IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1 – Assessment and Management of Environmental and Social Risks and Impacts
E&S Policy, Management Systems and Programs: The client holds a current ISO 14001:2015 Environmental Management System certification, providing a baseline framework for environmental compliance and continual improvement. Revital has a documented Environmental Policy and Environmental Health & Safety (EHS) philosophy, policy & principles under which it has committed to compliance with the relevant national legal requirements on EHS and fire protection, the implementation of EHS management systems, and the provision of a safe and healthy work environment. Revital also has Human Resources (HR)/Labor-related policies (grievance, disciplinary, code of conduct & ethics, HR, leave, recruitment, safeguard), which have commitments on compliance with respective national legal requirements on wages, working hours, prevention of child and forced labor, freedom of association, and non-discrimination.
Identification of E&S risks and impacts: Revital has a Risk Management policy that guides the company in identifying, assessing, and mitigating risks that may affect its operations, financial stability, reputation, and compliance with legal requirements. Additionally, the company has Standard Operating Procedures (SOPs) for environmental impact identification and risk assessment, primarily focused on Occupational Health & Safety risks. For the current manufacturing plant, site-level risks were also identified through the preparation of an Environmental Social & Impact Assessment (ESIA). However, the ESIA did not fully align with IFC PSs, as gaps were identified, particularly in labor and working conditions, hazardous materials and emissions management, community health and safety, stakeholder engagement, biodiversity, and E&S management systems. Some of the gaps were closed by Revital’s ESMS, while others will be closed through the implementation of ESAPs.
The Project involves the development of a new logistics, warehousing, and liquid-handling facility on a greenfield site within the Dongo Kundu SEZ. Revital has initiated a site-specific ESIA for the proposed facility and is required to obtain approval from the National Environment Management Authority (NEMA) before commencement of construction. At the time of appraisal, the ESIA process for the new facility at the Dongo Kundu facility was ongoing. Revital will complete the ESIA in accordance with IFC PS1 before construction. (ESAP #1).
The current ESMS comprises multiple standalone E&S-related policies and procedures. However, there is no single, integrated ESMS framework document that defines scope, links policies, procedures, risks, and governance, and applies consistently across current operations and future expansion (Dongo Kundu). To close the gap, Revital will develop an integrated ESMS aligned with GIIP and PS, covering current operations and the expansion area. The ESMS will consolidate E&S policies and procedures, including systematic E&S risk identification, and define roles and responsibilities. Revital will also develop procedures for monitoring and reporting E&S performance (ESAP #2).
Organizational responsibility for ESMS implementation is defined, with oversight provided by senior management and day-to-day implementation led by the Quality Manager and Human Resources Manager, supported by operational teams and contractors. Monitoring and review are undertaken through inspections and audits. However, the focus remains primarily on environmental compliance, with limited attention to occupational health and safety (OHS). While the client shows commitment to E&S resources, a lack of dedicated E&S specialists compromises the implementation of their ESMS. To close this gap, Revital will hire a qualified E&S specialist, who will be responsible for the current operation and the expansion area (new facility) (ESAP #3).
Revital has established emergency preparedness and response arrangements as part of its ESMS, including documented procedures for fire safety, chemical spills, equipment failure, workplace injuries, and other operational emergencies, supported by trained personnel, emergency equipment, and coordination with relevant internal teams. The facility is equipped with portable fire fighting equipment appropriate to the types of fire risks present in manufacturing and utility areas. This includes fire extinguishers of different classes (water, foam, dry chemical powder, and carbon dioxide), selected based on fuel type and electrical risks, and distributed across operational areas. In addition, the company conducts drills, though they only cover fire. The current emergency preparedness and response plan only covers the current operations and does not include community safety. To address these gaps, Revital will update its emergency preparedness and response framework to address all other potential emergencies for its operations, incorporating community-facing risk scenarios, including the expansion area (ESAP #4).
Revital undertakes E&S monitoring and review activities as part of its ESMS to track compliance with applicable legal requirements, internal policies, and operational controls. Monitoring activities are currently implemented through periodic inspections, audits, and statutory assessments, with a primary focus on environmental compliance, occupational health and safety performance, and labor and working conditions. E&S performance data are reviewed by site and functional management as part of routine operational oversight, including follow-up on identified non-compliances and the implementation of corrective actions where required. While these arrangements provide a baseline framework for monitoring and compliance assurance, current monitoring and review practices are largely compliance-driven and not yet structured around a standardized set of E&S performance indicators or a formal management review cycle, and E&S reporting to senior management remains largely qualitative. Under ESAP #2, monitoring, review, and reporting procedures will be developed.
Revital's stakeholder engagement framework is currently limited and primarily focused on employees, contractors, regulators, local authorities, suppliers, and customers. Employee engagement is facilitated through toolbox talks, inductions, a staff welfare committee, and an Environment, Health and Safety (EHS) Committee. In contrast, engagement with external stakeholders occurs mainly through routine regulatory reporting, inspections, site-level interactions, and issue-specific communications. The Company maintains formal worker grievance and whistleblowing mechanisms; however, it lacks a documented Stakeholder Engagement Plan (SEP), and community-facing engagement processes remain limited. Although the operational facility is not associated with complex or high-risk community environmental impacts, the expansion area is located adjacent to communities previously resettled within the broader development area, necessitating a more structured approach to stakeholder engagement and grievance management. To close the gap, Revital will develop and implement a formal Stakeholder Engagement Plan, strengthen external communication and grievance mechanisms, and establish a systematic approach to engagement with neighboring communities, including consideration of legacy issues arising from past resettlement activities (ESAP #5).
PS2 – Labor and Working Conditions
Revital's workforce is over 550, including both direct and outsourced employees. The company’s direct employees, including disabled (hearing & speech), are 272, of which 185 are men and 87 women. Revital also engages third-party contractors for specific services, including security and other support functions.
Revital has a documented HR management framework that outlines the processes the HR department must follow for staff recruitment/resignation/retirement/reemployment, labor contract signing, salary management, and performance management. The Company has labor-related policies/procedures that commit to compliance with the respective national legal requirements on wages, working hours, prevention of child and forced labor, freedom of association and non-discrimination, workplace harassment, sexual harassment, and Gender-Based Violence (GBV), in accordance with PS2. The management framework will be implemented in the expansion project.
Revital has established a formal employee grievance mechanism, administered by the Human Resources function and supported by documented policies and procedures. The mechanism includes commitments to confidentiality, non-retaliation, fair investigation, and recordkeeping. Employees may submit grievances through suggestion boxes, an internal email address, or the whistleblowing channel, including anonymously. HR investigates grievances and communicates responses to complainants. In 2025, Revital received four grievances, all of which were successfully closed. Revital also maintains a complaints process for gender-based violence and sexual harassment under its zero-tolerance GBV policy, with multiple reporting channels, including anonymous whistleblowing and confidential HR-led investigations. Given the mixed workforce and contractor interfaces associated with the expansion project, GBV/SEAH prevention measures are incorporated into labor management arrangements and grievance mechanisms.
The Project presents occupational health and safety risks associated with machinery operation, warehousing, and cold-chain activities, fire hazards, electrical systems, and ergonomic stressors, including repetitive tasks, manual handling, prolonged standing, and awkward postures, which may result in injuries, worker fatigue, musculoskeletal disorders, electrical shock, burns, or electrocution if not adequately managed through appropriate controls, training, and supervision.
Revital’s corporate SOP for EHS philosophy, policy & principles includes commitments to providing a safe and healthy working environment, providing training, eliminating, and reducing EHS risks. The company has relevant procedures for identifying potential OHS risks, providing preventive and protective measures, and documenting incident reporting and investigation procedures embedded within its OHS. These procedures cover the reporting, investigation, documentation, and statutory notification of workplace incidents, including injuries, accidents, hazards, and notifiable events, with defined roles, timelines, and corrective action follow-up. Revital’s OHS performance has been typical of low- to medium-level manufacturing, with no employee or contractor fatalities in the last 2 years. OHS performance reporting is currently managed on a case-by-case basis, with limited consolidation of standardized injury and lost-time indicators across reporting periods, as part of ESMS strengthening. Under ESAP #2 above, OHS data will be aggregated into a consolidated ESMS-level performance reporting framework
Revital engages third-party contractors and suppliers through agreements that reference E&S requirements, including OHS, environmental compliance, and conduct standards. However, systematic procedures for monitoring labor conditions and E&S performance of third-party workers are not consistently defined or applied, and supply-chain due diligence beyond the site level remains limited. The Company's increased reliance on third-party logistics providers and contractors at Dongo Kundu underscores the importance of robust contractor oversight and supply-chain oversight. To address this gap, Revital will formalize supplier E&S screening criteria, establish minimum E&S requirements, and implement monitoring and audit mechanisms for contractors and suppliers (ESAP #6).
PS3 – Resource Efficiency and Pollution Prevention
Revital’s water and electricity resources use is characteristic of a light-to-medium industrial medical manufacturing plant. Water and electricity are used primarily to support manufacturing operations, utilities, and employee welfare associated with the production of medical devices. Electricity is a key input for operating machinery, as well as for offices and ancillary services. Water is used mainly for cleaning and domestic purposes. The facility relies on legally permitted water and power supply arrangements, and consumption of both resources is monitored and reported as part of statutory environmental compliance. The client has diesel backup generators installed at the manufacturing plant, used intermittently during grid power outages to maintain operational continuity. Revital has implemented measures to improve energy and water efficiency, including solar power, energy-efficient machinery, LED lighting, and water reuse through closed-loop processes. Revital's GHG emissions arise primarily from purchased grid electricity (Scope 2) and the limited use of diesel backup generators (Scope 1). Resource consumption and emissions are generally consistent with the nature and scale of the Company's operations. They are managed through measures aligned with Good International Industry Practice (GIIP), including the WBG General EHS Guidelines.
Hazardous materials and waste are managed through operational procedures covering storage, handling, spill prevention, emergency response, and disposal. Licensed contractors are used for off-site waste transport and disposal, with records maintained to support traceability and regulatory compliance. These arrangements are broadly consistent with GIIP and the WBG General EHS Guidelines on hazardous materials and waste management.
Non-hazardous solid wastes include packaging materials, plastics, paper, and general domestic waste. Waste management is guided by operational procedures aligned with the waste management hierarchy (reduce, reuse, recycle, recover, and responsible disposal). Solid waste is segregated at source, temporarily stored in designated areas, and collected by authorized service providers for recycling or disposal.
Wastewater generated by Revital is limited to domestic and utility-related sources associated with sanitation and equipment cleaning activities. Wastewater is managed through legally permitted sanitation and drainage systems, with monitoring and reporting undertaken as part of statutory environmental compliance, largely consistent with the principles of the WBG General EHS Guidelines.
The proposed Dongo Kundu facility will adopt Revital's existing waste management processes, enhanced to reflect the scale and nature of logistics, warehousing, and cold-chain operations. The planned installation of ice-pack freezers and temperature-controlled storage will increase energy demand and introduce refrigerant use, resulting in additional Scope 1 and Scope 2 GHG emission sources. To manage these risks in line with GIIP and the WBG General EHS Guidelines, Revital will develop an Energy and Refrigerant Management Plan. The plan will address energy efficiency measures, selection of low-global-warming-potential refrigerants, leak detection, refrigerant recovery, and monitoring of energy consumption and refrigerant performance (ESAP #7).
PS4 – Community Health, Safety, and Security
Revital’s operations generally present moderate, site-specific community health, safety, and security risks associated with logistics activities, traffic movements, emergencies, and interactions with neighboring communities. Potential risks include fire or fuel-related incidents; traffic and road safety risks associated with employee and delivery vehicle movements; localized noise and nuisance impacts; and accidental pollution or waste-handling incidents. These risks are particularly relevant given that the expansion area is adjacent to communities that were previously resettled and remain near the Project site. Appraisal identified gaps in the assessment and documentation of community health, safety, and security risks, including those associated with security arrangements. While the Client employs contracted security personnel, there is no documented assessment of potential risks to workers and neighboring communities, including resettled communities, nor evidence of security personnel vetting, training, proportional use-of-force procedures, or adequate monitoring and grievance mechanisms. To address these gaps, Revital will develop and adopt a Community Health, Safety, and Security Management Framework. The framework will address traffic management, community communication, security management, contractor conduct, and engagement with surrounding communities, including those affected by past resettlement activities (ESAP #8)
