This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability (2012). The key E&S issues include (i) the company's management and monitoring systems to assess and manage E&S risks and impacts from its operations, as well as those related to the construction of new facility in India and expansion of manufacturing facilities in Bangladesh and supply chain management funded under the project ; (ii) consistent management of labor and working conditions and Occupational Health and Safety (OHS) policies and practices, prevention of sexual harassment and Gender Based Violence (GBV); (iii) monitoring and management of waste and wastewater and hazardous materials (iv) life and fire safety risk management and emergency preparedness and response (v) client’s stakeholder engagement activities related to E&S aspects. 

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

Policy: The EPIC Group has adopted an Environmental Protection Policy, Health and Safety (H&S) policy, and HR policy that is broadly consistent with the principles of IFC’s Performance Standards (PSs).

Identification of E&S risks and impacts: The company identifies and manages E&S risks and impacts associated with its operations in Bangladesh and India through compliance with applicable national laws and standards and E&S regulatory permits and requirements. At the facility level, EPIC’s factories maintain a regulatory register comprising a list of applicable legal regulations along with a permit renewal calendar. As per ESAP #1, the company, as part of the E&S risk identification process for the new facility in India will engage a qualified third-party consultant to undertake an Environment and Social Impact Assessment (ESIA) in line with the requirements of IFC PSs and national law. Based on the ESIA, the company will develop and implement a suite of site-specific Environmental and Social Management Plans (ESMPs), consistent with national law and standards, requirements of IFC PSs and WBG General EHS guidelines (2007) and WBG EHS Guidelines for textiles manufacturing (2007). The ESMPs will include documented E&S management and monitoring plans for the construction and operation phases of the new apparel manufacturing facility.

The India facility construction will be undertaken in five phases, with the pilot phase (phase 1) of the project likely to be commissioned in January 2025, while the remaining phases will be commissioned subsequently (by 2026 or later). Further, as part of ESAP# 2, before starting the construction for pilot phase (phase 1 of the new facility) in Odisha, the company will undertake a focused ESIA and prepare construction phase site-specific ESMPs as well as HSE plan in line with the requirements of IFC’s PSs and WBG General EHS guidelines (2007) and WBG EHS Guidelines for textiles manufacturing (2007). Subsequently, before commissioning of the phase 1 of Odisha project, as per ESAP#3, the company will prepare operational phase E&S management plans based on the focused E&S impact assessment and ESIA, national law and standards and WBG General EHS Guidelines, and WBG EHS Guidelines for Textile Manufacturing (2007). This includes a site-specific E&S monitoring plan for the new apparel factory in India, which will specify minimum KPIs/parameters to be monitored, monitoring frequencies, type of monitoring, and the definition of thresholds that signal the need for corrective actions.

Environmental and Social Assessment and Management System: The company has established E&S management systems (ESMS) for its operations in Bangladesh. The company has developed a facility-level E&S aspect-impact matrix for all the key departments level, to identify and assess E&S risks and impacts and identify appropriate control measures. Based on the matrix, the company has developed a comprehensive set of procedures, including operational control procedures (OCPs), risk control procedures, standard operational procedures (SOPs), emergency preparedness and response procedures, and training management systems. These collectively constitute the essential components of the EPIC's E&S operation and performance framework. The SOPs cover E&S aspects under compliance, sustainability, engineering, HR, legal, production, maintenance, and warehouse- which factor in the requirement of regulatory compliances and multiple buyer E&S requirements.

EPIC’s Facility level ESMS has been established for CIPL and is certified as per ISO 14001 (Environmental Management); other facilities in Bangladesh, have similar facility level ESMS and uniform SOPs are consistently implemented across the company. The company has also established Occupational Health and Safety Management Systems certified as per ISO: 45001 (Occupational Health and Safety) across its factories in Bangladesh (CIPL, EGMCL & GTL). The scope of the ESMS appropriately covers the factory operations but was found to be lacking in terms of the coverage of planning, design, and construction-related activities.  As per ESAP#4, the ESMS will be updated to formalize and update the existing E&S procedures in line with the requirements of IFC PSs and WBG EHS guidelines for textiles manufacturing (2007) and  good international industry practices ( GIIP), which at minimum will include: (i) screening procedure/checklist for assessing E&S risks and impacts associated with the new projects, expansion at operational plants, asset acquisition, decommissioning of existing asset (due to space limitation for renovation or refurbishment); (ii) management programs, including standard operating procedures (SOPs) for managing EHSS risks and impacts from type of construction (captured above); (iii) procedure for land purchase including policy/guidelines (compliant with requirements of IFCPS 5-8); (iv) EHS procedures for construction phase integrating and updating the HSE management plan already in place (covering construction phase related impacts and risks); (v) contractor ESHS management and oversight procedure for construction/ refurbishment/ decommissioning stage activities; (vi) E&S organization for construction stage activities; (vii) dedicated emergency preparedness and evacuation plan for construction stage activities as per IFC PS 1 requirement; (viii) stakeholder engagement framework and community grievance mechanism including grievance mechanism for construction stage workers meeting PS1 and PS 2 requirements; (ix) monitoring, reporting and management review of E&S performance during construction phase including checklist for labor camp accommodation facilities. The company will cascade down the ESMS procedures to the company’s new apparel manufacturing facility in India funded under the project. The expansion, decommissioning (eg. ETP plant) and reconstruction (within the existing company premises or in the existing EPZ) are currently being undertaken in line with the local regulations, and relevant EPZ guidelines (as applicable) including preparation of the EIA/ IEE as per the Department of Environment (DoE) requirements. The company will ensure that construction stage ESMS requirements (as per ESAP #4) are be implemented for further expansion demolition and reconstruction activity in Bangladesh.

Organizational Capacity and Training: The company has dedicated teams at the corporate level, including Sustainability, Compliance, Maintenance and Utility, and Human Resources (HR), which has direct access to the Board. The Executive Vice President (Sustainability & Innovation) takes on the overarching responsibility for monitoring and managing environmental aspects, while the Chief People Officer (CPO) supervises social and labor-related matters as well as stakeholder issues throughout the EPIC Group's operations. Compliances with regulatory requirements, health & safety, international frameworks, and standards, as well as buyer’s requirements, are dealt with through a dedicated compliance team led by the Vice President (HR & Compliance).

Each facility has dedicated competent and knowledgeable teams, to ensure the effective implementation of the ESMS, OHS, and HR aspects. The EHS Managers and the welfare officers, at the factory level are assigned the responsibility of managing and coordinating the E&S performance of the facilities, receiving support and guidance from the corporate team. Separate EMS/EHS committees have also been constituted at the factories with inter-departmental representatives (from Compliance, HR, Admin, Utilities & Maintenance, Production, etc.) – this team is tasked with the responsibility of implementing environmental initiatives at the department level and conduct internal assessments to review environmental performance improvements and progress. The facilities also maintain a structured life and fire safety (L&FS) organization that includes a designated fire safety officer and is supported by a team consisting of firemen and technicians. The company has prepared an EHS regular training calendar to ensure that staff and workers are trained on the various aspects of the ESMS.

Emergency Preparedness and Response: The company has documented Emergency Response Plans (ERP) for its factories in Bangladesh compliant with national law. The emergency response plan outlines specific procedures to be followed in case of fires, floods, earthquakes, cyclonic storms, boiler explosions, chemical incidents, security threats, labor unrest, and other potential emergencies. A specific emergency response organization at the factory level has been established, and external responders to be contacted in emergency situations (Fire Service, Police, Hospital, etc.) have also been identified. Emergency response training and mock drills are organized for the work on a regular basis. As per ESAP#4, the company will put provisions for ERP during the construction stages.

Monitoring & Reporting: The company monitors E&S indicators linked with resource consumption (energy and water usage), stack emissions and ambient air quality, GHG emissions, wastewater generation and quality of treated effluent, workplace and ambient noise levels, solid waste generation and disposal, accident/incident records, labor compliances, grievance redressal, etc. Internal auditing is coordinated through the Compliance Department and the findings are shared with the Senior Management. External audits are organized as per the requirements of global customers and the company’s systems and procedures are reviewed during independent assessments (as required by the buyers) applicable to the apparel industries sector such as Worldwide Responsible Accredited Production (WRAP), SEDEX Members Ethical Trade Audit (SEDEX SMETA), Zero Discharge of Hazardous Chemicals (ZDHC), Higg Facility Environmental Module (Higg FEM), OEKO-TEX, International Accord (ACCORD), Alliance for Bangladesh Worker Safety (ALLIANCE), Better Work 2022, Supplier Compliance Audit Network (SCAN), Global Organic Textile Standards (GOTS), Global Recycled Standards (GRS), Organic Cotton Standards (OCS), Recycled Claim Standards (RCS) amongst others.

Management Review: Each of the respective heads related to compliance, sustainability, HR report to the senior management on a regular basis for status update on ESMS performance as well on E&S issues requiring intervention.

PS2: Labor and Working Conditions

The company is certified and continues to be audited (across all Bangladesh units) as per Buyers requirement as per  Worldwide Responsible Accredited Production (WRAP, https://wrapcompliance.org/en/), Sedex Members Ethical Trade Audit (SMETA, https://www.sedex.com/solutions/smeta-audit/), Workplace Conditions Assessment (WCA, https://www.intertek.com/assurance/wca/) and other Buyers requirement. Additionally, the following units- PGCL, CIPL, and GTL are involved with Better Work (BW) Bangladesh (https://betterwork.org/bangladesh/), a collaboration between the International Labour Organization (ILO) and the IFC,  focused on promoting decent work, empowering women and inclusive economic growth in the RMG sector. BW combines factory assessment (to monitor compliance with international core labor standards and national labor law), learning through advisory factory visits, training (specially-tailored one-on-one coaching of factory managers from BW experienced staff in identifying compliance and other issues and establishing the means of improvement), and industry seminars (opportunity for factories to learn from their peers) and workshops aimed to tackle collectively areas of needed improvement.

The total manpower strength of the company is around 25,000 and annual worker attrition rate average 3.5%; the female worker representation is around 70%. The company does not have contract workers in the operations apart from 217 security personnel of which 27 are female. Going forward, EPIC anticipates hiring around 4,000 new workers in Bangladesh for EGMCL-7 and 6,500 in India greenfield project which will be locally recruited.

Human Resource (HR) Policies and Procedures, Working Conditions and Terms of Employment: The company has a Code of Conduct (CoC) which captures the key tenets of overarching labor welfare provisions applicable to the company operations. Additionally, EPIC individual operations adopt HR policies and procedures [E.g Service manual as per law in Bangladesh], in addition to detailed policies [covering employment conditions] in line with the EPIC code of conduct and are  broadly aligned with the IFC PS 2 requirements. These policies and procedures are reviewed and renewed as per changes taking place in the operations, labor law changes, and customer or compliance requirements. The HR policies and procedures are made available for all workers at employment. Key HR policies and procedures were found to be displayed on each shop floor in factory noticeboards. The appointment letter articulating the terms and conditions of employment was reviewed and found to be in local language understood by the workers [also confirmed in the BW reports]. As part of ESAP#5, The company will streamline and consolidate HR policies for the corporate level including the EPIC code of conduct, certain site- specific HR policies (as applicable) in line with IFC PS 2 requirements, which will be available for implementation and customization (as per country specific legislations). As part of ESAP #6, the company for the upcoming apparel manufacturing unit in Odisha (India) will develop HR policy manual in line with the corporate level HR policies, local Indian regulations, and IFC PS 2 requirements.

Review of HR policies, and workers' consultations indicate worker employment conditions and terms of employment available to all the workers in Bangladesh complaint as per local law and, in some cases, beyond legal requirements. Some of these employment terms and additional benefits include annual leave (15 days), sick leave (14 days per calendar year, casual Leave (10 days per calendar year), Provident Fund (PF), 112 days of maternity leave for female workers, life insurance for all employees, scholarship programs for children of associates, death donation benefit, medical facilities for workplace injuries and outside accidents for employees, annual bonus (02 Bonus per year), annual attendance bonus, Ifthar allowance for the month of Ramadan, transport/transport allowance, food allowance.

Collective Bargaining and Freedom of Association:  The company has a well-articulated freedom of association policy for Bangladesh operations in line with the EPIC code of conduct. In Bangladesh, all EPIC facilities have been organized through the Worker Participation Committee (WPC), as per local labor regulations. Discussions with the management and workers as well as BW assessment report indicate that: members of the WPC have equal members from management and from the workers [usually 12 each with the sizeable representation of women workers); WPC is formed through an election process [for a period of 2 years] and candidates were nominated by their co-workers in every case following the legal framework;  WPC election is held within 30 days of the formation of the Election Conduction Committee (ECC) formed with workers' representatives [3] and management representatives [2]; meeting agenda is set by both the management and workers and meeting notice is posted on the notice board 7 days ahead of the meeting (held every 2 months); meeting minutes were maintained in the files and sent to the Department of Labor (DoL) within 7 days of the meeting and minutes were posted on the notice board;  decisions of meetings were implemented most of the times and followed up in subsequent meetings. The names and photographs of the WPC members are displayed on the notice boards.             

Non-discrimination and Equal Opportunity: EPIC has a well-defined policy on non-discrimination (in line with EPIC CoC), and the company does not discriminate against any workers i.e. full-time, contract or migrant workers. In Bangladesh, apart from the security workforce, all the workers are direct employees of the company. Migrant workers are employed only for EPIC Jordan facility and follow migrant worker employment laws in Jordan applicable for migrant workers, including home country regulations when a worker is recruited.

Grievance Mechanism: EPIC has established a grievance mechanism (GM) for workers consistent with IFC PS 2 requirements apart from additional GM including a direct hotline of Amader Kotha (https://amaderkothahelpline.net/), and other buyers (grievances received by Buyers are communicated to the company for suitable action). The company’s own GM and Buyer’s GM are adequately displayed on all shop floors in the local language, and awareness is ensured for the workers. The company’s own GM is a simplified system with a clear process flowchart, grievances screening & identification of severity level, roles and responsibilities, review period, and indicators for review. Multiple grievance channels available to the workers include  department supervisor / manager, unit counselors, welfare officer, plant HR Head or BHs, suggestion / grievance boxes provided, central HR (Corporate Office), WOVO Digital App (received at HR Central Office), EPIC Ethics Hotline. The GM process has provision for anonymous complaints, and all these grievances are reported on a daily basis to the corporate level (suggestion boxes are opened on a weekly basis in front of the corporate team), and the remediation process is put in place within the stipulated timeline. The employees are trained on GM starting with onboarding and induction program, and further through pocket meetings, participatory council, display on factory noticeboards, and digital panel display during lunch. For the WOVO digital app training (which allows them to raise grievances through the home too), an awareness session (spanning a total of 320 training hours was conducted for 20,705 participants) from the five plants and corporate office team of EPIC in Bangladesh allowing sufficient time to familiarize employees with the features and functionalities of WOVO. At each factory, there is a dedicated Grievance Handling Committee (GHC) to handle grievances within a stipulated time frame.

Prevention of Sexual Harassment: EPIC has developed a framework prohibiting sexual harassment at workplace (Harassment Policy and Investigation Policy) in each jurisdiction where EPIC Group operates factory or office premises (Hong Kong SAR, China, New York/Arkansas, Dubai, Jordan, and Ethiopia). In Bangladesh, EPIC, in addition has a dedicated Complaints Committee (CC) with an independent ombudsman to handle all sexual harassment issues. CC is an independent committee that consists of employees, worker participatory council member, external independent members (3 management, 2 workers and 2 external members). Sexual harassment cases, if any are screened from the consolidated grievances received by EPIC at the corporate level.  Discussion with the workers and BW assessment report indicate that the CC committee forms an investigation committee (typically including one worker and one management representative, two representatives from outside organizations) to investigate the cases.  Once the CC provides the investigation report to the management, a relevant committee at a higher level takes the action/decision or provide a remedy based on the severity level of the case reported.  Where necessary, the company may take disciplinary action including terminations. EPIC Group partnered with BRAC Bangladesh to provide a company-wide “Safeguard” training for all its Bangladesh-based staff. As part of ESAP#5, EPIC will further strengthen and update the sexual harassment  at workplace grievance procedure in line with survivor centric approach and detailing out the process for screening,  investigation, and resolution process, including provision for training of the committee members on undertaking an investigation.

Protecting the Workforce: Employment opportunities provided by EPIC are free of any forced, bonded, or child labor and are ensured through established policies and SOPs. The company ensures that it does not employ those who are under the age of 18 years, and follows national law, which is usually verified through national ID and authenticated via the government database, birth certificate, physical markers of age checked through doctor and licensed medical practitioners will check for. EPIC’s policies are aligned with local and international labor legislation and standards such as ILO Conventions, ISO 45001: 1800, BW or Fair Labor Association (FLA). Additionally, the implementation of these standards is verified through internal monitoring and annual social audits based on WRAP and SEDEX auditing standards and also verified as part of the BW assessment.

Retrenchment: The company policies on retrenchment indicate that the company complies with the host country regulations should there be a situation requiring retrenchment. During COVID-19, two factories in Jordan and Vietnam were closed, and retrenchment process was done as per the host country regulations with the aid of local lawyers and audit firms. As part of ESAP# 5, the company will augment the retrenchment policy in line with IFC PS 2 requirements.

Worker’s Accommodation: The company’s facilities in operation do not provide any accommodation for workers. EPIC will contractually allocate responsibility to the construction company to ensure that the provision of accommodation for construction workers complies with respective national laws and requirements of IFC PSs. As part of ESAP# 3, the company will develop/ update labor accommodation guidelines in line IFC- EBRD Workers' Accommodation: Processes and Standards  (2009). The construction stage accommodation facilities for workers will be monitored by internal EHS auditing team.

Occupational, Health and Safety (OHS): The company has established an OHS management system certified per ISO: 45001 and has adopted a H&S Policy accompanied by a documented OHS Manual and SOP on Safety Management, Hazard Identification and Risk Assessments (HIRAs) have been prepared to list all identified hazards within a work zone, including the hazard levels and the controls available to eliminate or reduce the associated risk. The HIRAs have been developed specific to different work zones within the factory and appropriate signages, highlighting the risk assessments and safety instructions, have been displayed in respective work areas. Training is provided to workers on usage of personal protective equipment (PPE) and usage of PPE was noted to be adequate. The compliance team of the facility is responsible for routine inspections and monitoring. The factories have also constituted a safety committee, which meets regularly to discuss the OHS issues. A workplace environmental quality monitoring program is in place to monitor indoor air quality (PM10, PM2.5, SO2, NOx, VOCs, CO, CO2, O3, CH2O) in work areas, using third-party laboratories. The company also monitors workplace noise within the factories and has identified production zones/ancillary areas with high noise levels, basis which a PPE protocol has been designed and implemented. The company conducts regular annual medical check-ups for staff members. Once operational, the new apparel factory in India will implement similar OHS systems and processes.   The company's Lost Time Incident Frequency Rates (LTIFR) across facilities in operation was reviewed [Jan - Dec 2023] and was found to be below the levels for Bangladesh. The LTIFR for operating facilities when compared to Industry benchmark was found acceptable within the range of 3.21 to13.77, with the Epic Group values in the acceptable range [6.18-9.14].

Supply Chain: EPIC has a documented Code of Conduct (CoC) (available online at: https://www.epicgroup.global/corpinfo21v1/wp-content/uploads/2023/05/EPIC_Group_Code_of_Conduct_May2023.pdf) that provide its commitment to labor standards including for the business partners to comply with local and international laws/ regulations and include suppliers and third party facilities [non- captive]. The code of conduct clearly state EPIC’s policy on maintaining traceability in the supply chain. In addition, all raw material suppliers are required to sign the EPIC Forced Labour Certification. The key raw materials for EPIC include fabric, trims, zipper, cotton, and thread. A review of the information shared by the company indicates that the company maintains traceability of all the raw materials supplied to the company. For fabric, the company, apart from articulating the requirements, relies on either Better Cotton Initiative (BCI), and  Organic Content Standard (OCS) certification.

Effectively, the EPIC compliance team follows specific processes for ensuring compliance in raw material sourcing, third-party outsourced facility compliance, and ensuring customer/ Buyer’s process and protocol. The facilities used for outsourcing work (in case of capacity constraint) have long-standing relationships with EPIC, are disclosed to Buyers, and are audited to similar operational, labor, and environmental standards as EPIC manufacturing facilities and are committed to EPIC’s CoC.  In addition, buyers like Levis and Uniqlo have their own audit processes for these facilities. EPIC conducts a comprehensive evaluation before onboarding the third- party facilities periodic visits, unannounced audits taking place, including worker interviews during visits. EPIC follows the following process as part of onboarding the facilities which evidenced through supporting documentation: EPIC conducts a comprehensive evaluation of the supplier, based on Epic Standards, national law; the customer conducts an audit to approve the supplier for EPIC; the supplier agree and sign EPIC Supplier CoC; legally binding agreement signed with the suppliers, before entering to business with EPIC; periodic social audits and un-announced audits conducted to check compliance to the standards; in case of non-compliance, corrective actions are agreed and a decision communicated to the respective responsible stakeholders for decisions.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: The EPIC Group operations consume resources such as electricity, diesel, gas, and water. Last year’s consumption of (EPIC facilities in Bangladesh was approximately 17.50 million (kWH) of electricity, 7.2 million cubic meters of gas, 1015 kilo liters (KL) of diesel, and approx. 1.3 million cubic meters of freshwater consumption. The company sources electricity from the national power grid and also has on site captive power generation capacities at its CIPL (2.5 MW) and EGMCL (1.15 MW) manufacturing facilities that use natural gas as a fuel. The company has also installed rooftop solar at its CIPL (100 KW) and GTL (800 KW) facilities. The company also has backup diesel-based generators. The water requirement is sourced from groundwater aquifers at the CIPL, GTL, and PGCL, and the company has obtained permit from the Upazilla Parishad authorities for use of the groundwater resources. At EGMCL, the water is supplied by the Bangladesh Export Processing Zones Authority (BEPZA).

The daily process water requirement for the new manufacturing facility in India is estimated at 2,250 cubic meters, including sanitary water. The Odisha Industrial Infrastructure Development Corporation (IDCO) will supply the water for the new factory. Power for the facility will be sourced from the state power grid, and the facility will be equipped with an alternative power connection through UPS and backup diesel generators to mitigate and address any potential disruptions if they were to occur.

Greenhouse Gases (GHG) Emissions: The company annually prepares its GHG Inventory through a third-party service provider and ensures the disclosure of emissions in its annual sustainability report. The total GHG emissions (Scope 1 and Scope 2) covering greenfield facility in India and the capacity expansion in Bangladesh will be 3964 tCO2e/year. The company continues to explore opportunities to improve energy efficiency across its operations and expand its renewable energy footprint to achieve its long-term sustainability goal. As a step in this direction, the new factory in India is being designed as a net-zero carbon facility.

Air Emissions: Exhaust gas emissions produced by combustion of gas in captive power plants and or diesel in backup generators are the main source of air emissions. The company’s factories also use boilers for steam generation using gas, diesel, and fabric wastage as fuel. The most recent point source air emissions monitoring results indicate compliance with the national air emission limits as well as WBG General EHS guidelines. The company also performs monitoring of ambient air quality and results confirmed compliance with the national ambient air quality standards.

Wastewater Treatment: The company generates process wastewater from its washing operations. The company at the CIPL, EGMCL, and GTL factories has installed on site Effluent Treatment Plants (ETP). The PGCL facility uses a dry process without generating process effluents. A softener system is also being introduced to treat and recycle wastewater from ETPs back into the production processes; this enables the reuse of the treated water, reducing the need for freshwater intake. The effluent quality is tested regularly by third party, and monitoring results for the facilities showed compliance with national standards and WBG EHS Guidelines for Textile Manufacturing (2007) .  The company has adopted a program to upgrade existing ETPs to meet the aspirational level set by the ZDHC wastewater initiative. The ETP upgrade has been completed at CIPL, is ongoing at EGMCL, and is proposed to be implemented at GTL. Additionally, the treated effluent is tested quarterly by the Department of Environment (DoE).

The company collects domestic sanitary wastewater in properly designed septic tanks in line with the national regulations within the factory premises. The company is actively working on plans to progressively install sanitary wastewater treatment plants (STPs) at its factories. For the new apparel manufacturing facility in India, effluent treatment will be arranged through a common effluent treatment plant (CETP), to be installed by the industrial park authorities, upon obtaining the required regulatory approvals. The company will commence the operation of its washing facilities only after the CETP is commissioned. In case authorities Industrial Park authorities do not install CETP, the company will ensure provision for ETP for its plant as per national regulations, WBG General EHS Guidelines, and WBG EHS Guidelines for Textile Manufacturing (2007).

Waste management: The company as part of the ESMS has developed a Waste Management Policy and Procedures. The primary solid waste stream produced by the company's factories consists of waste fabric, utilized as a fuel in fabric waste boilers installed at CIPL and EGMCL units; a part of this fabric waste is disposed of through a global fabric recycling platform (Reverse Resources), where it undergoes downcycling in the apparel industry. The other waste streams from the factories, such as paper, cartons, plastics, and iron scrap, are disposed of through third-party recyclers. The factories generate a limited amount of hazardous waste in the form of used batteries, spent oil, cartridges, chemical drums, etc., that is stored in designated hazardous waste storage areas within the factory premises and disposed of through third-party vendors. The company reports that no hazardous waste is generated from the manufacturing process. Monthly records are maintained on the quantity of waste handled for various waste streams, and manifests are maintained for all waste disposed of through vendors. 

Hazardous Chemicals: The company uses approximately five hazardous chemicals within apparel manufacturing. The company has a documented chemical management policy and has also developed a chemical incident and accident prevention and control procedure that offers specific guidance for storage, transportation, transfer, handling, and disposal of chemicals. The procedures also provide    guidance for accidental spills of hazardous chemicals, aiming to minimize the potential harm to both human health and the environment. Chemicals are stored in a dedicated chemical store with secondary containment, proper labeling, and MSDS. During the appraisal, inappropriate handling and mixing of bleaching agents were noted at the washing section at CIPL- taking place in a constrained area and without the use of proper PPEs. As per ESAP#7, the company will revise its chemical management policy and procedure, providing specific guidance for handling and mixing bleaching agents in the washing processes and ensuring implementation across all factories.

For the new apparel manufacturing facility in India, as per ESAP#3, the company will develop site specific monitoring and management plans for air emissions, wastewater, hazardous chemicals, and wastes generated from the Project, consistent with national law, requirements of IFC PSs and WBG General EHS Guidelines and WBG EHS Guidelines for Textiles Manufacturing (2007).

PS4: Community Health, Safety and Security

Infrastructure and equipment design and safety: The EPIC Group’s apparel manufacturing plants in Bangladesh have been designed, constructed, in compliance with the national building and fire safety codes and relevant factory regulations. The company has obtained factory, layout approvals, building stability certificates, and operational permits from the competent authorities for all its operational facilities. The company has established regular infrastructure and an equipment safety-related inspection regime in compliance with local factory regulations. A Standard Operating Procedure (SOP) has been developed for planned preventive inspection of facilities and their regular maintenance (PPM), which outlines a PPM calendar for all operational units. All critical machinery and equipment are inspected on a regular basis as per the PPM calendar, ensuring compliance with national standards and norms.

Life and Fire Safety: The visited company factories exhibit a comprehensive approach to life and fire safety (L&FS). Fire detection, alarm, and suppression systems, both passive and active, are well-integrated. These include centralized smoke detection and alarm systems, fire hydrants, fire extinguishers, manual call points, fire exit signages, emergency lights, and public address systems. The facilities have valid fire licenses issued by the Bangladesh Fire Service and Civil Defence Department (BFSCD) and are compliant with their requirements. Periodic audits, as well as bi-annual fire drills, are conducted by the BFSCD on each factory. The company organizes firefighting training and in-house fire drills for the employees on a regular basis to build preparedness and ensure compliance. The emergency evacuation plan is posted in the local language and is strategically placed in required areas. Adequate emergency exits, unobstructed pathways, and outward-opening exits leading to safe assembly points were noted. The assembly points were found to have sufficient space. Stairwells have adequate capacity and adhere to local law requirements, with handrails and are clear of obstructions. The fire extinguishers for the facilities are selected based on the risk and are properly installed throughout the facilities as per requirements. The extinguishers are regularly inspected and undergo periodic maintenance as per a predefined plan. The fire alarm systems were found to be adequate, and the alarms were audible throughout the premises. The factories perform monthly fire alarm tests and routinely verify the proper functioning of the emergency power system.

The factories have a defined L&FS organization with a designated fire safety officer and are supported by a team comprising of firemen and technicians. The company’s facilities adhere to factory regulations by ensuring that a minimum of 6% of the total workforce are certified firefighters, with an additional 6% having received rescue training and a further 6% having undergone first aid training. The company’s factories in Bangladesh are signed up with ACCORD (International Accord) and ALLIANCE (Alliance for Bangladesh Worker Safety) framework agreements, as a requirement for their international customers. Periodic audits and inspections have been carried out at the company’s factories by ACCORD and ALLIANCE in respect of structural, electrical and fire safety; closure of the gaps through implementation of remediation plans at the company’s factories have been assessed and certified. Additionally, the company also involves the Bangladesh University of Engineering and Technology (BUET) to independently assess and certify the structural safety of all company factories. 

For the new apparel factory in India, as per ESAP#8 the company will prepare a L&FS master plan identifying major fire risks, applicable codes, standards and regulations, and mitigation measures that meets the requirement of L&FS guidelines such as local building codes, local fire department regulations, and in accordance with an internationally accepted life and fire safety (L&FS) standard (e.g., United States National Fire Protection Association -NFPA or equivalent). The L&FS master plan must cover fire prevention, means of egress, detection and alarm systems, fire suppression and control, emergency response plan, operation and maintenance and training requirements. The company will commission a suitably qualified L&FS consultant to review the site-specific designs and certify that all the L&FS-related aspects are consistent with an internationally recognized L&FS code in addition to ensuring alignment with the Indian national building and fire safety codes. Following construction, as per ESAP# 9, as part of the new apparel manufacturing facility commissioning test the L&FS professional will inspect the commissioning of the L&FS systems to confirm that the new facility has been constructed in accordance with the agreed design. In doing so, the Company will submit to IFC, professional certifications that the new facility in India is constructed in compliance with national building and fire safety codes and previously approved engineering design, and that all LFS systems were installed as designed and tested in accordance with the L&FS master plan. Any remedial measures needed to bring the buildings into compliance with IFC’s requirements will be completed within a timeframe agreed upon with IFC, subject to feasibility based on mutual agreement and regulatory / 3rd party approvals.

Security Personnel: The plants are mostly located within designated industrial areas, and considering the nature of operations inside the plant, there are no major risks and impacts anticipated to neighborhood communities due to onsite accidents and emergency situations. The company has retained security services contractors to provide security services at all its plants through unarmed security guards. The contractor trains new guards in their own training center before deployment and then provides on-the-job weekly and fortnightly training. The company facilities are usually audited as per the requirements of US Customs-Trade Partnership Against Terrorism (CTPAT). Hence CTPAT aligned SOPs and security protocols are followed at the plant. As per ESAP#10, the company will review and strengthen its security management plan in line with the requirements of IFC PS 4. This update of the security plan will be guided by the principles of proportionality and good international practice and include procedures to: assess risks posed by security arrangements; ensure hiring, rules of conduct, training, equipping, and monitoring of security personnel; provide for background verification on security personnel's individual character with no incidents of past abuses; train security personnel to exhibit appropriate conduct towards plant workers and neighboring communities; train security personnel to manage mock sessions of labor unrest and protests; and to receive and resolve grievances about the security arrangements and acts of security personnel.

EPIC’s manufacturing facilities in Bangladesh are located in the EPZ. For plants like CIPL, the level of engagement with the community stakeholders is relatively higher. EPIC’s CSR programs are carefully planned and designed through a needs assessment process. The “Improving Access to Drinking Water in Communities for Apparel Workers” project was implemented by WaterAid Bangladesh in partnership with the Village Education Resource Center (VERC) to ensure safe drinking water facilities in their workers’ communities. As part of the Social Responsibility Program, EPIC is doing a Student Scholarship Program for the worker's children to support the continuation of studies and end results back to society; it has also sent 5 female workers for higher study graduation in Asian University for Women (AUW).  As part of ESAP# 11, EPIC will develop a stakeholder engagement plan (SEP) and external GM per IFC PSs, to apply to the entire company, including (i) stakeholder identification, analysis, and planning, (ii) disclosure and dissemination of information, (iii) updating the community grievance mechanism, and (iv) ongoing reporting to affected communities and stakeholders, in a manner aligned with IFC PS1 requirements. All the sites will be expected to record details of stakeholder consultations at the facility level.

  The company will locally disclose the social and environmental information for the project at the following locations. Any queries and/or comments about the project may be directed to: