IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Management System and Policy
BLS holds ISO 9001 certification for quality management systems. There is a quality, security, and environment policy in place. The policy covers the company commitment to quality delivery while safeguarding the environment and ensuring safety of its personnel.
BLS is in the process of development of the environmental and social management system (ESMS) in alignment with guidance of the ISO 14001 (environment), 45001 (occupational health and safety – OHS), and the applicable national regulatory requirements such as on climate risk assessment and management and is developing environmental and social (E&S) standard operation procedures (SOPs) and key performance indicators (KPIs), GHG emissions tracking and energy efficiency planning. BLS will develop the E&S Policy and ESMS, including an Internal E&S Auditing Procedure in line with IFC PSs (ESAP #1).
BLS selects its contractors based on their expertise, certification, and fulfilment of contractual requirements. BLS will develop a Contractor Management Procedure to strengthen its contractor selection through the integration of E&S requirements into its tender documents and ensure that these requirements are fulfilled for new projects under construction, including an E&S Monitoring Protocol (ESAP #2). Additionally, contractors will be required to develop E&S Management Plans (ESMPs) for projects under construction (ESAP #3).
Identification of Risks and Impacts and Management Programs
The company undertakes an E&S risks assessment process related to its activities as required by national authorities for environmental and construction permitting purposes. For instance, a risk assessment process is implemented by the Quality, Health and Safety and Environment (QHSE) team during the assessment phase and covers hazards associated with fire safety, control measures, including trainings, maintenance planning, engineering controls and reporting procedures.
BLS will develop an E&S Assessment and Management Procedure aligned with IFC PS and local requirements to identify and manage E&S risks associated with land acquisition, development of greenfield assets, and acquisition of existing firms and brownfield assets (ESAP #4).
Organizational Capacity and Competency
BLS’s Sustainability Committee defines E&S strategic priorities and time-bound initiatives.
BLS’ QHSE Unit manages the implementation of E&S policies and compliance in each BLS operation. BLS will assign a qualified person to the QHSE Unit to coordinate the implementation of the ESMS and ensure adequate E&S supervision of the E&S performance of all assets under construction and operation and an EHS leader at each operational site reporting to the BLS QHSE Manager (ESAP #5). BLS has 13 operational sites, most of them being logistics sites; where a BLS client is operating on a site leased from BLS, the client will provide their own EHS staff.
General E&S trainings are provided to BLS staff. Going forward, BLS will develop a comprehensive E&S Training Plan for all the direct employees and contracted workers across all BLS operations (ESAP #6).
Emergency Preparedness and Response
There are Emergency Preparedness and Response Plans (EPRP) in place for the operational sites. For sites under construction, the EPRP is developed and implemented by the contractor on site. Scenarios covered by specific plans include large fires, electric incidents, process safety incidents, hazardous chemicals spills, serious environmental incidents, traffic incidents and on-site accidents, natural disasters, and extreme meteorological events such as floods and security incidents such as bomb threats. The company has also installed fire domes in all its warehouses and on its premises that are under the management of the company that leased premises from BLS. This is in addition to the fire detection and fighting systems installed and regularly monitored at all BLS sites. Signage, assembly points, water tanks for firefighting and fire drills were all found in line with IFC PS requirements.
PS 2 – Labor and Working Conditions
BLS employs 266 employees (92% males and 8% females). BLS also engages approximately 103 third-party workers.
Human Resources Management, Policies and Procedures
BLS organizational structure includes the QHSE Director and an HR Manager who report directly to the H&S HR Director who oversees BLS’s application of national labor laws.
BLS’ HR policies cover a range of issues such as recruitment, remuneration, grievances, and non-discrimination commitments, including fair, competency-based recruitment processes without any discrimination based on race, religion, gender, age, disability, or marital status. BLS’s code of conduct emphasizes respect for individuals, including equal employment opportunities, prohibition of child labor and forced labor, protection against harassment, and ensuring health, safety, and hygiene at work. BLS has an Employee Handbook that contains all company’s HR policies and reflects the provisions of national legislation and its applicable to contractor workers and suppliers. The company will update the Employee Handbook to include measures related to gender-based violence, freedom of association, contracts template, and retrenchment in line with IFC PS2 and make it available to workers in Arabic (ESAP #7).
Employee Grievance Mechanism
At BLS, employees can raise grievances through a variety of channels. The system is managed at company level and grievances are dealt with by the compliance department. Employees can also raise grievances through the BLS HR function. The company will update the Workers’ Grievance Mechanism to align it with IFC PS2, including allowing anonymous grievances and a separate route gender-based violence and harassment (GBVH) and assign and train personnel on its use (ESAP #8).
Occupational Health and Safety (OHS)
The company has an OHS Policy as well as various procedures guided by ISO 45001 principles and an OHS Training Plan for direct employees targeting warehouse operators, lifting equipment operators and forklift operators.
BLS has a procedure for reporting information on work-related accidents and incidents including conducting investigations and analyses of their root causes. The company will develop an OHS dashboard for the KPIs aligned with IFC PS2 and WBG General EHS Guidelines for the analysis of OHS performance data such as lagging and leading indicators (ESAP #9).
Per local regulatory requirements, OHS audits are conducted for warehouses used for pharmaceuticals and cosmetics by the National Office of Food Safety (ONSSA) team prior to any contractual agreement and periodically thereafter to ensure continued compliance with certification requirements. BLS will integrate internal audits into the ESMS to include worker safety, workplace parameters, and security (ESAP #1).
Workers Engaged by Third Parties
A number of third-party contractors engaged by the company provide services such as truck transportation and security. The company also uses temporary workers to respond to seasonal peaks in business activity. There is no distinction in the HR procedures and training of direct, indirect, or temporary employees.
BLS E&S requirements are communicated to contractors through the contracts, which include standard clauses that require contractors to comply with and respect labor legislation, regarding work permits, remuneration, working hours, OHS, industrial accidents, membership of and contributions to social organizations. Monitoring contractor HR management and compliance with PS 2 requirements will be included in the Contractor Management Procedure (ESAP #2).
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas (GHG) Emissions
BLS’ annual GHG emissions in 2023 were estimated to be 4,185 tonnes of CO2-eq., including both directly through on-site fossil fuel combustion and electricity consumption for refrigeration, lighting, etc. at the warehouses and indirectly such as emissions from fleet fuel consumption by the transportation fleet provider. The estimated scope 1 emissions are 25 tCO2e/year and scope 2 are 4,160 tCO2e/year.
Pollution Prevention
The company’s existing operations are not associated with significant environmental pollution. The limited pollution risks and impacts associated with BLS’s operations can be prevented and mitigated by implementation of appropriate mitigation measures consistent with good international industry practices (GIIP). While there are no significant direct impacts of BLS operations on air quality, BLS will implement an E&S Monitoring Procedure including noise, air pollution, water, wastewater, and fuel management and will be tracked against the general IFC EHS guidelines across all its operations (ESAP #3).
In terms of resource consumption, there is minimal use of water inside the warehouse and minimal wastewater is generated. The only source of waste based on the nature of business is packaging material and solid waste. Based on the solid waste management plan, all waste is segregated at source. A licensed waste disposal contractor is responsible for final disposal and recycling of the waste generated from the warehouse facilities.
PS 4 – Community Health, Safety and Security
The company does not own or operate the fleet of trucks used for its operations. The service provider is responsible for the of the E&S performance of their fleets.
The transport service provider has in place adequate transportation safety management systems. This includes effective approaches to journey, fleet, and driver management. BLS will develop a Road Transportation Safety Monitoring Program to ensure compliance with local laws and the Traffic Safety section of the WBG’s General EHS Guidelines (ESAP # 10).
Security Risk Management
The company contracts a private security provider to protect its facilities. The guards are not armed and are externally trained on access control, emergency evacuation and responsibility during emergency situations such as theft or property damage by the security service provider.
