If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards. 

This is a Category B project based on IFC’s 2012 Policy on Environmental and Social Sustainability. IFC’s review concluded that E&S risks and impacts associated with this project are limited, site-specific, and can be readily addressed through generally accepted mitigation measures described in this document and the Environmental and Social Action Plan (ESAP). The key E&S risks and issues for this investment are: (i) effective implementation of the E&S Management System (ESMS), organizational capacity/competency of its environmental, health, safety and social (EHSS) and agronomic functions; (ii) HR and OHS Management Systems for assurance of fair and safe working conditions for direct, seasonal workers and contractors, including workers’ grievance management; (iii) promotion of Good Agricultural Practices (GAPs), including soil conservation, water and solid/hazardous waste management, Integrated Pest Management (IPM) and use of agrichemicals, and biodiversity conservation, including certification against a credible sustainable production standard; (iv) E&S supply chain requirements applying to the out-grower scheme; (v) stakeholder engagement and community grievance mechanism.                                                   

Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts

E&S Policies. PCS adopted a Group-level E&S Responsibility Policy, setting out the objectives and general approach for its subsidiaries, including PCA, and aligning with the principles of ISO 26000 on social responsibility. Going forward, PCA will develop and implement a Farm E&S Policy to align the E&S requirements and performance of its farm operations with IFC PS requirements (ESAP #1). The Farm E&S Policy will i) highlight the company’s commitment to address and mitigate all E&S risks associated with its onion production; ii) achieve an efficient management of natural resources and the protection of the surrounding environment; include the iii) prohibition of child and forced labor ; iv)  prevention of Gender Based Violence and Harassment (GBVH) and enhance gender inclusion; v) meeting IFC PSs, applicable national and regulatory requirements, WBG EHS Guidelines (General and Annual Crop Production - http://www.ifc.org/ehsguidelines) and Principles and Criteria of a credible agriculture production standard (e.g. Global Gap for crops and Rainforest Alliance). The Policy will also include a Code of Conduct applicable to all its workforce, contractors, service providers.  and third-party suppliers, including the out-grower scheme. This policy will also commit PCA to achieve certification of its farm operation against a credible agriculture production standard (e.g., Global G.A.P for crops or Rainforest Alliance). Existing and future employees and third-party suppliers (from the out-grower scheme) will acknowledge the provision of the E&S Policy as part of the employee and suppliers onboarding and induction process.

E&S Risk Assessment. As mentioned above, PCA prepared a local ESIA study in 2023 as per national regulatory requirements covering the entire 646 ha project area. In April 2023, the National Environmental Protection Agency (EPA) issued a certificate confirming the receipt of the study and requested that PCA proceed to the next stage of E&S assessment process, including ground truthing. The ground truthing phase was completed in July 2023 and a revised draft ESIA version was submitted to the EPA. This draft version is undergoing final review by EPA before issuing an environmental license, including Terms and Conditions (T&Cs), which is expected by August 2024. PCA will secure all required legal and regulatory approvals (licenses and permits) prior to the IFC financing, including, among others, for environmental, labor, agrichemical, and water issues (ESAP#2). An updated ESIA study was commissioned in 2024 to further assess specific IFC PSs related risks and impacts associated with the 646-ha farm operation and the Project’s out-growers’ scheme, including the land leasing process, existence of biodiversity values and ecosystem services, and sustainable abstraction of groundwater. The updated ESIA study includes impact assessment studies for (i) hydrology and hydrogeology, (ii) aquatic and terrestrial ecology, (iii) air quality and noise, (iv) climate change, and (v) socio-economic baseline of the adjacent four villages. Key E&S risks identified in the updated ESIA study of 2024 include: (i) potential adverse impacts of the project affected communities (PACs) due the proximity with the farm operation; (ii) impacts on livelihoods activities due to the restriction of access to unused land, (iii) impacts on critical and natural habitats, (iv) community health, safety and security, (v) labor and occupational health and safety impacts; (vi) supply chain related risks of the out-grower scheme. The updated ESIA study has allowed to avoid and/or minimize E&S risks through the amendment of the design of the farm. Draft E&S Management Plans (ESMPs) have been developed based on the local and updated ESIA studies for the farm operation. The implementation effectiveness of the ESMPs will be reviewed while being updated annually before the clearing for each 50 ha expansion (ESAP#3). In addition, PCA will prepare an ESMP execution strategy that will include (i) a pluri-annual budget for ESMPs implementation; (ii) human resources required for the execution; and (iii) a monitoring plan. ESMPs budget will be validated and signed off by PCA’s CEO at the beginning of each year.

As a result of the iterative E&S risk assessment process, PCA redesigned the farm from the original footprint to exclude: (i) the Rogbatha village and thus avoiding the need for physical displacement; (ii) an area of 80.6 ha of natural habitat and wetland, and (iii) areas of identified sacred shrines. An additional 300 m buffer zone between the farm and the Rogbatha village will be established to avoid any potential community health and safety risks from the farm operation. As part of the ESMP implementation, PCA will strengthen its E&S monitoring dashboard to track its E&S monitoring programs and results at the farm. More specifically, PCA will enforce the establishment of the buffer zones and re-assess its effectiveness, based on monitoring results on dust, noise and exposure to fertilizers/agrichemicals. (ESAP#3).

A 25-year land lease agreement have been negotiated in 2022 on a willing buyer-willing seller basis between PCA, land owners from the four adjacent villages (Rogbatha, Rogbereh, Mathen and Forikolo), the Lokomasama Chiefdom, and the Government of Sierra Leone. An initial 71 ha of land has been cleared in 2023 and is currently in production to assess farm's yields, including resource needs, such as access to water supply. Whilst access to the farmland is not restricted by any physical fence, residents from the four adjacent villages will continue to have access to the farmland for farming activities until the farm plot is formally brought under production by PCA. During the 2024 ESIA consultation process, the adjacent villagers were informed that the 646-ha farmland would be leased to PCA and will be gradually developed over the next years. Prior to the clearing of the estimated 50ha plot per year, PCA will undertake an assessment of dependencies of the targeted plot and develop/implement a livelihood restoration plan in line with PS5 requirements. This informed consultation and participation process with the project-affected villagers will be part of a formalized Land Access Procedure that will be disclosed to communities and signed off by the PCA's senior management (ESAP#4).

E&S Management System and Programs. At the time of the appraisal, the only available draft SOPs were limited to water monitoring and pesticide usage while their implementation were under the monitoring of the farm manager. Going forward, PCA will develop and implement a PS1-compliant ESMS (ESAP#5). Aside from the Farm E&S Policy (ref. ESAP#1) and the implementation of the E&S Management Plans – as defined in the Terms and Conditions of the Environmental License (ref. ESAP#2) and the implementation of E&S and Agronomic SOPs consistent with Good International Industry Practices (GIIP), such as the WBG EHS Guidelines for annual crop production, and the Principles and Criteria of a credible agricultural production standard for onion (e.g. Rainforest Alliance, Global G.A.P for crops), the ESMS will also include an  E&S implementation plan and training for the farm’s workforce. Other key ESMS’s elements will also include (i) an E&S risk assessment/management procedure for the annual 50ha expansion; (ii) a supply chain management system for the out-grower scheme; (iii) an Emergency Preparedness and Response Plan and procedures; (iv) E&S organization capacity/competency; (v) an E&S monitoring and review system including E&S and Agronomic Key Performance Indicators (KPIs). The PCA's E&S manager, with the support of Community/Gender Liaison Officers (CLOs/GLOs), will have the overall responsibility for the effective implementation of the ESMS. PCA will undertake a verification audit of its ESMS by an independent E&S consultancy firm to confirm compliance with IFC PS requirements and relevant/applicable sections of the WBG EHS Guidelines. PCA will also achieve certification and/or independent verification against a credible agricultural production standard (e.g., Global Gap for crops and Rainforest Alliance) for its farm, including proposed future expansion (ref. ESAP#1).

E&S Capacity and Competency. Since the early development stages of the farm, the identification and management of the E&S risks and impacts has been under the responsibility of PCA’s CEO and farm manager. A Community Liaison Officer (CLO) was also hired for the stakeholder engagement, especially with the four adjacent villages and local authorities. An additional CLO oversees the relations with farming associations involved in the out-grower scheme. With the ongoing expansion of the farm and increasing E&S requirements per this IFC financing, PCA has appointed a full-time E&S manager in May 2024. The E&S manager will have the responsibility to develop/implement a PS1-compliant ESMS at the farm (ref. ESAP#5), including ESMPs and E&S/agronomic SOPs. An additional CLO will be also hired to support (i) the development/implementation of the Land Access Procedure (ref. ESAP#4), including the progressive land clearing process associated with the additional 50ha plot each year and (ii) the engagement activities with cooperatives and individual farms associated with the expansion of the out-grower scheme (ESAP#6). A Gender Liaison Officer will also be hired to enhance engagement to address Gender-based Violence and Harassment risks associated with the Project – see PS2 section. 

The HR aspects is still under the responsibility of PCS Group HR manager. A PCA’s welfare officer at farm level is responsible for all the administrative aspects of hiring seasonal labor for planting and harvesting season. Going forward, PCA will hire an experienced HR officer based at the farm to oversee HR and labor-related aspects, including the development of an HR management system, compliant with Sierra Leone Labor Code and PS2 objectives. PCA will also develop/implement an annual E&S training curriculum and schedule covering E&S management practices and SOPs, including OHS work permit and procedures for its staff based on workplace hazard (ref. ESAP#5).  In compliance with the national labor regulations, PCA will establish an Occupational Health and Safety (OHS) committee at farm level, composed of PCA management team and workers. The committee will also cover the out-grower scheme and will develop and deliver daily safety toolbox meetings, while monitoring the implementation of leading and lagging OHS indicators.

Emergency Preparedness and Response. PCA has yet to develop and implement an Emergency Preparedness and Response Plan (EPRP). Fire safety installations (e.g., fire hydrant system) are lacking, including at the hazardous materials (diesel) storage area. As part of the ESMS (ref. ESAP#5), PCA will develop/implement an EPRP, consistent with PS1 and GIIP. PCA will collaborate with local government agencies to respond to emergency situations while communicating its EPRP to adjacent communities. The EPRP activities will be commensurate with possible emergency scenarios (fire, flood, agrichemical spill, heat wave) and will be periodically updated.

E&S Monitoring and Reporting.  PCA will define an internal E&S monitoring and reporting procedure for the farm operation and the out-grower scheme, including the definition and measurement of key performance indicators (KPIs), such OHS leading and lagging indicators, resource (water and energy) usage and efficiency, pollution control i.e., air emissions, noise, effluents monitoring, solid/hazardous waste management, and handling/application of pesticides. The KPIs will be consolidated into a monitoring/ reporting dashboard and shared annually to PCA’s management for review and corrective actions, as necessary.

Supply Chain Risk Assessment and Management. In addition to the farm and ancillary facilities (pumping house, drip irrigation system, agrichemical warehouse), PCA is also developing an out-grower scheme, through pre-harvest agreement to buy onions' produce from smallholder farmers.

PCA’s out-grower strategy includes signing service agreements with farmers groups located in the project area.  In 2024, PCA signed service agreements with 45 farmers cooperatives, reaching around a totality of 1350 farmers, 82% of which are female. The cultivated area for each cooperative range between 0.6 – 3 ha. As part of the project development, PCA intends to target 5,000 farmers in its out-grower scheme over the next 10 years. The general irrigation pattern observed is hand irrigation, on few occasions, some groups pump water from small reservoirs using generators, small solar generation power and hosepipes. Transport from the farmer groups’ site to the farm is provided by the Project. 

In the service agreements, PCA agrees to supply cooperatives with seeds, insecticides, herbicides, fertilizers and to buy onions from out-growers at market price. Other information included in the services agreements include numbers of members, size of land and minimum amount of onion produce to be sold to PCA. PCA’s CLO also provides basic agronomic and safety training, and safety equipment (gloves for handling of chemicals) to the out-growers. PCA is also responsible for the transportation from the storage facilities in the villages to Freetown. PCA will enhance the service agreements template with the farmer groups and include: (i) evidence of a lawful occupancy of the land (i.e., customary ownership, land lease, freehold, tenancy agreements); (ii) a formalized checklist of seeds/chemicals and training delivered to each cooperative; (iii) avoidance to any additional land clearing without any prior agreement from PCA; (iv) inclusion of an out grower Code of Conduct (ESAP#7). In case of a formal request of land expansion from a cooperative participating to the out-grower scheme, PCA will undertake a rapid biodiversity risk assessment to avoid conversion of natural habitats and/or impacts on key biodiversity values.

The out-grower Code of Conduct will include, among others, provisions on (i) prohibition and no tolerance of child labor and forced labor; (ii) handling and safe use of agrichemicals and fertilizers; (iii) measures against GBVH; (iv) no expansion of onion production on key biodiversity areas or conversion of natural habitats without prior agreement from PCA; (v) sustainable reporting and monitoring criteria to PCA.

Key E&S risks associated with the out-grower scheme include: (i) occupational health and safety (use and handling of agrichemical); (ii) incidence of child labor; (iii) gender-based violence and harassment (GBVH) and (iv) biodiversity risk due to the potential conversion on natural habitats during land clearing.  To address PS2/PS6 supply chain risks, PCA will develop/implement a supply chain management system (SCMS) covering, but not exclusively: (i) a Supply Chain Sustainability Policy aligned with IFC PS2/PS6 risks and P&C of a credible agriculture production standard; (ii) the Out-Grower and Supplier Code of Conduct; (iii) training to PCA  purchasing team and CLOs on Supplier Code and E&S/agronomic SOPs as well as to all out-grower participants; (v) annual independent verification audit for validating the effective implementation of the Out-grower Code of Conduct; (vi) establishment of a Child labor management and remediation system (ESAP#7).

As part of its stakeholder engagement plan, PCA will develop/implement a communication campaign with the out-grower to prohibit use of child labor, avoidance of exposure to agrichemical product and significant conversion of natural habitat. (ref. ESAP#22).

Performance Standard 2: Labor and Working Conditions

As of May 2024, PCA employs 10 direct workers and 162 casual workers, of which the majority are nationals of Sierra Leone and 82% are women. The number of casual workers vary according to the farm’s activities. The client’s target for the next season is around 500 seasonal hires. These employees are mostly mobilized from the four neighboring villages. The farm manager has an oversight of on-site HR matters and is supported by the welfare officer and the Group HR manager. 

Human Resource (HR) Policies and Procedures. PCA has adopted the PCS Group HR manual, aligned with the Sierra Leone Labor Code, which outlines several HR policies and procedures, including a Code of Conduct (CoC), a recruitment policy, an anti-bribery and corruption policy, and general terms and conditions of employment. The following HR gaps with PS2 objectives have been identified in this manual: (i) prohibition of sexual harassment and gender-based violence (GHVH), (ii) employees’ contracts, for both permanent and seasonal labor, (iii) worker’s grievance mechanism, (iv) retrenchment, (v) freedom of association, and (vi) labor and OHS policies and (vii) procedures for workers engaged by contractors. PCA will update its HR manual and disseminate in a language accessible to all its workforce its HR policies and procedures in a manner consistent with national Labor Code and PS2 requirements (ESAP#8). 

Working Conditions and Terms of Employment. The PCS Group HR manual defines the general terms and conditions of employment for all employees in line with the Sierra Leone’ Labor Code and the collective bargaining agreement for the Shipping, Clearing and Forwarding Trade Group and employees’ unions.  The HR manual includes the rates schedule that sets out the different allowances and leaves available to PCA permanent employees. The minimum wage at farm level aligns with the statutory minimum wage in Sierra Leone, and PCA maintains electronic pay slips for all permanent employees showing the number of days worked, basic salary and additional allowances, and statutory social security and tax deductions. Permanent workers receive letters of employment established in accordance with the national labor regulations, which specify basic salary and regulatory deductions, and reference allowances as per the Industrial Trade agreement. Casual workers are mainly recruited for weeding and harvesting activities. The casual workers receive a letter of appointment for 6 months. During this period, they work full-time at the farm for 3 months; while for the remaining three other months, as agricultural work can’t be performed because of the rain they mostly don’t work, even if they can occasionally be requested to help on the farm. Both permanent and casual workers have access to PCS Group's contracted health clinics located in Freetown. PCA support workers with a transport allowance to reach the farm. A certain number of casual workers have reported during the appraisal of not being aware of any written record detailing their entitlements and obligations. In addition, the recruitment of casual workers is carried out through an informal process without clear selection criteria and distribution amongst the four villages. PCA will develop/implement a local employment plan (i) clarifying the recruitment criteria among the four adjacent villages and clearly explaining the employment’s terms and conditions to all casual workers; (ii) developing record-keeping procedures; (iii) strengthening identification and registration of all casual workers; and (iv) revising casual worker’s contracts in a manner consistent with national labour laws and IFC PS2 requirements (ESAP#9). 

A changing facility with gender-segregated compartments and equipped with showers and toilets has been built on site. A canteen has also been recently built in proximity to the farm. Regular checks will be implemented by the HR/E&S team to verify the hygienic conditions and define any corrective actions, if needed in line with IFC/EBRD Worker Accommodation Guidelines. As the planned farm workforce will be recruited from the adjacent villages and on a casual basis, PCA has no plans to build worker’s accommodations at the farm. Should any changes in its workers’ accommodation strategy or expansion of the current facilities change int the future, PCA will ensure that the facility will comply with the requirements of the abovementioned Guidelines (ESAP#10).

There is no transportation provided to workers to the farm; however, a transportation allowance is delivered as part of the benefit’s package for direct and casual workers. During the site visit, workers expressed their concerns on (i) the long time and distances taken to reach the farm, except for Rogbatha village, all other communities live 2 to 4 km from the farm and (ii) the safety issues related to the use of the communal road to the site. As part of its road transportation risk assessment, PCA will conduct a needs assessment for worker transportation and identify the best approach to minimize workers’ time to the farm. In case of provision of transportation, PCA will conduct a risk assessment and will implement a transportation safety plan in line with IFC PSs (ref. ESAP #17). Please refer to PS4 and ESAP section for details.

Workers’ Organizations.  The PCS Group HR manual outlines the right of every employee to join a worker's organization of their own choice without previous authorization, as per the provisions of the national Labor Code. At the time of the appraisal, none of PCA employees have joined and/or formed a union or workers organization. As per ESAP#8 above, PCA will update its HR policies and procedures to clarify its approach to freedom of association and collective bargaining in line with national Labor Code and IFC PS2 requirements. 

Non-discrimination and Equal Opportunity. The PCS Group HR manual outlines a commitment to non-discrimination and equal opportunity. However, the HR manual stipulates that for employees who already benefited of one maternity leave, an interval of two years is required before another maternity leave is granted. As part of the proposed update of HR manual, PCS will include the principle of non-discrimination on the basis of pregnancy or maternity that will be applied to all its permanent and casual workers (ref. ESAP#8). Gender-based violence and harassment (GBVH) is prevalent in Sierra Leone and PCS HR procedures allow for compassionate / personal leave including for cases where employees need to deal with legal matter pertaining to sexual assault or domestic violence. The HR manual and CoC will be updated to address Gender-Based Violence and Sexual Harassment (GBVSH) in the workplace and within communities and will be supported by an induction training and annual refresher training for all farm employees (ref. ESAP#8). To better capture the gender aspects of the community engagement, PCA will recruit an additional Gender Liaison Officer (GLO) with specific focus on enhancement of gender-based initiatives at the farm and in its out-grower scheme (ref. ESAP#6).

Workers’ Grievance Mechanism. PCS HR manual has an internal grievance procedure for permanent employees. The procedure lacks specific provisions for non-retaliation and gender-based violence and harassment (GBVH). PCA will enhance and disseminate a grievance mechanism accessible to all workers, including seasonal workers and third-party contracts. The mechanism will outline (i) available channels to submit grievances (including separate channels for grievances related to sexual harassment, and for confidential and anonymous complaints); (ii) roles and responsibilities for treating and responding to grievances; (iii) timeline for taking corrective action; and (iv) system to log, track and report grievances and their status in accordance with PS2 requirements (ref. ESAP #8). These procedures will be documented, and appropriate worker sensitization undertaken through in-person sessions and dissemination of information on appropriate channels. All personnel (staff, contractors and third parties) involved in managing sexual harassment grievances will receive additional specialized training.

Protecting The Workforce.  The PCS Group HR manual has provisions on the prohibition of child labor and forced labor in the Group’s direct and sourcing operations. Furthermore, the minimum age of employment at PCA is 18 years, and proof of identification and age will be required at the time of employment. 

Occupational Health and Safety. Key OHS risks for workers at the farm includes exposure to hazardous pesticides and herbicides, musculoskeletal conditions due to repetitive motion, overexertion and manual handling, potential accidents from use of farming machinery and vehicles, exposure to heat and dust during weeding and harvesting activities. Other working condition-related issues that were observed during appraisal included insufficient in-field water and lack of shade facilities. PCA does not have a consolidated Occupational Health and Safety (OHS) policy, SOPs manual and/or worker permit system. OHS KPIs for leading/lagging indicators and incident reporting have not yet been implemented nor monitored. Going forward, PCA will develop an OHS management system, based on workplace risk assessment and SOPs for its farm operation. In a manner consistent with GIIP and as per applicable and relevant sections of the WBG EHS Guidelines (General and Annual Crop Production), the OHS SOPs will address issues that include the (i) identification of potential hazards to workers, particularly those that may be life-threatening or cause long-lasting damage; (ii) provision of preventive and personal protective equipment, including improvement of storage room, drinking water provision,  provision of shade areas to prevent heat-stress, elimination or substitution of hazardous conditions or substances; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents (including KPIs); (v) heat stress management plan and (vi) emergency prevention, preparedness, and response arrangements (ESAP#11).  

The farm is located in remote areas with limited access to health services. PCA will secure first aid kits at farm site and will designate staff to receive first aid training to provide immediate assistance. In the future, a full-time nurse and walk-in clinic will be established at the farm. PCA will establish a contractual agreement with a neighboring hospital to handle major injuries. As part of the OHS management system, PCA will develop a workplace monitoring program and a medical surveillance program for workers (ref. ESAP #11).             

Life and Fire Safety.  PCA does not conduct periodic fire safety training on general awareness, prevention, evacuation, and fire safety. Life and fire safety installations (e.g., fire hydrant system) are lacking at the farm and at its associated facilities (warehouse). Once the construction of the farm facilities (e.g., agrichemical warehouse and water reservoir) is completed, PCA will obtain the final-construction fire safety certificate from the national authorities. PCA has engaged the National Fire Force to train workers on fire safety and prevention; a L&F safety professional will be also engaged to assess that the construction of the facilities has been carried out in accordance with the approved design and in line with the L&FS section of the WBG General EHS Guidelines (ESAP#12).

Workers Engaged by Third Party Workers. PCA makes use of a limited number of third-party contractors, predominantly for construction activities of farm’s facilities, such as the water reservoir and storage areas. As part of the HR policies and procedures, PCA will formalize its contractor selection and management procedure, including contractual provisions, that will include the vetting and ongoing monitoring of contractors’ safety, compliance with labor law, and applicable EHS and working conditions and labor standards and policies. In addition, the contractor management process will ensure that all contractors have access to PCA worker grievance mechanism (ref. ESAP#8).  Labor and working conditions performance of contractors and service providers will be audited as per the procedure established as part of the ESMS (ref. ESAP#5). 

Performance Standard 3: Resource Efficiency and Pollution Prevention

Resource Efficiency. The farm relies on three diesel generators of a capacity of 550 kw each (genset) and PCA is currently investigating supplementing their existing energy supply mix with solar energy where feasible. Fuel consumption is monitored and recorded on a monthly basis. Process water is obtained from five permitted 70 meters deep boreholes located within the premises of the farm.? PCA conducted a hydrogeological analysis and did not identify any risk to the shallow wells used by the neighbouring communities.  Water is pumped from the boreholes into an 80,000 cubic meters above ground reservoir for subsequent usage. As part of the ESMS, PCA will improve its water resource sustainability by implementing water use efficiency measures and establishing relevant KPIs as part of the E&S monitoring procedures. Also, PCA will extend its monitoring to ground water level through the installation and use of piezometers or using existing community water wells as monitoring locations (ref. ESAP#5).?

Greenhouse Gases.  The Scope 1 and 2 emissions of the Project will increase from 930 tCO2e/year at year 1 to 20,860 tCO2e/year at the completion due to accumulative impacts of additional agri-inputs, land clearing and fuel usage in the vehicle fleet. Therefore, the annual average Scope 1 and 2 emissions of the Project are estimated to be around 11,120 tCO2e/year.

Air Emissions and Ambient Air Quality. Air pollutant emissions from the project are expected to include particulate matter (PM) from land preparation, soil cultivation, crop harvesting, and vehicles travelling on unpaved areas, ammonia, and nitric oxide emissions from volatilization of fertilizer and nitrification of soils, combustion product (SO2, NOx, CO) emissions from vehicle and generator exhaust, as well as from crop and cleared palm trees burning, and VOC emissions from pesticide application and biogenic emissions from standing crops.?PCA will develop an air quality management plan which will define the approach to monitoring and control measures and ensure compliance with local requirements and WBG EHS Guidelines, including within the communities close to the operations (ref. ESAP#5). More specifically, the ambient air quality sampling of PM10, PM2.5, NO2, VOC and NH3 concentrations will be undertaken at Rogbatha once Phase 3 activities commence. Sampling should be conducted at representative times during the dry season, such as during land preparation, the growing season and harvesting. ?The land leased is mostly covered with overgrown palm trees. Most of the cut trees for the pilot phase have been burned, and part of the ashes utilized on the cultivated fields as a pH-regulator. Going forward, PCA will establish and implement a no-burning policy on site. PCA will use mechanical uprooting and avoid open burning of cut trees during site preparation, field operations, and post-harvest, as per WBG EHS Guidelines for annual crop production and voluntary standard for sustainable agricultural production. Cut trees will be stored in a protected place. In addition, PCA will assess controlled burning in energy production facilities to extract thermal energy for beneficial use. Where burning is unavoidable, this should be covered by a risk assessment and an implementation of identified control measures (ESAP#13). 

Noise.?The noise impact assessment completed as part of the ESIA upgrade has highlighted that the current machinery (tractors, bulldozers, generators, etc.) used for operations, can generate high levels of noise on site, which may exceed the exposure limits set in the WBG EHS Guidelines. In addition, the farm operations (including the traffic) are not expected to be a permanent source of nuisance to nearby residents. PCA will include noise monitoring requirements for sensitive receptors in Rogbatha and Mathen as part of its E&S monitoring procedure especially when noise generating activities are occurring next to sensitive receptor. (ref. ESAP#5).? 

Water Supply.  PCA operates 4 bore wells (BH1-BH4) with a depth between 60m and 75m at its central well field (and a fifth well BH0 for the monitoring of groundwater levels), of which 3 wells are productive with a total capacity of 45 l/s, or on average 15 l/s per bore well. Sixteen community wells were identified in the vicinity of the farm, of which 9 are located very close to farm production areas. Community wells depths ranged between 15 and 23 m and water levels between 7.8 and 17.5 meter below ground level. The latest hydrogeological impact assessment of 2024 estimated that the groundwater reserve available for irrigation is 13.36 Mm3/year (based on the average groundwater recharge rate), over the delineated aquifer area of 33.53 km2. The average irrigation demand for onions is estimated at 5,660 m3/ha, equalling 2.83 Mm3 for the net irrigated area of 500 ha per growth season. The peak demand by mid-season is estimated at 57.9 m3/ha/day (but much less during most of the growing season), requiring 20 additional bore wells with a capacity of 15 l/s. The estimated irrigation demand at full development is only 21% of the estimated catchment groundwater recharge. Thus, groundwater resources will be sufficiently available for the farm, without the need for additional surface water resources.

Extensive groundwater modelling has shown that for the most part there will be no impact of groundwater abstractions for the farm on groundwater levels in surrounding shallow community wells, possibly with the exception of 2 or 3 community wells in Forikolo. The groundwater is moderately acidic (pH between 5.9 and 6.2), which is suitable for union crops. However, the soil pH is 4.5 with low levels of phosphate, potassium, calcium, and magnesium in the soils, and the application of lime, phosphate, potassium, calcium, magnesium, and organic matter have been recommended to improve the pH and overall soil quality for optimal onion farming. PCA will hire a suitably experienced irrigation specialist or an ad hoc irrigation consultancy, to (i) design the dry season cropping/planting schedule,  (ii) design the drip or central pivot irrigation systems with the aim to maximize the irrigation efficiency, (iii) advice PCA on the optimal and cost effective way for increasing the low soil pH through lime application or otherwise, and (iv) optimize the proposed well field development in terms of location and abstraction rates in order to minimize the impacts on community wells. The Irrigation Specialist will develop and implement an Irrigation Strategy defining inter alia: (i) the irrigation design aimed at optimizing water use and reducing peak demands; (ii) a water abstraction strategy; (iii) a monitoring strategy and protocols for both surface and groundwater; (iv) monitoring and analysis of water consumption; and (v) an adaptive water conservation management plan. This strategy will be developed and implemented in accordance with PS3 requirements and applicable WBG EHS Guidelines (ESAP#14).  

Water quantity and quality monitoring. The monitoring of groundwater levels and of the abstracted volumes of ground water will be implemented as soon as possible for the production boreholes, as well as for the monthly groundwater level monitoring of community wells in Forikolo and other key locations as identified through groundwater modeling. Borehole samples were collected and analysed in March 2024 and parameters were compliant with the WHO water quality guidelines for drinking water, except for the pH which were below the WHO guidelines of 6.5. With the proposed expansion of farming activities, surface water might be impacted following events such as hazardous materials spills or leaks or inadequate waste disposal. PCA will develop a water management and monitoring program that will (i) install meters at crucial locations to assess water quality in sampling locations, including at-risk community water wells; and (ii) integrate all pollution management and monitoring actions relevant to the protection of the surface and groundwater resources, as well as stormwater management. Monitoring results will be reported in an Annual Monitoring Report to be submitted to IFC. PCA will engage the surrounding stakeholders to minimize the impacts of water extraction on downstream communities and ecosystems. In case the water monitoring plan detects a negative impact on groundwater and surface water use by other stakeholders, PCA will mitigate such impacts by providing medium-depth wells for the affected communities (ESAP 15).

Effluent Treatment Plant. Wastewater from the farm operations is currently managed via a septic tank system. As per the local ESIA, PCA is considering the installation of a small-scale wastewater treatment facility, the Biorock Wastewater system, which is a compact non-electric residential wastewater treatment plant. As part of the ESMS, PCA will (i) develop a wastewater management procedure consistent with WBG General EHS Guidelines; and (ii) conduct effluent analysis at the wastewater treatment facility (once installed) to demonstrate compliance with national regulatory requirements and WBG EHS Guidelines (ref. ESAP#15).?? 

Crop Residue and Solid Waste Management. PCA’s farm operations generate non-hazardous waste, including cleared palm trees and crop residue, plastic, wood, metal. Most of the waste is stored in designated areas and collected by licensed service providers at the farm. PCA plans to allocate a dedicated organic waste/composting area within the farm. This designated space will be utilized for storing and composting various materials, including crop residues (such as leaf material, roots, and plant parts) as well as organic and agricultural waste (such as old plant material and poor-quality vegetables not suitable for the market). Additionally, given the significant quantities of palm trees cleared during the land clearing/construction phase for the 71ha pilot plot, these trunks can be repurposed either by converting them into mulch and/or compost using a woodchipper for use on the farm, or alternatively, they may be provided to the community as building materials, if feasible. As a component of the ESMS (ref. ESAP#5), PCA will develop and adopt a Solid Waste Management Plan defining their waste management strategy and approach to sorting, handling, storage, and disposal which are consistent with applicable legal and IFC PS3 requirements.? 

Hazardous Materials Storage and Management. Hazardous materials storage at the farm includes a 40,000 cubic litres diesel storage tank for the three generators, enclosed within a self-bunded container. Hazardous chemicals (pesticides, herbicides, etc.) are also stored in a dedicated building at the farm, however with uncontrolled access and inadequate storage (e.g., lack of labels and Material Safety Data Sheet, segregation). For the Crop Protection Product (CPP) application, the water from the reservoir is directed into the fertigation system. Within this system, the water is combined with the necessary fertilizer before being conveyed into the drip irrigation system. PCA will undertake a cholinesterase test for the CPP sprayers and develop a procedure for the reception, handling and storage of hazardous materials aligned with IFC PS and WBG EHS requirements (ref. ESAP#5).  

Integrated Pest Management. PCA will develop and adopt an Integrated Pest Management (IPM) program in accordance with the requirements of IFC PS3, applicable WBG EHS Guidelines and credible agricultural production standard. The IPM program will cover (i) selection of pesticides low in human and ecosystem toxicity, (ii) packaging and storage requirements, (iii) manufacturing by licensed and approved entities, and (iv) an appropriate application and storage regime (ESAP#5). 

Performance Standard 4: Community Health, Safety & Security

Community Health and Safety. The local ESIA adequately assessed the increase in community health and safety risks during the establishment of the 71ha pilot, including (i) nuisance from noise and dust; (ii) risks of GBVH and sexually transmitted infections (STIs) due to workers/community interactions; (iii) potential influx from the region for people seeking job opportunities at the farm; (iv) uncontrolled access to farm’s ancillary facilities (e.g., water reservoir; fuel and chemical storage material). PCA will develop and implement a community health and safety management plan which will integrate the proposed mitigation measures included in the 2023 and 2024 updated ESIA studies (ESAP#16). During the land clearing process of the 71ha, PCA has been stockpiling biomass material such as palm and other trees on the border of the cultivated area. The surrounding communities are using these trees for charcoal making use and income generation. As per ESAP #13, PCA will avoid any open burning of trees within or near the farm. PCA will also identify a storage area for cut trees that will be guarded and not accessible by the surrounding communities. Furthermore, a formal livelihood engagement plan with the four adjacent villages will be develop and implement for income generating activities (ref. ESAP#5).  

Traffic Safety. The farm is accessible via a 5km rural road off the main Lungi-Port Loko highway and passing through a village reaching the farm. The farm has been recently fenced and the PCA is building a road for community use to bypass the farm site. Until completion of the new community road, community members are allowed to use the section located within the farm’s gates. No speed limit measures such as signals and speed bumps are present on this access road and within the farm. PCA will mainly rely on transport service providers during the harvest seasons for the transport of the produce to the distribution centres. Furthermore, additional third-party transportation services will be used by farmers to transport produce to the farm as part of the out-grower scheme. Potential risks include traffic safety due to operations, noise and dust. PCA will conduct a periodic and specific engagement on these matters with the nearby communities by establishing communication channels to raise any concerns with the company’s activities and mitigate risks identified by communities as per its stakeholder engagement (ref. ESAP #16). For road traffic safety, PCA will develop and implement a Traffic Management Plan, including a Road Safety Policy and Procedures consistent with WBG EHS Guidelines (ESAP#17). The Plan will stipulate (i) drivers’ rules and regulations; (ii) requirements for daily inspections; (iii) vehicle speed limits; (iv) rest time for drivers; (v) appropriate behaviours of drivers. Prior to hiring the service providers, PCA will implement a due diligence process for screening prospective contracted drivers including a full session on defensive driving and compliance with E&S provisions of the CoC, including zero tolerance to GBVH. PCA’s E&S manager will be responsible of the implementation of the Road Safety procedures by enforcing the requirements outlined in contracts with all transport providers and contractors, including the ones involved in the out-grower scheme.

Security. Security on site is provided by (i) an unarmed private security company deploying guards patrolling project footprint; (ii) 2 security guards from the PCS corporate office to check entry access at the gate; (iii) two additional officers from the neighbouring communities to facilitate the engagements with the local communities. In addition to that, local police agents provide security services at the farm on 12-hour shifts. The police forces oversee the circulation of vehicles and people through the rural road and prevent the risks of thefts at the farm. In agreement with the national police, PCA will develop and implement a protocol for engagement for the public forces on site, including, but not limited to, specific training on UN Basic Principles on Use of Forces and Human Rights; UN Code of Conduct for Law Enforcement Materials and First Aid Principles. PCA will undertake a security risk assessment for both use of public and private security. The outcome of the security risk assessment will determine the content of the project level security management plan (SMP) aligned with the Voluntary Principles on Security and Human Rights and IFC PS4 requirements. The SMP shall include provisions for third party security providers in terms of section, rules of engagement, appropriate conduct towards workers and communities (including training on GBVH), monitoring and grievance mechanism to receive complaints about the security arrangements and personnel, including GBVH complaints (ESAP#18). 

Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The region is characterised by Western Guinean lowland forests, mangroves, estuarine and freshwater aquatic habitat and cultivated land. It is located within the Scarcies River Estuary Marine Protected Area (MPA) and is 2 km north of the Sierra Leone River Estuary MPA/Key Biodiversity Area (KBA). The following Natural Habitat types were mapped: primary forest and wetlands (seeps, floodplain wetland and estuarine habitat). Nineteen invasive or alien plan species were recorded within the area of influence (AoI).

The project area is associated with Critical Habitat (CH) for a range-restricted aquatic snail, Sierraia leonensis. Other priority biodiversity values include a patch of primary forest which supports an IUCN Red-listed Near Threatened tree species, Albizia ferruginea, and the Northern Ground-hornbill (Bucorvus abyssinicus IUCN Red List - Vulnerable), which was identified in the AoI. 

Project-related impacts on biodiversity include the loss and degradation of Natural Habitat (NH) including associated species, changes to water quality because of erosion and runoff, solid waste disposal in the aquatic environment, pesticide/herbicide runoff, disturbance and potential mortality of fauna communities as a result of collision, noise/vibration, dust and poaching, and introduction and spread of invasive species. PCA will implement a 50m buffer around the Natural Habitat which will avoid physical clearing and will reduce runoff of herbicides and pesticides into the aquatic environment. PCA will regularly monitor the data regularly should the buffer zone be extended, (ESAP#19). In addition, the following management plans will be developed/implemented: spill management plan, influx management plan, storm water management plan and alien invasive plant management plan. A key mitigation measure to minimize impacts on Critical Habitat is the restriction of direct abstraction of water from Kipulun Creek. No residual impacts on CH/NH are anticipated if the proposed mitigation measures are effectively implemented. A monitoring program on the identified impacts will inform adaptive management, if needed (ESAP#20). As the Project overlaps with the Scarcies river estuary MPA, the Project will consult with area sponsors/managers and affected communities and develop an additional program to enhance the conservation of this area (ESAP#21).     

As part of the local ESIA, stakeholders such as local government, regulatory authorities, and local communities (where relevant) were engaged relating to anticipated project impacts and mitigation measures. Further engagement was conducted as a component of the updated ESIA update, including key informant interviews, focus group discussions and stakeholder mapping.  PCA will develop and implement a stakeholder engagement Plan to comply with the IFC PS1 requirements.  The SEP will include the following elements: (i) identification and overview of socio-economic characteristics of the communities around the farm; engagement principles, objectives and criteria for stakeholder engagement; (ii) local regulations and lender requirements; (iii) analysis of key E&S risks and impacts; (iv) summary of engagement activities and stakeholders’ concerns; (v) identification, analysis and prioritization of stakeholders, focusing on those directly affected, including vulnerable groups; (vi) methods and tools to provide information and consult with each stakeholder group, including women, men, youth and vulnerable people; (vii) annual stakeholder engagement activities; (viii) timetable, adequate resources, and responsibilities, (ix) a grievance mechanism that is accessible freely by all parties to and (x) completion indicators for monitoring purposes. Furthermore, to mitigate potential risks of child labor and chemical exposure in the communities participating in the out-grower scheme, PCA will develop an ad-hoc initiative sensitizing the risks of child labor in its operation. (ESAP#22).

PCA will enhance the dissemination of its engagement practice and grievance mechanisms through ad-hoc communication channels on site and in the neighboring communities such as setting up a community information points that will provide periodic updates on project information and phases, job opportunities and community initiatives. The community information point will also serve to collect suggestions from neighboring communities and will be completed by other suitable communication tools suitable for the project area (ESAP #23). Community initiatives include interventions in health and education sectors as per the request of the neighboring communities. As part of the SEP, PCA will formalize its community interventions though a Strategic Community Investment Procedure that will (i) set up the clear criteria and sector for strategic intervention to mitigate project impacts; (ii) identify suitable NGOs partners for the implementation and monitoring; (iii) build up capacity of local communities to transitioning and hand over project intervention (ref. ESAP #22). 

Pee Cee Agriculture Ltd

32E Wilkinson Road

Freetown

Sierra Leone

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IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

In addition, Affected Communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC. The CAO is mandated to address complaints from people affected by IFC-supported business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of IFC.

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Complaints may relate to any aspect of IFC-supported business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC-financed business activity. Complaints can be submitted to the CAO in writing to the address below:

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International Finance Corporation

2121 Pennsylvania Avenue NW

Room F10K-242

Washington, DC 20433 USA

Tel: 1 202 458 1973

Fax: 1 202 522 7400

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The CAO receives and addresses complaints in accordance with the criteria set out in the CAO Policy which is available at: www.cao-ombudsman.org.