The expansion of the existing SLFM facility includes the acquisition of one acre of land leased from the Government of Sierra Leone convertible to freehold property at the end of the construction activities. No involuntary resettlement is associated to this additional land leased within the Cline Town industrial zone.

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012) due to limited and site-specific E&S risks and impacts associated with the proposed expansion. These can be avoided or mitigated by adhering to Good International Industry Practices (GIIP). Key E&S risks and issues for this investment are: (i) implementation effectiveness of SLFM E&S management System (ESMS) across its operations, including E&S policies, risk assessment studies, E&S management plans and Standard Operating Procedures (SOPs), E&S organizational capacity/competency; (ii) fair treatment and safe working conditions for employees and contractors, including implementation of HR policies and procedures aligned with PS2 requirements; (iii) emergency preparedness and response, including dust explosion; (iv) resource efficiency and GHG emissions; management of air emissions and dust, noise, solid/hazardous waste, and effluent; (v) community safety, traffic and use of security forces; (vi) risk of significant conversion of natural habitat for wheat production; (vii) stakeholder engagement and community grievance mechanism.

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

Environmental and Social Policies and Management Systems. SLFM has developed Quality, Health, Safety and Environment (QHSE) and Human Resource (HR) Policy statements demonstrating its commitment to minimizing its E&S impacts and complying with Sierra Leone E&S legal and regulatory requirements, including (i) quality management policy, (ii) social accountability policy, (iii) HR policy; and, (iv) integrated QHSE policy. To effectively implement this QHSE/HR policy framework, an E&S Management System (ESMS) has been drafted to guide the development of principles for business conduct, the procedures for identifying and managing E&S risks and impacts, E&S procedures for overseeing contractors’ performance and the organizational framework for operating the ESMS. Going forward, SLFM will develop and implement a PS1-compliant ESMS to include the following elements: (i) identification and assessment of E&S risks and impacts; (ii) E&S management programs, (iii) E&S organizational capacity and competence; (iv) emergency preparedness and response, including L&FS and dust explosion provisions, (v) stakeholder engagement and community grievance mechanism; (vi) community health, safety and security management plan; (vii) occupational health and safety (OHS) management programs; (viii) contractor management procedures; (ix) Supplier Code of Conduct; and, (x) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs) (ESAP#1).

Identification of E&S Risks and Impacts. SLFM has completed an E&S assessment (ESHIA Addendum) report for the expansion of the flour mill as per the requirements of the Environmental Protection Agency of Sierra Leone (EPA-SL) Act of 2022. This report identified the risks and impacts associated with the project, provides a baseline of management information and support the long-term viability of the project as well as the risks and impacts associated with the construction of the new silos, new mill facility, and administrative building. The local ESHIA Addendum and associated E&S management framework plans were approved by EPA-SL in April 2023. As part of the IFC investment, SLFM will strengthen the E&S risk assessment of its expansion by conducting a supplemental transport risk assessment to cover its transport related operations (ESAP#2) across its extended area of influence. Also, SLFM will secure all relevant environmental permits for its activities including water abstraction permits as necessary prior to operation of the expansion project (ESAP#3).

E&S Management Programs. The E&S risk assessment as defined in the ESHIA Addendum includes framework E&S management plans (ESMPs) for the proposed expansion of the flour mill during the construction and operation phases, including E&S monitoring and review. SLFM will develop specific ESMP(s) that will describe the mitigation and performance improvement measures and corrective actions that address construction and operations E&S requirements, including labor and working conditions, occupational health and safety, energy efficiency, emergency preparedness (e.g. dust explosion and fire), water management, waste management, pollution prevention, food safety, transport management, community, health, safety and security management, and security management (ESAP#4).

Organizational Capacity / Competency. SLFM has appointed an E&S consultant for its regulatory compliance monitoring and a QHSE committee is in place at the flour mill. The E&S organisation is structured under the general manager (GM), operations manager and the HR Director. The E&S Consultant currently reports to the operations manager. There are no internal EHS resources to oversee the day-to-day management of the E&S aspects during construction and operations phases. SLFM will recruit a EHS manager who will be reporting to the GM (ESAP#5). The EHS Manager will have the responsibility of overseeing the development and implementation of the ESMS, including PS gaps as identified in the attached ESAP, and conducting monitoring of E&S performance and reporting to SLFM management team.

E&S Training Plan. SLFM provide E&S training to its staff and employees as part of the employee onboarding process. Other specialised trainings (e.g., from the Freetown firefighting department) are also provided on emergency preparedness and response. SLFM will provide specialised training to E&S personnel as part of the organisational capacity building with ESMS implementation (ref ESAP#1). Safe systems of work training and spill response as well as training on standard operating procedures will be included in the E&S training plan and implemented across the flour mill and warehouses.

Emergency Preparedness and Response. In accordance with regulatory requirements, SLFM has prepared a draft emergency preparedness and response plan which identifies potential emergency situations and accidents that could occur at the flour mill complex; potential impact on the environment and outlines the necessary response actions and responsibilities. The plan includes measures to prevent or mitigate accidents, such as routine awareness of safety precautions to workers and visitors. It also includes measures for fire outbreaks, electrical shocks, transformer safety, fuel storage, spillage and pollution prevention and other potential hazards like pest infestation and contamination of finished products. SLFM will update its EPRP, to cover its warehouses, transport fleet and clearly defines; (i) roles and responsibilities; (ii) structure of emergency response organization; (iii) legal and company requirements; (iv) emergency equipment including L&FS; (v) emergency procedures for dust explosion, fires, spills and medical evacuations; (vi) resources required; and (vii) drills, monitoring, maintenance and inspection of the emergency equipment, reporting and performance assessment (ESAP#6).

Monitoring and Review. Apart from quarterly regulatory audits conducted as part of construction phase monitoring by an external consultants as per the ESIA regulatory approval Terms and Conditions, there is no formalized E&S monitoring and reporting of SLFM performance to senior management. As part of its PS1-compliant ESMS (ref. ESAP#1 above), SLFM will develop an E&S monitoring/reporting procedure which will specify Key Performance Indicators (KPIs), including occupational health and safety (OHS) leading and lagging indicators (incident records, near miss, hazard reporting and other workplace monitoring data), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and food safety.

PS2: Labor and Working Conditions

At the time of this appraisal, SLFM employs 88 staff in its flour milling operations comprising of 90% male and 10% female workers. Another 17 contract workers (40 at peak construction) are/will be working for the EPC contractor for the construction of the new flour mill which will last until end of 2024, and 16 third-party security officers. SLFM hires occasionally up to 25 casual labor for various loading and unloading tasks in its flour mill and warehouses. These casual workers are provided with basic PPE and training for the tasks to be completed. During loading and unloading of flour bags at the warehouse, day workers (casual labor) are sourced from the neighbouring community through a community leader or headman.

Human Resources Policies and Procedures. SLFM HR management system is based on its HR policy and the collective bargaining agreement (CBA) negotiated between Sierra Leone’s companies in the manufacturing sector and the national labor inspectorate. The policy includes processes related to recruitment and onboarding, salary payment, work organization (salary, hours of work, overtime payment, leave, illness, injury and other entitlement to benefits), training, and progression/promotion and termination procedures. The CBA equally includes provisions on non-discrimination and equal opportunity, safety and security in the workplace and human rights. SLFM will develop a PS2-compliant Human Resources (HR) Manual for its employees and contractors as a management tool for its workforce that; (i) reflects the working conditions and terms of employment as agreed in the CBA; (ii) incorporates procedures for allowing anonymous complaints, (iii) clarifies limits on overtime hours, (iv) clarifies recruitment, performance management and benefits; and, (v) aligns entitlements with the recently updated Employment Act (May 2023) (ESAP#7).

Working Conditions and Terms of Employment. Employees are recruited under permanent or term contracts, which specify entitlements and obligations, including 40 working hours, five-day work week, probationary period, remuneration package and leaves. All employees are insured in the national insurance scheme which is monitored by the National Social Security Insurance. Employee are provided termination notice period of one month for contracts over four months and 2 weeks for contracts less than four months. Severance payment is completed as per Sierra Leone Labor Code. The Government labor inspector is involved in termination to ensure compliance with national labor law. Employees performance reviews are completed twice a year with management and recommendations made for promotion. There are currently no labor cases pending before the court.

Grievance Mechanism. Complaint boxes are available at the flour mill. SLFM has yet to implement a formal grievance mechanism for workers. The company will formalize a grievance mechanism accessible to all workers, including third-party workers, indicating (i) available channels to submit grievances (including separate channels for grievances related to gender-based violence and sexual harassment, and for confidential and anonymous complaints); (ii) roles and responsibilities for treating and responding to grievances; (iii) timelines for taking action; and (iv) system to log, track and report grievances and their status in accordance with IFC PS2 requirements (ESAP#8). The mechanism will also include a differentiated procedure and management of GBV and sexual harassment related grievances. SLFM will sensitize its workforce and disseminate information on online platforms and notice boards with additional specialised training provided to staff managing GBV and sexual harassment grievances.

Protecting the Workforce. SLFM keeps a record of accidents and injuries and provides PPE to the workforce. The mill is fitted with smoke alarms and emergency contact numbers are displayed at all important places within the facility. Good housekeeping is maintained, electrical plugs and switches kept in order and stairs within the mill and silos have handrails and are in good conditions. The transfer of grain to silos is completed through conveyors and transfer from silos to mill is undertaken mechanically reducing manual handling to minimum thus protecting the workforce from exposure to hazards. Earmuffs are provided for workers in the process area and proper cleaning operations are put in place to reduce the flour dust in addition to mandating use of face masks for workers involved in packing at the warehouses.

Workers Engaged by Third Parties. SLFM will hire a few third-party workers through service providers for security. These third-party service providers are required to comply with all SLFM policies and standards, including SLFM’s HR policy, as well as national Labor Code. Also, SLFM will develop and implement a procedure to monitor labor and working conditions of third-party workers as per ESAP#1 and monitor that the EPC contractor workers and any other third-party workers perform as per its HR/OHS requirements.

Occupational Health and Safety. Handling, dust, excessive noise, suffocation, falls, slips and trips, fires, transport, electrocutions, and injuries from improperly guarded machinery are the main hazards and risks associated with flour milling operations. Inhalation of flour dust over time can produce allergic reaction and chronic respiratory disorders, including sensitization and asthma. Though flour milling is a highly automated processing, limiting workplace risks while minimizing the number of employees involved in a milling line, SLFM tracked 55 cases of medical treatment over the past two years of operations. During 2023, four cases of loss time injuries (LTI) were reported irrespective of the irregular milling activities. However, no fatality has been recorded at the flour mill following recommencement of activities in 2016. SLFM has formulated an integrated EHS policy committed to providing a safe and healthy work environment for all employees, contractors, and visitors. SLFM has drafted a EHS management plan based on risk assessment and management. Workplace noise and air quality monitoring records are well within the applicable (WHO guidelines) national standards. For high noise environment, SLFM has installed physical barriers to contain the noise. Personal protective equipment (PPE) is adapted to different workstations and tasks and is provided to the workforce. Strict usage is monitored by the HR team. Fire extinguishers are installed at strategic locations within the flour mill and millers are trained to use this equipment efficiently by trainers from the national fire brigade. Incident statistics are documented on a quarterly bases for the flour mill with no fatal accidents reported in the last two years. An employee’s health and safety committee is in place at the mill. As per ESAP#9, SLFM will formalise the HSE management plan to include safe work procedures, risk assessment and management, warehouse safety, driving safety, incident investigation and prevention, and performance measurement. Also, SLFM will update its OHS procedure (ref. ESAP#1) to address climate-related events, including heatwaves by incorporating preventive measures for workers including but not limited to providing access to drinking water, alternate working schedules during hot weather and updating the EPRP to address climate-related hazards scenarios as well as annual audiometry and spirometry check-ups for the millers. Finally, SLFM will extend its training program to include manual handling to casual workers recruited from the local communities as packers during loading and unloading operations in warehouses (ESAP#9) as well as in emergency preparedness and response procedures.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency. SLFM milling operation includes (i) the break system which is the first grinding stages for the wheat; (ii) scalping, grading, dusting which represents the separation of the ground materials after each of the break rolls; (iii) sizing system consisting of the removal of bran from the system; (iv) purifiers pertaining to the cleaning up of semolina stocks (endosperm fragments) by grading and aspiration to remove bran fragments; (v) reduction system comprising the reduction of semolina to flour; (vi) flour dressing  which relates to the separation of flour from the other materials (mainly bran) and (vii) enhancement. SLFM has been implementing cleaner production interventions at its existing flour mill to reduce its energy and water consumption, including collection of rainwater and use in dust suppression for its access road, reduction of dependency on diesel generated electricity, optimization of waste through re-use of its bran in producing animal feed, and recycling of its construction waste.

Electricity consumption. SLFM relies on the national grid for its electricity. There are also three standby generators (700kva, 300kva and 100kva) available for use in the event of power outage. The gensets are located within a generator building. SLFM only consumed 300 litres of diesel for the gensets operation this year as it relied mostly on electricity from the grid.

Water. SLFM sources its water from the national water utility and on-site ground water well installed within the facility. Three water reservoirs (combined capacity of 9,500 litres) are installed within the flour mill. A total of 60,000 litres of water is consumed annually for nominal operations. Water consumption has increased during ongoing construction owing to additional use of water for concrete batching and dust suppression. SLFM will include the EPC contractor water consumption as part of its ongoing monitoring and will ensure abstraction volumes from the groundwater well are recorded, including water provided to the nearby community through the community standpipe (ref. ESAP#1).

GHG emissions: Wheat processing does not result in significant quantities of wastes and emissions as the bran is processed into animal feed. 25 air conditioners installed are serviced annually. Diesel is used for standby generators and for mobile equipment and trucks that make up the fleet of the company. The Project’s main energy sources are grid electricity and diesel for backup generators. The project emissions are estimated to be around 1,752 tons of carbon dioxide equivalence per year and with the expansion project, GHG emissions are expected to remain below 25,000 tons of carbon dioxide equivalence per year.

Noise. SLFM monitors noise at pre-selected receptors as well as outside the perimeter of the facility at the closest sensitive receptors to determine its impact on the neighbouring communities, if any. The noise levels at nearest community receptors are within national limits and in compliance with WBG EHS Guideline values. Millers are provided with suitable hearing protection given the exposure time to the noise. As part of the flour mill expansion project, SLFM will revamp it generators and install silencers to reduce noise and include audiometry test as part of the annual health check-up of its milling staff.

Air monitoring. SLFM monitors ambient air quality at plant boundaries and the surrounding and analyse for any spike in pollutant levels which may be attributed to its operations. SLFM records instantaneous maximum readings of Particulate Matter (PM) 10 and PM 2.5. The emission monitoring reports indicate compliance with applicable legal requirements (WHO) standard limits for PM 2.5 (which is 25 µg/m3) and PM10 (which is 50 µg/m3) - also adopted as national limits.

Waste management. Typical waste generated from the flour mill include packaging material, plastics, cans paper, mill waste, food remnant, and other construction waste like concrete and rubble. Hazardous waste including used oil which is stored in a 210 litres sealable container separate from the non-hazardous waste. Both waste streams are collected in distinct labelled skips placed at a dedicated, well-ventilated and locked storage area. The waste is accumulated on site temporary and carted away by an authorised waste management company.

Wastewater treatment: Flour milling is a dry process. Wastewater generated at the flour mill will mostly be from chemical toilets and lavabos. This stream is drained to septic tanks which are removed by an authorized liquid waste management service provider for treatment at a municipal facility. Stormwater and other effluents from construction activities including incidental concrete wastewater is channelled into a drainage ditch that discharges outside the factory boundary into a municipal stormwater drainage ditch. As part of this IFC investment, SLFM will install decantation sumps and other filter devices at the outlet of stormwater drainage systems aligned with WBG EHS Guidelines (ESAP#10)

Hazardous Materials and hazardous waste management. SLFM has a fuel storage area with three tanks placed on concrete hard stand saddle-line structure with a capacity of over 50,000litres. The fuel tanks are locked and secured when not in use. Automatic shut-off nozzles are installed on all dispensing units and pumps. Apart from hydraulic oil and diesel, no other chemicals are used for the operations. Other occasional chemical wastes on site include chemical additives used at the concrete batching plant. As part of the IFC investment, SLFM will implement proper hazardous material storage protocols including storage of hazardous materials in roofed bunded areas and installation of oil water separator connected to hardstanding surfaces used for refilling at the fuel storage area aligned with WBG EHS Guidelines (ESAP#11). Also, SLFM will ensure that adequate spill kits and firefighting equipment are readily available at the fuel depot.

PS4: Community Health, Safety and Security

Food Safety. SLFM has a quality officer responsible for food safety quality inspection as part of the flour mill expansion responsible for the implementation of the food safety management process and overseeing laboratory testing and analyses. As per ESAP#1, the company will ensure that laboratory protocols are updated and material safety data sheets (MSDS) and safety protocols for all reagents are updated, and laboratory technicians sensitized.

Life and Fire Safety. The SLFM silos have been designed as per ANSI / ASAE 2008. SLFM incorporates life and fire safety (L&FS) requirements in the design of the flour mill. The design of the flour mill considered the fire resistance rating of the structure and façade, smoke control systems and internal L&FS systems, including portable fire extinguishers, and water tanks. Also, the design includes automatic smoke detectors, fire alarms and power dust extraction systems. As per ESAP #5, SLFM will model fire incidents for the flour mill and main warehouses, develop, implement L&FS measures including fire water system (water reservoir, fire pump, standpipe, fire hose reels), mapping out national incident response facilities (fire brigade, hospitals, incident support structure) and include communication with nearby communities in its EPRP awareness program for communities within its area of influence prior to commencement of operations of the expanded flour mill.

Traffic Safety. SLFM is in a build-up industrial zone / urban area in Cline Town with narrow roads and relatively high traffic. The company will develop and implement a traffic management plan applicable to its transport fleet, its suppliers and distributors (ESAP#12). The plan will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards as well as alcohol and drug testing requirements. Also, SLFM will develop and implement a traffic management plan applicable to own fleet, suppliers, distributors and addresses driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards as well as alcohol and drug testing requirement. Also, SLFM will provide a detailed induction session on the E&S provisions of its Code of Conduct, including zero tolerance to gender-based violence and sexual exploitation, abuse and harassment for its own truck drivers and transport service providers.

Security Personnel. SLFM employs 16 unarmed security personnel for access control through a third-party security agency. Existing measures include background checks, screening of all vehicles at the gates, cameras at perimeter. SLFM will include training requirements for security personnel as well as expand the workers grievance management (ref ESAP#8) to cover its third-party security agents.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource

SLFM is located less than 1km from Sierra Leone River Estuary Marine Protected Area, and approximately 1km from a Key Biodiversity Area / Important Bird Area (KBA/IBA) of the same name. The project site does not overlap with the designated areas and based on the nature of the development and its location in an already highly build-up area, there are no pathways of impact to either the protected area or KBA/IBA. The mill expansion project will occur in area with pre-existing buildings, hard standing and no vegetation and therefore clearly Modified Habitat. No impacts to Natural Habitats are likely.

SLFM is sourcing wheat from Europe to produce flour at its mill in Sierra Leone as well as buying processed wheat flour to supply the local market. The wheat is obtained through a Turkish wheat supplier who sources wheat from multinational companies in the Black Sea and Baltic Sea region. Wheat from the Black Sea (Ukraine) is known to present low risk of conversion of natural / critical habitat. Also, the supplier occasionally sources wheat from South America (Brazil) where the risk of critical / natural habitat conversion cannot be ruled out. However, for the SLFM, all the wheat will be sourced from the Black Sea region as an average protein content of 13% is required. The company will buy 50% of wheat of 12.5% protein wheat content and 50% of 13.5% protein wheat content, which limits the choice of origin to Black Sea region only. As part of IFC investment, SLFM will develop (i) a third-party wheat supplier screening protocol to ensure all wheat are sourced from certified or equivalent verified suppliers compliant with IFC PS2/PS6 supply chain requirements; (ii) a Supplier Code aligned with IFC PS6 requirements to be signed by wheat suppliers as part of sales agreement, which will prohibit wheat sourcing from recently converted natural habitats; and (iii) procedures for monitoring and independently verifying the implementation of SLFM Supplier Code (ESAP#13).

SLFM has engaged with neighboring communities as part of ESIA consultation. There is an ongoing engagement process in place. Regular meetings take place between the company and community close to the factory and a community development action plan (CDAP) is in place with deliverables agreed upon as per the T&Cs of the company’s Social License to operate.

There is no formal mapping / register or a community grievance mechanism in place. However, a community grievance redress mechanism committee is in place with the counselor and traditional authority as the main focal points while the headman is the main person who channels complaints to the company for management. SLFM will develop (ref. ESAP#1) a Stakeholder Engagement Plan and Procedure with a stakeholder analysis and mapping exercise, in line with IFC PS1 requirements. The SEP will formalize the external grievance redress mechanism to (i) receive and register external communications and grievances from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and documented responses; (iv) provide feedback to stakeholders on grievance mechanism results, and (v) monitor implementation and effectiveness through KPIs. Also, SLFM will develop separate channels for receiving and managing grievances related to gender-based violence and sexual harassment, and for confidential and anonymous complaints.

 The ESRS/ESAP and the Environmental Social and Health Impact Assessment (ESHIA) will be made available via IFC Project Information Portal and at Sierra Leone Flour Mill Limited

 Contact Person: Mr. Amadu Juldeh Sowe, Chief Executive Officer

Company Name: Sierra Leone Flour Mill Limited

Address: 1, Lumley Street, Freetown, Sierra Leone

Email: sowe@bsbtellme.com

Phone: +23277602114