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
Policy, E&S Management System, and Programs:
Aspen continues to implement the Group’s safety, health and environment policy and management systems, which is developed per IFC Performance Standards (PSs) requirements as an existing client, across their sites. All manufacturing facilities except the Sioux City (USA), India and Ghana sites have certified environmental management systems aligned with the requirements of the ISO 45001:2018 (occupational health and safety management) and ISO 14001:2015 (environmental management) standards. The API manufacturing sites have the relevant accreditations, including US Food and Drug Administration (‘FDA’) accreditation. For non-certified sites, the Company applies the environmental management principles and various Group-level SHE standards, that are implemented across all business units.
Identification and Assessment of Risks and Impacts:
Aspen identifies E&S risks and impacts associated with its facilities and operations through risk assessments in compliance with applicable national standards, E&S regulatory permitting requirements and Group-level SHE standards. The Hazard Identification and Risk/ Impact Assessment and determining controls (‘HIRA’) Procedure is applied at all business units. Where risks are identified, the selection of required mitigation measures are determined by the principle of the hierarchy of controls. By applying the Design and Change Management Standard, issue-based risk assessments are also conducted for the management of changes and for any new projects prior to the design phase to ensure that all SHE risks are considered and mitigated. Prior to the acquisition of any new operations, or expansion of existing facilities, the Company commissions qualified third party consultants to undertake E&S due diligence and prepare Environmental Impact Assessments (‘EIAs’) or Environmental Audits (‘EAs’) at the business units in compliance with host country regulations and ensures that actions in the EIA management plans or EA corrective action plans are effectively implemented in a timely manner. Any new operations acquired would subsequently be systematically incorporated into the Aspen’s Group SHE program.
Organizational Capacity:
Aspen’s Board monitors the status of environmental and OHS risks through review of material environmental and OHS management performance indicators on a quarterly basis. The Social & Ethics (‘S&E’) Committee assists the Board in monitoring the adequacy of SHE management systems in the Group and the extent to which these comply with relevant legislation.
Under the strategic direction of the Group Chief Operations Officer, and reporting to the Group Executive: Strategic Manufacturing, the Group Operations Health & Safety Manager develops and promotes Aspen's SHE standards and monitors the alignment of business units’ H&S management systems with the Group standards. This is achieved through the H&S Centre of Excellence (COE) which comprises all operational SHE Managers.
Under the strategic direction of the Group Chief Corporate Services Officer, and reporting to the Group Executive: Risk, Sustainability & Compliance, the Company’s Sustainability function develops and promotes Aspen’s environmental management principles and standards, while the Company’s Ethics & Compliance function monitors compliance.
Each subsidiary has dedicated SHE officers responsible for the day-to-day compliance obligations and for providing technical support within the operations. This includes driving facility-level SHE key performance indicators (‘KPI’) targets which are developed annually and aligned with Group SHE KPIs.
The Group Executive: Risk, Sustainability & Compliance and Group Operations Health & Safety Manager provide regular E&S performance reports to the S&E Committee of the Board.
Emergency response plan:
The Company has developed and implemented site-specific emergency preparedness and response plans and procedures (‘EPRP’) as part of each material business unit’s Business Continuity Plans (‘BCPs’). The EPRP cover potential emergencies like fire, medical emergencies, spillage and confined space entry. Emergency exits and assembly points are identified, and regular drills are conducted frequently. The Company has not reported any major emergency or incident in the past two years at any of its facilities.
Monitoring and Review:
The Company monitors a wide range of SHE-related KPIs for its operations such as environmental KPIs which include carbon emissions; waste recycled; hazardous waste generated, water usage; and electricity consumption. OHS KPIs include Total Recordable Incident Frequency Rate (TRIFR), High Consequence Incident Frequency Rate (HCIFR); and lost workday frequency rate. HR KPIs include average staff turnover; average training spend per employee; and percentage of females in top management roles in the Group. KPI results are reported quarterly to the Group Sustainability and HR management functions and senior management.
The Company annually publishes a detailed Integrated Report in which sustainability data on E&S performance of company operations is shared with interested parties https://aspen-reports.co.za/reports/2023/index.php.
PS 2 – Labor and Working Conditions
As of June 2023, Aspen employed about 9,000 employees globally, with 94% being permanent employees and 6% temporary employees. The permanent employee ratios were 48% female and 52% male.
Working Conditions and Management of Worker Relationship:
Aspen has a corporate HR strategy, policies and procedures. These are customized in each business unit, per applicable labor legislation requirements and are consistent with IFC PS:2. The Group’s HR function is partially decentralized and each business unit has dedicated HR personnel responsible for implementation of HR policies and procedures. The corporate Diversity and Inclusion Framework and corporate Code of Conduct include statements on promotion of equal opportunity principles and non-discrimination in respect of employment policies and practices. Sexual harassment in the workplace is prohibited and appropriate corporate policy is implemented across all operations and any material reported infringements are escalated and investigated requiring resolution to the satisfaction of the Aspen Ethics Committee and the Board’s S&E Committee.
Discrimination of employees based on age, nationality, gender, race, physical health, sexual orientation, individual belief systems and/or any other prejudicial grounds is prohibited. Aspen policies further denounce the use of child labor and unfair labor practices, both within Aspen and in the Company’s supply chain. These principles are further embedded in Aspen’s Equity, Diversity and Inclusion Framework, the Sexual Harassment Policy and Aspen’s new Anti-Harassment and Anti-Bullying Policy. Human capital, industrial relations and legal compliance frameworks are in place to uphold employee rights and ensure compliance with labor legislation. During the year 2023, no incidents of unfair discrimination were identified in the Group. The Company’s policies are communicated to staff during induction, regularly through the Company’s communication channels and periodic training sessions. Aspen’s Code of Conduct prohibits any instances of child labor, forced or compulsory labor in its own operations and in contractors and suppliers.
Freedom of Association and Grievance Mechanism:
At the end of 2023, approximately 10% of the Group’s employees were members of a trade union and approximately 31% were represented by collective bargaining councils (10% of employees are members of a trade union and are also represented by a collective bargaining council). Formal processes are in place for engagement with trade union representatives in each country.
The Company has a formal grievance policy accessible to all staff, supported by a three-tier grievance procedure (i.e. Department head, HR, and Management team). Staff members and contractors can lodge anonymous and non-anonymous grievances through multiple channels such as by phone, by email, or via drop boxes. The Company has established a grievance handling committee at each business unit that meets on an ad-hoc basis to review and respond to staff grievances. The HR department confidentially retains a record of all grievance cases.
Occupational Health and Safety:
Following the corporate HIRA procedure, all business units manage OHS processes by conducting risk identification and mitigation processes. Health and safety induction is provided to employees, external contract workers and visitors. Regular safety training programmes are provided to employees as well as external contract workers.
The total recordable incident frequency rate (‘TRIFR’ – reflects the percentage of employees who experienced reportable incidents, which include minor medical cases other than first aid treatment, over the 12 months ended 30 June 2023 per million work hours) has for 4 consecutive years been below 1.5. The 2023 TRIFR was 1.16 (versus 3.0 for pharmaceutical and medicine manufacturing, www.bls.gov). No occupational fatalities were recorded. Compliance control measures are in place across the supply chain to address the safe and compliant handling and transport of all materials and products.
Third-party Workers and Supply Chain:
Aspen’s Code of Conduct for suppliers requires that suppliers and service providers undertake responsibility for conducting business in compliance with applicable environmental laws and regulations. Through the Group’s Contractor Management Standard, each business unit establishes, implements, and maintains a documented contractor (including sub-contractors) management program. The program supports the Company in identification, evaluation and control of safety, health and environmental hazards/aspects and risks/ impacts associated with contractors and sub-contractors.
The Company uses a set of criteria to evaluate and select potential suppliers and contractors and undertakes regular supervision of the activities of selected service providers, which includes a risk-based contractor compliance evaluation and inspection programme. Supplier and contractor agreements include binding SHE-related clauses such as requirements on waste management, OHS, labor and working conditions.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas (‘GHG’) Emissions:
Electricity is mainly sourced from the national grid in each host country with renewable sources such as solar also being utilized. Additional energy sources utilized by Aspen are fuels, liquid petroleum gas, purchased steam and natural gas. As part of its energy conservation initiatives, the Company has implemented a series of energy efficient lighting and solar projects and plant and process optimizations.
Water is extensively used in the Company’s manufacturing processes, in the cleaning of equipment and facilities, for employee hygiene, in steam generation and to maintain the required manufacturing environmental conditions. Municipal water is the primary source of water across the Group, although groundwater is also used at some of its manufacturing sites. The Company conducts an annual water risk assessment for all manufacturing sites using a web-based tool to understand their exposure to risks and inform future sustainable water management and water stewardship initiatives. Water conservation initiatives implemented so far, include the installation of process and utility water recovery and recycling systems, the use of efficient closed water-based cooling systems and reconfiguration and optimization of the Purified Water System operation to decrease water rejection cycles.
The main emissions sources are from fugitive refrigerants, and the consumption of fuel and natural gas, primarily used in stationery combustion equipment such as boilers and standby generators, and the operation of Aspen-owned vehicles. The 2023 total GHG emissions (Scope 1 and 2) at Group level were reported at around 149,000 tons carbon dioxide equivalent.
Pollution Abatement:
The Company has implemented initiatives on air quality measurements and incorporated periodic stack emission tests and installation of technically advanced air handling systems and exhaust filtration systems at all relevant facilities.
Twenty-three percent (23%) of Aspen’s waste is classified as hazardous. The Company has established and implements a corporate waste management standard to manage both hazardous and non-hazardous waste in compliance with the waste management legislation applicable in each country. The Company uses specialized licensed waste management service providers to manage the transportation, treatment, and disposal of waste in accordance with contracted terms and relevant host country legislation. In 2023, the Company reported a reduction (4%) in total waste generated and an improvement in the percentage of waste recycled from 80% to 86%. Two percent (2%) of total waste generated is landfilled (previously 5%).
The quality of effluent discharge is monitored and controlled across all sites, in accordance with local municipal by-laws. Wastewater treatment plants are in operation where required to ensure legal compliance to local permit conditions.
PS4: Community Health, Safety, and Security
Most Aspen manufacturing facilities are located within industrial zones. In cases where there are local communities in proximity to a Company facility, during the EIA process and subsequent facility-level EPRP planning, local stakeholder feedback is incorporated into SHE risk mitigation and into EPR plans. Compliance control measures are in place for supply chain, to address the safe and compliant handling and transport of materials and products.
Unarmed security personnel are employed at Aspen facilities, some security personnel are employees, and some are employed through security contractors. The Company has security policies and procedures for access control and security systems across all manufacturing and commercial sites to prevent unauthorized entry.
