidelines for Waste Management Facilities. The KPIs will also report on external grievances. This procedure will integrate the annual on-site internal audit program and management review to assess compliance with the local regulatory requirements, corporate E&S policies and procedures, and the IFC PSs and relevant and applicable WBG EHS Guidelines. The monitoring program will be extended to cover third-party activities e.g., oversight of construction and operation and maintenance (O&M) contractor EHS and labor management (ESAP#1).
Eneris’s corporate EHS, HR and legal teams are responsible for the initial E&S assessment, obtaining all construction and operational permits, including the environmental authorisations for any new developments. The company retains the services of external E&S consulting firms to undertake the required EIA studies for its projects and will do the same for any ESIA to be developed for the planned sub-projects. Going forward, as part of the E&S risks and impacts screening procedure, Eneris will engage external consultants/ technical experts for the identification of E&S risks at an early stage of the process (applicable to M&A or new project designs). This will be defined in the E&S risk screening procedure (ESAP#2).
The company requires contractors and sub-contractors to follow Eneris’ E&S policies and procedures which are reflected in the legal agreements. Furthermore, the company assigns/hires an EHS coordinator for the construction projects to ensure that the contractors and sub-contractors effectively implement the required provisions and management plans, and the EHS coordinator reports to the corporate EHS team. For each sub-projects under the proposed investment, the company will develop and implement construction E&S management plans (CESMP), consistent with the local regulatory requirements, EIA/ESIA commitments, corporate E&S policies and procedures, and the IFC PSs and relevant and applicable WBG EHS Guidelines, and will integrate the implementation of the plans within the contractual requirements of the contractors (ESAP#5).
At the corporate level, Eneris has an E&S management team, including a public relations and communication specialist. The team monitors the E&S performance at the plant level with periodic and unannounced internal audits to ensure effective implementation of the permit conditions at the plant/facility level. As indicated above, the company has established the EHS database system to monitor E&S performance and incidents at the plant/facility level. The corporate E&S team reports directly to the Chief Executive Officer and is supervised by the Board of Directors. At individual sites, the company has dedicated EHS specialists to monitor the EHS performance and deliver EHS trainings reporting to the site manager with a dotted reporting line to the corporate E&S team. Eneris also established a Sustainability Committee to manage the company’s Sustainability-related initiatives and relevant reporting.
Before commercial operations, as per ESAP#6, Eneris will develop and implement Operations E&S Management Procedures and Plans for sub-projects consistent with IFC PSs, relevant WBG EHS Guidelines, national requirements, ESIA commitments and the outputs of any relevant supplemental assessments conducted as part of the agreed ESAP.
To manage E&S risks related to procurement and supply chain, Eneris has developed a formalised process, including vendor prequalification, selection procedures, and a Code of Conduct for Business Partners, which defines the company’s E&S commitments (including commitments relating to labour practices and human rights). The code is annexed to the supplier’s and contractor’s legal contractual agreements. The company monitors its suppliers on an ongoing basis to identify any significant changes in its supply chain and if new risks or incidents of child and/or forced labour are identified through desktop review and physical audits. The suppliers are disqualified if they cannot pass the initial or annual reviews. As per ESAP# 1, Eneris will formalise a supply chain policy and evaluation procedure based on the existing risk assessment and monitoring process implemented. The corporate E&S team will oversee the E&S aspects of the supply chain management in line with IFC PS requirements.
Eneris accepts hazardous and non-hazardous waste directly from companies based on documented delivery forms, while municipal waste is also collected directly from households. The company has implemented procedures for customer identification and evaluation (within the group), and each time before starting a new activity, the history of relationships with a specific customer is checked. Considering that the origin of the waste sources is known and controlled by the company and the implementation of the process discussed above includes relevant monitoring, the risk of informal waste collectors is considered minimal.
Emergency Preparedness and Response
Eneris has a documented corporate emergency preparedness and response plan (EPRP), which includes a system of classification of emergencies, identifies emergency response teams, communication plan, crisis management team & responsibilities, and procedures for tracking and reporting on emergencies. All plants/facilities have an individual emergency and fire safety & response plan in line with the local regulatory requirements. Annual emergency response (ER) drills are conducted in coordination with the local fire brigades. All implemented emergency procedures apply to employees and third-party workers on its plants/facilities. Training is defined according to the scale and nature of operations and associated risks at each facility. Stakeholder engagement activities, both at the corporate and plant levels, will include communicating the key elements of EPRP for the respective plant. Additionally, local communities will be involved in scenario-based emergency evacuation drills in accordance with the identified potential risks.
Composting plants’ EIA identified that the project area is in a flooding risk zone. Considering the nature of the operations, the facility’s design will incorporate the relevant preventive measures to avoid potential environmental impact in case of flooding, such as an adequate drainage system design. As part of the required Operations E&S Management Plan for the facility, the plant-level EPRP will have relevant preventive and mitigation actions for flooding risk, including drills and training for the plant’s employees (ESAP#6).
The design will incorporate operational safety requirements for biogas and HW treatment plants, including gas detection systems, emergency shutdown systems, and fire suppression systems.
Eneris facilities have adequate firefighting equipment and firefighting water/foams, which are properly maintained. There is a firefighting team at each plant/facility, which is trained by the local fire brigades. Each site holds periodic ER drills e.g., fire/explosion drills in landfills. All chemicals are labeled and stored appropriately with relevant material safety data sheets (MSDSs). During the site visits, it was observed that the consistency of the implementation of the fire safety plans needs to be improved. The company will implement a detailed fire safety inspection at all its operational facilities. Based on the findings, the company will develop a fire prevention and safety improvement plan (ESAP #7).
The transportation-related emergencies are monitored by the corporate E&S team. HW, including medical wastes, are transferred using vehicles specifically designed for HW transportation. The drivers and loader receive training on how to handle the material and what actions to take in case of a road accidents. To ensure a systematic approach is implemented across its subsidiaries, Eneris will develop and implement a road safety management procedure as part of the corporate ESMS (ESAP#1).
PS 2 – Labor and Working Conditions
As of September 2024, Eneris employed a total of 1929 direct workers (73/27 male/female ratio). Additionally, the company has 88 contracted workers for supporting services e.g., security, maintenance, truck drivers. During the winter and summer periods, the company hires seasonal workers as required.
Eneris has a set of corporate-level HR policies and procedures, including a code of ethics, which covers respect for human rights and working conditions, anti-harassment including sexual harassment, counteracting mobbing and discrimination, whistleblower procedure, recruitment and selection policy, onboarding, training, terms and conditions of employment, including zero tolerance for any form of discrimination and harassment. Eneris’s HR policies and procedures are applicable to all Eneris employees, and all information related to the labour and working conditions are communicated during the onboarding procedure of all new staff and available on the intranet.
The employment terms and conditions are in line with national legislation and employees are provided with written contracts that state the contract type and duration, wages and benefits, hours of work, overtime, breaks, leave, pension, health insurance and other relevant information. While no collective bargaining agreements are in place, the company respects workers’ right to associate and Eneris workers can join labor unions. At Eneris, currently, there are three active worker unions with elected union leaders.
As per ESAP#8, Eneris will update the existing HR policies and procedures to cover seasonal and third-party workers and to be fully aligned with IFC PS2. The updated HR policies and procedures will be extended to all subsidiaries including the ones operating new facilities acquired through M&A or to be developed as part of the sub-projects.
As indicated in the ESAP#1, Eneris will define in the CMP, the company’s requirements for contractors and subcontractors, aligned with national requirements, PS2 and the company’s HR policies and procedures. For the sub-projects, during the project's construction phase, the company will supervise the contractor’s (and their sub-contractors’) compliance with the relevant requirements.
Eneris does not employ anyone below 18 years of age, except for apprentices, which can range from 16 years of age and above. The company strictly follows the requirements prescribed by the EU/Polish labour law for apprentices, which is in line with PS2 requirements, e.g., they are assigned to non-hazardous jobs, have no overtime and are employed for a limited duration relevant to their education.
All work-related grievances are currently managed in accordance with the whistleblower policy and anti-discrimination and harassment procedure, which allows for anonymous submissions and have a dedicated channel for handling harassment cases including grievances related to sexual harassment in accordance with the Polish dignity labor law. The company has assigned dedicated and trained focal points to handle worker’s grievances including sexual harassment complaints. The company engages with a qualified external advisor to ensure full confidentiality. All direct employees and contractors can report grievances through hotline or e-mail. All the grievances and relevant responses and actions taken by the company are recorded. The relevant policies and procedures are explained at the time of hire and accessible from varied sources (e.g., flyers, intranet). ESAP#9, Eneris will formalize its existing activities for managing the workplace and GBV grievances under a standalone worker’s grievance mechanism procedure to allow for anonymous grievances to be raised by all direct and contracted workers and will develop a grievance register process to collect and address the grievance and concerns in a transparent and timely manner. Additionally, Eneris will develop and implement a training program for all workers on the grievance mechanism, and a program for managers and HR personnel on how to receive, handle complaints and conduct investigations. The grievance mechanism procedure will be communicated and understandable to all workers and will be implemented in all sub-projects and existing facilities.
Eneris operations are managed in line with the local regulations, including identification of OHS risks, job hazard analysis for each position, implementation of controls with operational procedures, monitoring of working conditions and working environment, and recording accident/incident statistics and investigation. Health tests are done periodically for the staff and include respiratory and skeleton system control, chemicals in blood and audiometry checks. All required protective protection equipment for specific job needs are provided. Employees are required to report accidents/incidents, including near-misses and unsafe acts, to facilitate investigations and the identification and implementation of corrective measures to prevent accident occurrence. Induction of newly hired workers and periodic training for all employees including third-party workers including seasonal workers, are mandatory. OHS training includes topics such as operational procedures, general site safety rules and regulations, incident, accident, near-miss reporting, emergency procedures, permits to work, material handling, fire prevention, working at heights and fall protection and first aid. The corporate OHS team conducts periodic audits to all operational sites. All sites have a dedicated EHS specialist.
Most of the injuries reported involved workers performing waste collection activities. Eneris will undertake a behaviour-based safety assessment with a particular focus on increasing awareness among the workers in the waste collection and sorting operations (ESAP#10) As part of ESAP#1, Eneris will ensure the development of an adequate mechanism to require and monitor that all subsidiaries comply with the company’s OHS management system and implement GIIP as described in the WBG/IFC General EHS Guidelines and the EHS Guidelines for Waste Management Facilities.
Eneris has digitised its fleet with in-vehicle real-time GPS monitoring systems, which allows tracking of employee and fleet safety. This system allows tracking of all company waste cleaning and transportation operations, routes driven, unsafe acts (speed limit exceedances), and unsafe conditions and identifying opportunities to increase efficiencies and driver’s continuous improvement in real-time.
PS 3: Resources Efficiency and Pollution Prevention
Eneris is committed to reducing resource consumption and has undertaken several activities to minimise the use of raw materials across its facilities. Energy efficiency audits were conducted, identifying areas for improvement, and actions were implemented. Additionally, electric and CNG vehicles have been added to the waste collection fleet.
Electricity for existing facilities is supplied from the national grid, and water is sourced from city networks or wells depending on the location of the facility and the available water supply alternatives. Fuel oil is the main energy source for heating the furnace and controlling the process temperature the Bydgoszcz HW incineration plant. Landfills have biogas collection and incineration systems to eliminate methane emissions and recover energy, with generated electricity sold to the grid.
Biogas plant’s energy will be supplied from an adjacent plant, and water from the city network. HW incineration plant is designed to capture and reuse waste heat, with water supplied from the city network. Both the biogas plant and HW incineration plant will incorporate high-efficiency equipment and plan to recycle treated wastewater for cooling.
Eneris is in the process of improving environmental data collection across its facilities. In line with IFC PS3 and ESAP #11, Eneris will quantify annual direct (Scope 1) and indirect (Scope 2) GHG emissions using internationally recognised methodologies such as ISO 14064 or the GHG Protocol.
Eneris manages pollution prevention through procedures and policies covering leachate, groundwater, and odour monitoring at landfills, dust control, and air emissions. If municipal sewers are unavailable, systems are installed to collect and treat effluents in line with local regulations and permits.
The sub-projects which will be financed through the proposed investment, are/will be designed to meet EU requirements, ensuring pollution prevention controls for wastewater treatment, emissions, and waste disposal as per GIIP and applicable and relevant WBG EHS Guidelines. The sub-projects air emission abatement technologies are designed to comply with local/EU regulatory requirements and will meet the relevant levels of the WBG EHS Guidelines for Waste Management Facilities. HW incineration plant will have an advanced flue gas treatment systems to capture and neutralize pollutants. Once operational, the plants are expected to have the required pollution prevention engineering controls in terms of wastewater treatment, fugitive and point emissions (including, where relevant, VOCs, CO, NOx, HCl, HF, SOx, heavy metals, and dioxins and furans) and waste disposal.
Air emissions from Bydgoszcz HW incineration plant meet the local regulatory requirements and WBG EHS Guideline, including emissions level for dioxins/furans. Ambient air quality monitoring data from the incinerator plant demonstrated compliance with local/EU regulatory requirements and operational permits. The incineration emission monitoring results are disclosed in real-time at the facility’s gate, and on the information board located on the building of the secondary school in Bydgoszcz.
All landfills have leachate collection, treatment and monitoring systems to prevent groundwater contamination. The leachate is collected in lined retention/evaporation ponds. All other wastewater streams, e.g., contaminated stormwater, are collected and disposed by a licensed third-party. The wastewater generated in other operational plants are also discharged by an authorized third-party. The review confirmed that the design elements, including liners, leachate collection systems, landfill gas recovery system, and cover systems in place at the landfills, meet the environmental protection and waste containment regulatory requirements and site-specific permit conditions.
The industrial wastewater generated from sub-project HW incineration plant will be pre-treated onsite and recycled back to the process. At the biogas plant, the effluents from the anaerobic digestion of agricultural waste will be sent to the farms for land application. The digested sludge is planned to be sold as fertilizers.
Regular soil and groundwater monitoring is conducted at the existing facilities/plants in accordance with the permit requirements. The most recent soil and groundwater quality monitoring reports for all landfills and Bydgoszcz HW incineration plant site were reviewed as part of the E&S due diligence. The monitoring data found generally in compliance with the Polish regulatory requirements and WBG EHS Guidelines. At Bydgoszcz site, the available subsurface soil quality assessment results did not show any indication for potential soil impact and were below the Polish reference values (based on respective EU Directive) and the US Environmental Protection Agency Regional Screening Levels set to assess soil contamination levels in industrial sites. The groundwater quality measurement results from one piezometer showed that some parameters are above the baseline concentrations, which were communicated to the local authorities, who required continuous monitoring of the soil and groundwater quality to identify potential impacts. If/when the results show a potential contamination associated with the surrounding facilities operations, the company reports such results to the competent authorities. If/when a source of contamination is detected at the plant site, the company will eliminate such source and implement remedial measures consistent with GIIP.
In the Balin landfill, no groundwater monitoring is carried out by the company as the groundwater in the landfill area was already drained by the operations of a now-closed mine located in the site’s vicinity. This situation is acknowledged and approved in the permit issued for the facility operation by the governmental authorities.
In line with ESAP #12, Eneris will formalise a soil/groundwater monitoring program to ensure consistency, quality control and replicability of the results at all the operational landfills and existing and future hazardous waste and biowaste treatment plants consistent with GIIP. Additionally, the company will develop a procedure to conduct Phase II environmental site investigation for proposed new plants or M&As and to establish soil/groundwater baselines for each site as part of its ESMS and screening procedures. If any historical pollution is detected at any given site for which the available information doesn’t allow to ensure remediation to meet EU and Polish soil/groundwater standards is technically and financially feasible, the company will not proceed with the project.
To prevent soil/groundwater contamination, all process areas of the plants/facilities in operations have hard surfaces with impermeable layers. All storage tanks have double containments and are stored properly. During the site visit, it is observed that not all waste storage areas are covered at visited sorting facilities; therefore, Eneris will implement an engineering review and analysis to identify waste storage areas for which cover is warranted at its sorting facilities and other facilities (if applicable) (ESAP#13) to optimise containment and minimise the production of contaminated stormwater and leachate.
Waste management operations are associated with odour emissions, and Eneris implements several operational odour control measures. Depending on the type of operation, these measures include covers on landfilled waste, landfill gas flaring or collection and processing, aerobic waste composting, biofilters, and activated carbon filters on ventilation systems and controlled air emission outlets. To minimize odour nuisances, all sub-projects design includes the necessary preventive measures in line with GIIP. However, odour-related complaints have been reported by communities surrounding some facilities, including Bioproten and Balin facilities.
Eneris will assess the implementation of adequate odour emissions monitoring in its existing plants and future operations (including sub-project) if needed, will define mitigation measures, ensuring that the objectives of PS3 are properly met (ESAP#14 and #1).
The design of sub-projects includes noise mitigation measures in line with GIIP, such as erecting physical sound barriers, scheduling noisy operations during the daytime, and selecting low-noise equipment like compressors. The existing facilities are typically located away from residential areas. Environmental noise monitoring is periodically carried out in accordance with local regulatory requirements. In waste collection and transportation operations, the company implements necessary measures to minimise noise generation.
At the existing HW incineration plant, Eneris conducts reactivity checks for each waste batch before incineration and prepares daily loading sequences to prevent violent reactions. This procedure will also be implemented at Hubal.
Ash and slag generated from incineration are disposed of by authorized third parties at hazardous waste landfills. On-site storage of hazardous waste, such as medical waste awaiting incineration, is managed within dedicated buildings to prevent potential contamination. Hazardous materials used in operations, mainly fuels and lubricants, are stored aboveground with proper secondary containment.
Waste from MBT facility operations is disposed of at the company’s landfills or supplied for heat recovery or recycling in industrial processes carried out by licensed third-party companies. Non-biodegradable materials generated in the biogas plant’s production process will be sold to third parties as an energy source.
PS 4: Community Health, Safety and Security
Eneris landfill, sorting, MBT sites and operational plants are located at a distance from sensitive receptors, whilst waste transfer stations are mostly located close to urban areas. All sub-projects, as per available EIAs, will be designed and operated as per EU requirements.
The planned composting plant, while located in an industrial area, will be approximately 200 m from the nearest residential community, and the risks and impacts will require the design of adequate mitigation measures and careful management during operations.
For the sub-projects, the identification of potential risks and impacts to communities and relevant mitigation measures will be confirmed and as needed, complemented with the supplemental studies required under the ESAP (ESAP #3 and #4).
Eneris operates owned and leased vehicles and equipment dedicated to waste transportation and collection, including hydraulic truck cranes, hook lifts, gantry trucks, tanker trucks, and box trucks. Given the nature of Eneris’ activities, the most significant risk to the community’s health and safety is related to road traffic, collisions, and accidents. Eneris initiated awareness-raising campaigns among residents about the potential dangers associated with blind spots related to the operations of waste trucks and training programs for truck drivers. The company reported a relatively high frequency of incidents and accidents affecting the company’s drivers. In addition to the road traffic management system already implemented by the company, as part of the corporate management system, Eneris will develop and implement road safety management procedures in line with the GIIP to ensure systematic implementation of measures to minimize risks for the communities (ESAP#1).
The company also implemented "Eco Ambulance" service consisting of a fleet of rapid intervention vehicles to collect hazardous waste such as tanks, barrels, contaminated packaging, plastic bags, and other harmful substances which are inadequately disposed of or found abandoned in public areas. The "Eco Ambulance" vehicles are equipped with spill intervention materials and are operated by staff trained in rapid intervention to contain, collect and transport hazardous materials spills on public domain or private properties.
All Eneris sites are secured by a fence and monitored using either cameras or detectors in accordance with the law, which requires the implementation of a visual inspection system for the waste storage or disposal sites. The company employs private security service providers for access control and site patrolling based on framework agreements with licensed companies. The security guards are unarmed and, in case of unauthorised access into facilities, are not mandated to intervene directly but are required to seek police intervention.
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
All of Eneris’ existing facilities and sub-projects are in the temperate broadleaf and mixed forests biome of the Central European mixed forests ecoregion (Resolve, 2017). The sites are located within industrial areas or former agricultural land, which had been converted prior to the M&A. The site of the biogas plant is within the boundaries of Ostoja Drawska Special Protection Area (SPA), a Natura 2000 site designated under the EU Birds Directive, and Drawa River Site Key Biodiversity Area (KBA)/Important Bird and Biodiversity Area (IBA). The plant will be constructed adjacent to an existing biogas facility and on a former pig farm, with no greenfield expansion. Although the site is close to areas of Natural Habitat including a wetland, direct impacts on biodiversity values associated with the SPA/KBA are not anticipated.
In line with PS6 requirements, the company will consult relevant stakeholders (e.g. authorities responsible for the designation and management of the SPA, the NGO responsible for the designation of the KBA/IBA) with respect to their planned activities within the Ostoja Drawska SPA. A PS6-compliant biodiversity risk assessment (as needed in the form of an Appropriate Assessment per EU requirements) for the biogas plant will be carried out as part of the relevant ESIA studies. The assessment will identify priority biodiversity values at the project site and its surroundings that could potentially be subject to risks and impacts associated with planned project activities. Commensurate with identified risks and impacts, a Biodiversity Management Plan (BMP) will be developed to set forth measures related to the conservation of biodiversity values. As per ESAP#1, Eneris will also update its corporate ESMS to include a Biodiversity Policy and a Biodiversity Risk Screening and Management Procedure that will apply to the company’s future projects and M&As.
