This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012), with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures.

Key issues associated with the project include, i) ensuring the effectiveness of the company’s E&S management systems, including occupational health and safety (OHS), ii) alignment of human resources policies and procedures with requirements of PS:2: Labor and Working Conditions, iii) monitoring and management of air emissions, noise, hazardous materials and waste management, iv) stormwater management, and v) public safety and stakeholder engagement.                                                   

 PS1: Assessment and Management of Environmental and Social Risks and Impacts

Assessment:  In accordance with the Environmental Impact Assessment (EIA) Regulations (1999) B5 Plus undertook a Preliminary Environmental Assessment for the Prampram facility, and on this basis, an Environmental Permit was issued by the Ghana Environmental Protection Agency (EPA).  For the TFZ facility and as requested by the EPA, B5 Plus completed a Situational Analysis in February 2024.  This analysis identifies the E&S impacts of the facility and associated mitigation measures and includes an environmental management plan (EMP).  Based on this, an Environmental Permit will be issued for the facility.  While the rooftop solar project does not require an EIA in accordance with national legislation, B5 will undertake an EIA for this activity. As defined in ESAP #1, the Company will engage IFC to ensure this assessment aligns with the requirements of IFC PS’s

B5 Plus needs to submit an environmental management plan (EMP) for each facility every three years to retain the Environmental Permit for the facilities. EMPs dated 2022 have been completed for the Kpone  and Prampram facilities, and the EPA has issued environmental permits for both. The Environmental Permits include various conditions with which the Company needs to comply, and where applicable, these are referenced below.  

Management Systems: B5 Plus has a Quality, Health, Safety & Environment Policy (QHSE) signed by the company Chairman and dated 2020.  In addition, the Kpone and Prampram facilities are certified against ISO 9001, a quality management system; the TFZ site will be certified shortly.  The EMPs for each facility identify the potential E&S objectives of the facilities, the E&S impacts and supporting mitigation and management measures, process inputs, the waste types, and how these will be managed.  Further, the Company undertakes training on key high-risk activities such as working at heights, emergency response etc. However, B5 Plus needs to enhance their EHS management system to support implementation of the EMPs, including procedures and work instructions. Going forward, B5 Plus will develop and implement an EHS management system for all facilities aligned with the requirements PS:1, ISO 14001, OHSAS 18001 (environmental and OHS management systems) and their Environmental Permits.   This will include updating the existing QHSE Policy, defining environmental aspects and impacts for all activities, including objectives and targets, programs, plans, and procedures to support these and work instructions.  The management system will be underpinned by an ongoing training program. These requirements are defined in ESAP #2.

Capacity: Currently the HR Manager is acting as the EHS Coordinator across the various operations.  Each plant has a dedicated Safety Officer.  These officers support toolbox talks at the start of shifts and training on high-risk activities as referenced.  The officers undertake ongoing inspections of work activities during the shifts to ensure these are undertaken in a safe manner.  In addition, per the EIA Regulations, there is an Environmental Committee at each facility comprised of various representatives.  This committee meets quarterly and reviews progress against the relevant EMP. B5 Plus will develop specific ToR for these committees as defined in ESAP #2.

B5 Plus has agreed to appoint an experienced EHS Manager to oversee the implementation of the EHS management systems at the respective plants.  The EHS Manager will be supported by a qualified environmental manager and OHS manager.  Further, the Company will develop and implement an organization structure agreed with IFC to support effective EHS management across the respective operations; refer to ESAP #3.  

Monitoring & Reporting: There is no defined approach to monitoring, though the Company has undertaken baseline ambient noise and air quality monitoring as part of the Situational Analysis for the TFZ facility and ambient air quality and stack emission testing at the Prampram facility. In accordance with the Environmental Permits, each facility is required to submit an annual report to the EPA.  This report documents various E&S parameters such as resource use, available monitoring data, and the quantity of waste generated. The EHS management system to be developed by B5 Plus will include an EHS monitoring plan for each plant, which will incorporate all relevant parameters i.e., air quality, noise, wastewater, and waste management, amongst other.  OHS monitoring requirements are discussed below.  In addition, the information reporting system will be defined to ensure relevant information is regularly reported to appropriate Company representatives, including senior management.  In addition, EHS performance will be reported to the Board at their quarterly meetings.  These requirements are defined in ESAP #2.

Emergency Response: B5 Plus has an emergency response plan that applies to three plants and covers the types of incidents that could be anticipated to occur.  The Company has a crisis management committee that is activated in an emergency.  In addition, there is an emergency response team at each plant.  The teams are trained to respond to emergencies and the Ghana Fire Department undertakes training of the respective teams.  The observed availability of fire extinguishers throughout the facilities was good, though signage defining evacuation routes / muster points requires improvement. Each site is issued a Fire Certificate by the Ghana Fire Department annually following an inspection of the facility.  B5 Plus stated there is a fire drill on an annual basis, however, the approach is not documented. None of the facilities have experienced a fire to date.  Given the differing nature of the 3 facilities, B5 Plus will update the emergency response plan such that it is, i) specific to each facility, ii) defines the approach to training emergency response teams and workers to ensure the facilities can effectively respond to differing emergency incidents, and iii) document the regularity of emergency response drills to be undertaken.  In addition, the Company will review the emergency response signage (including that for nighttime) at all the plants to ensure it aligns with good international industry practice (GIIP).  These requirements are defined in ESAP #4. 

The scope of the Company’s E&S management systems is currently limited and requires enhancement to comply with IFC’s requirements.  However, this will be achieved via the implementation of the project’s ESAP.      

PS2: Labor and Working Conditions

Terms and Conditions of Employment: B5 Plus has some 3,400 workers, of which 509 are employed directly by the Company.  Expatriate workers employed directly by the Company have the required work permits facilitated by and paid for by the Company.  Other workers are all recruited locally and employed via one of 5 labor brokers. All workers have a signed contract (either with B5 Plus or the relevant labor broker) that references required information e.g., contract duration, salary, job profile, level of employment, working hours benefits, and leave, amongst other requirements.  

Workers may join unions and unionized workers at the Company have a collective bargaining agreement (CBA) is signed annually with the relevant union which includes information on wages, working conditions etc.

HR Policies and Procedures and Working Conditions: B5 Plus has a HR Manager, and each facility has supporting workers to manage day to day HR issues.  Labor brokers also have representatives working with the company to support on HR. 

The Company has an HR Manual inclusive of policies and procedures that apply to workers employed directly by B5.  Contracts for expatriate workers include a Code of Conduct with which they must comply, while the requirements for workers employed via labor brokers are all defined in their contracts.

Workers involved with production work 12-hour shifts, 6 days a week, with one day off. Administration workers work 9 am – 6 pm, 6 days a week, with Sundays off.   All locally recruited workers receive 15 days annual leave per the regulatory requirements, and expatriate workers receive leave at the end of their contract.  Sick leave is available to all workers per the regulatory requirements and female workers are provided with 3 months maternity leave.  

National workers are paid for 40 hours per week in accordance with the statutory requirements, with the remainder of their time paid as overtime (paid at 1.5 times the normal daily rate for standard overtime, while on Sundays and public holidays it is twice the daily rate).   All workers are paid more than the minimum salary and the national workers receive weekly and annual bonuses which are performance dependent.  All workers receive meals daily served in on-site canteens.   Transportation is free to all workers, and the Company has buses that access the surrounding areas and pick up / drop off workers. 

B5 Plus pays the labour brokers, who then pay the individual workers.  All workers require a bank account, and B5 Plus monitor payments made by third parties to confirm workers receive their salaries and that the amount is correct.  National workers are required to contribute 18.5% of their salary to social security, which also secures medical access. This comprises a 13% company contribution and 5.5% by the worker.  This approach applies to the managers, assistant managers, and supervisors, while for all other workers, B5 Plus pays the total amount, i.e., 18.5 % of the salary, on behalf of the workers. National workers are also covered with workers compensation paid by the Company.

The Company does not have a policy regarding forced or child labour; however, B5 Plus states that they do not support such activities. Workers are required to provide an identification card for employment purposes that verifies their age; no one under the age of 18 is employed. B5 Plus will update its HR manual to include a policy on forced and child labor and ensure its contracts with labor brokers and other contractors reflect this; refer to ESAP #5.

Discrimination and Equal Opportunity: The contract with expatriate workers includes a Code of Conduct, which incorporates a statement prohibiting non-discrimination and sexual violence.  However, the Company has no overarching policy on non-discrimination and equal opportunity.  Thus, B5 Plus will develop and implement a policy on non-discrimination and equal opportunity for workers employed by the Company.  B5 Plus will also inform workers of the policy; refer to ESAP# 5.

Grievance Mechanism: B5 Plus does not have a dedicated grievance mechanism to raise issues.  Workers are required to report grievances to their immediate superior who can engage the Head of Department if they are unable to resolve it.  If not addressed at this level, the HR department may raise the grievance.  The final recourse is with senior management.  The CBA defines a grievance mechanism for unionized workers and the whistleblowing policy can also be used to raise grievances against a breach in the Company’s HR policies and Code of Conduct. This policy also allows for anonymous reporting, as do the suggestion boxes located at the plants.  B5 Plus will formalize its approach to grievance management by developing a grievance mechanism that clearly documents the process for resolving grievances and the associated time frames. The mechanism will also define the approach, i) to reporting and managing grievances related to gender-based discrimination and sexual harassment and ii) anonymous reporting.  The mechanism will be available to all workers employed by B5 Plus, including contractors and labour brokers should they not have access to similar.  Workers will be informed of the mechanism and training provided to the HR department and labor broker representatives on the application thereof.  These requirements are defined in ESAP #6.

Retrenchment: B5 Plus has never retrenched any workers, including during the Covid-19 pandemic, and this is not currently envisaged given the Company’s expansion plans.  However, in the event the Company the Company does retrench workers, this will be conducted in a way that respects PS2 requirements and include the need to analyze alternatives to retrenchment, development of a strategy to reduce adverse impacts of retrenchment on workers if retrenchment is the only viable option and ensure the process is consultative and based on the principle of non-discrimination. 

Contractor and Third-Party Employees: Contracted service providers include those providing labor, security, food vendors, cleaning, and medical support.  Contractors are also utilized on specific building projects.  B5 Plus will develop a contractor management plan that applies to all contractors and ensures effective oversight and monitoring of contractor performance relative to B5 Plus’s conditions.   The latter will include the approach to be applied by contractors to ensure compliance with national law and the requirements of this PS.  Specifically, this will define the expected human resources policies and procedures, commitments against discrimination, compliance with B5 Plus’s EHS requirements when operating on-site, respect for the rights to freedom of association, key working conditions (wages, hours, benefits), social security registration, medical insurance and tax payments, and guidance to develop a grievance mechanism in line with this PS. These requirements are defined in ESAP #7.

Accommodation: Expatriate staff stay in accommodation blocks on-site, and the facilities align with the IFC / EBRD Workers’ Accommodation Processes and Standards (2009) requirements. Accommodation is provided free of charge.  B5 Plus will review the approach to emergency response at the accommodation blocks to ensure this aligns with the World Bank Group (WBG) General EHS Guidelines, including the requirement for adequate means of exit in the event of an emergency, and appropriate signage; this is addressed in ESAP #8.  There are locally recruited female workers who support the expatriate canteens and the accommodation facilities e.g., cooking, cleaning and laundry services, and reside on-site.  B5 Plus will review the approach to the accommodation of female workers and ensure this aligns with the Accommodation Standard referenced; refer ESAP #8.

Supply Chain: B5 Plus’s has no contracts with scrap suppliers.  Scrap is supplied to the Company by various suppliers operating in the region. 

B5 Plus will develop and implement a supply chain procedure in compliance with PS:2 supply chain requirements. This procedure will i) identify actual or potential risks of child labor, forced labor, and significant health and safety issues within the supply chain, ii) establish and communicate clear expectations regarding child labor, forced labor, and significant safety issues in B5 Plus’s supplier relationships, iii) develop a system to track and monitor supplier performance in areas where these risks are identified, and iv) formulate remediation plans as necessary.  Relative to scrap metal, B5 Plus will identify their primary suppliers, inform them of the supply chain procedure and look to extent the procedures to all suppliers of scrap metal where practical. This requirement is defined in ESAP #9.

Occupational Health and Safety: B5 Plus do not have a formal OHS management system, however, safety is integrated into activities via the support from the on-site Safety Officers e.g., toolbox talks, training on high-risk activities.  Personal protective equipment is provided by B5 Plus to all workers employed by the Company including expatriate staff, while labour brokers are required to provide PPE to workers that they employ.   Safety signage is prominently displayed throughout the plants.

B5 Plus monitors work-related incidents or injuries on site at the clinics, however, this information needs to be tracked.  In addition, workplace monitoring is required for heat stress, noise, and air quality. Each plant has a clinic staffed with a doctor and nurse 24 hours a day, 7 days a week, contracted from a service provider.  Each facility also has an ambulance should workers require transfer to a hospital. Visits to the clinics are typically being due to lacerations and eye injuries; malaria is also common.   B5 Plus covers the medical expenses of all expatriate workers, and national workers are covered by social security.

Workers undergo a medical check-up when they start work, however, there are no regular medical check-ups.

The EHS management system to be developed by B5 Plus will incorporate that required for the OHS management system at the site per the requirements of ESAP#2.  In addition, capacity requirements to support this system are addressed in ESAP#3.  As part of this system and as defined in the related actions, B5 Plus will also develop and implement a workplace monitoring plan and medical checkups for workers to ensure this aligns with GIIP, the requirements of the GIIP in the steel sector, the WBG General EHS Guidelines (2007) and the EHS Guidelines for Integrated Steel Mills (2007).  In addition, the Company will review the approach to machine guarding to ensure this aligns with GIIP and the Guidelines referenced above; refer to ESAP # 10.  

 PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: B5 Plus is installing a rooftop solar plant to improve energy efficiency, reducing the Company’s carbon footprint. Water for production is used in a closed loop system and circulated back to the cooling system.  The Company is undertaking a study to assess the viability of rainwater harvesting.  Where feasible, general waste and used oils are recycled or sold as by-products.  As part of the EHS management system the Company will develop a resource efficiency plan in support of their requirements for similar as defined in their Environmental Permits (ESAP #2).

Electricity, Water & Raw Materials: Energy for the 3 facilities is provided via electricity supplied from the national grid, LPG, HFO (used in the reheating furnaces) and diesel (used in standby generators). Water is supplied from several sources, including the Ghana Water Company, boreholes, and water tankers.  This water is used for cooling, in sanitary facilities and kitchens.  Potable water is provided to all workers as bottled water.  Scrap is the primary raw material. 

GHG emissions: Total scope 1 and 2 CO2 emission of the project are currently estimated at 26,850 tons per annum (excluding the new TFZ plant) and this increase to an estimated 41,300 once the expansion is complete (all facilities).  Note, this figure includes the CO2 emission savings from the solar project.

Based on an internationally accepted methodology, GRP will report GHG emissions to IFC in the Annual Monitoring Report.    

Air Pollution: Sources of point source emissions are the induction furnaces and the reheating furnaces.  Emissions from the induction furnaces are discharged via bag filters.  In December 2023, B5 Plus undertook monitoring of the operational induction furnace at the Prampram facility. While not all the parameters as defined in World Bank Group (WBG) EHS Guidelines for Integrated Steels Mill (2007) were monitored, those that were (particulate matter (PM), sulphur dioxide (S02), nitrous oxide (NOX) and carbon dioxide (CO) indicate compliance with this Guideline and national standards. The Company plans to monitor the induction furnaces at the TFZ facility in Q3 2024, once the plant has been fully commissioned.  

Ambient air quality was also monitored at three locations within the boundary of the Prampram facility in December 2023.  Results for PM were above the national standard while the results for nitrous dioxide (NO2), SO2 and CO were all within the national standards.  Ambient air quality monitoring was also undertaken as part of the Situational Analysis for the TFZ site.   Exceedances well above the national limits for PM were identified, while for SO2 and NO2 the results are within the national limits.  Given the location, there is the potential for activities outside the plant to be impacting the on-site results for PM.  

Per ESAP #11, B5 Plus will commission a suitably qualified consultant to develop an air quality monitoring plan (to be incorporated into the EHS monitoring plan referenced in ESAP #1) for the 3 facilities that defines the approach to regular point source emission monitoring, including continuous monitoring aligned with GIIP for the sector, the WBG General EHS Guidelines (2007) and WBG EHS Guidelines for Integrated Steel Mills (2007)  and the Environmental Permit conditions.  Based on emission monitoring results of the induction furnaces relative to the parameters defined in the Guidelines for Integrated Steel Mills, B5 Plus will develop an action plan to address areas of non-compliance if necessary.

In addition, the consultant will undertake a baseline ambient air quality program at all 3 facilities.  In doing so, the impact of the Company’s activities will be defined allied to the influence of off-site activities on these.  This exercise will also include the development of an ambient air quality monitoring program for all the facilities, including air quality management plans to mitigate the impacts of fugitive emissions; these plans will include the requirements for similar as defined in the EMP’s, the Environmental Permits for the respective operations and the recommendations of the ambient air quality study (refer to ESAP #11).     

Noise: Noise levels were monitored within the Prampram site in December 2023 as part of the Situational Analysis for the TFZ site.  The results of the day and nighttime monitoring indicate compliance with national standards and those of the WBG EHS Guidelines for industrial areas.  As part of the EHS monitoring plan to be compiled, B5 Plus will include regular environmental noise monitoring at agreed localities with IFC (refer to ESAP #2). 

Water / Wastewater treatment: All the ablutions facilities and kitchens are connected to septic tanks at the respective plants, which are regularly emptied by a service provider. Water is treated on-site prior to use in filtration plants. As there are closed water systems, no process water is discharged.  

Hazardous Materials and Waste Management: There is a need to designate specific areas for storing hazardous materials (e.g., oil in drum etc) and the HFO oil storage tanks need to be bunded; this is addressed in ESAP #12.   The Prampram and Kpone sites have fuel filling stations with underground diesel storage tanks.  These tanks are monitored for leaks via calibrating the amount of diesel used in the tanks regularly.  LPG and oxygen are stored on-site in designated areas in above ground tanks.

While some areas where used oil is stored are adequately bunded and undercover, other areas are not and require similar (refer to ESAP #12). Solid waste is separated on-site and stored in designated areas prior to collection.  Used oils is sold for recycling as is some general waste (paper, pallets etc.) and slag is used for road construction and in the cement sector. Other general waste including sludge from the cooling water system is disposed of by the municipality.

As part of the EHS management system, B5 Plus will develop a waste management plan that includes a waste manifest system. This system will allow the Company to confirm that waste materials, including recycled waste, are appropriately disposed of. Refer to ESAP #2.

Stormwater: Stormwater is collected in a network of stormwater collection drains on the sites and then discharged into municipal stormwater channels outside the facilities.  Stormwater may be contaminated with on-site materials such as oils and wastes that accumulate in the drains.  Thus, B5 Plus will review the approach to stormwater management such that this aligns with their Environmental Permits and the drains are regularly cleaned and contaminated and uncontaminated stormwater is separated and contaminated stormwater is treated e.g., via oil water separators, before discharging off-site.  Refer to ESAP #13. 

Site contamination: The 3 sites are in areas designated for heavy industry, and both the Kpone and TFZ facilities have industrial activities on their boundaries. A municipal waste disposal facility is also on the boundary of the Kpone facility.  As noted, the Prampram site is the first industrial development in the newly designated area, and there is no development in proximity.

Given the nature of the activities at the Kpone and FTZ facilities and considering B5 Plus recently acquired one of the sites, to establish the baseline environmental conditions for soil and groundwater, B5 Plus will commission a Phase I environmental site assessment (ESA) per ASTM E1527-21: Standard Practice for ESA’s by a suitably qualified consultant.  Based on the findings of this Phase I assessment, the need and scope of a Phase II ESA in alignment with ASTM E1903-19 will be defined. Following completion of the Phase II ESA, the Company will agree with IFC on a time-based implementation plan for the recommendations from this assessment as applicable.  In addition, as part of the scope of work for the ESA’s for all sites, B5 Plus will require the consultant to review their activities on-site and make recommendations to, i) limit the potential for the facilities to result in contamination e.g., hardstanding of areas, and ii) define an appropriate monitoring program to assess the site conditions at the facilities in an ongoing to basis to identify if on or offsite activities are impacting soil and groundwater quality.  These requirements are defined in ESAP #14.  

 PS4: Community Health and Safety

B5 Plus uses heavy vehicles to supply materials to the Company facilities including the transport of products to the depots.  The Company validates licenses before employing drivers and there is an annual driver training program supported by the Ghana Driver and Licensing Department.  B5 Plus has a transport Department which manages logistics, and there is a tracking system installed on all vehicles, and cameras are currently also being installed in the vehicle cabs.   To formalize the approach to traffic management, B5 Plus will develop a plan that documents the approach to driver and vehicle management, including the training and maintenance plans, controls to manage vehicle movements off-site, and associated responsibilities.  This plan will define the vehicle flows for the differing vehicle (e.g., material suppliers, scrap suppliers, customers etc.) movements on-site to limit risks to workers and infrastructure, and the controls that will be implemented to enforce vehicular flows, including that of security personnel when providing access to the facilities. Refer to ESAP #2.    

All the facilities have security cameras installed on the fence line with controlled access gates, and all security personnel are unarmed.                                         

The Situational Analysis for the newly acquired Tema facility included engagement with neighboring property owners, while the preliminary environmental assessment for the Prampram facility did not require any engagement. B5 Plus’s regular engagement with stakeholders is limited to that with the authorities.

B5 Plus is strongly committed to Corporate Social Responsibility with various programs in Ghana and the areas adjacent to their facilities. These include support to, i) the B5 Plus care foundation, a charitable organization providing care to underprivileged children via free education and basic medical care, ii) support for the construction of a police station in Tema, iii) medical equipment donations to NGOs, iv) bursaries for student education, and iv) DPS International, a well-recognized centre of excellence in learning, amongst other. 

To formalize the approach to stakeholder engagement, B5 Plus will develop and implement a Stakeholder Engagement Plan that includes a grievance mechanism through which individuals or organizations can raise issues with the Company if necessary. Refer to ESAP #14.                                                          

 Mr. Subhash Kedia

Phone No: 233 244 318 150

Email: finance@b5plusgroup.com

Address: B5 Plus Limited, Kpone Heavy Industrial Area, P.O. Box VO 853, Tema, Ghana