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
Environmental & Social Management Policy and Management Systems: Menema has a corporate health and safety policy (updated in February 2023) focusing on accident prevention and work-related health conditions. In July 2024, with support from their consultant firm (HSEC), Menema drafted a waste management plan that needs approval and implementation. However, Menema has not yet developed an E&S management system (ESMS) for existing operations.
Going forward, Menema will develop and implement an ESMS (including an OHS management system – refer to PS2 for details) for both the existing plastic consumer goods production facility and the greenfield mattress facility, commensurate to the scale and impacts of its activities, and consistent with the IFC PSs and relevant World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines (ESAP #1). The ESMS will include (a) EHSS/sustainability policy, (b) identification of E&S risks and impacts, (c) E&S management programs (including various E&S management plans (resource efficiency, wastewater, waste, road safety and security management), EHS training plan) and standard operating procedures (SOPs), (d) E&S roles and responsibilities, (e) emergency preparedness and response plan, (f) E&S monitoring and reporting and (g) stakeholder engagement and community grievance mechanism. The ESMS will cover operations of both the facilities and will include provisions for an ESMS implementation audit yearly for the first three (3) years by an independent auditor. Upon development of its ESMS, Menema will train its workforce, contractors, including casual and service providers on ESMS procedures.
To ensure effective implementation of its ESMS, Menema will develop a two-year (2025-2027) Implementation Plan, including specific assignment of capital expenditures (CAPEX) and operational expenditures (OPEX) for the environmental, Life and Fire Safety (LFS) and health and safety improvement measures identified (ESAP#2).
Identification of E&S Risks and Impacts: E&S risks and impacts of Menema’s processing facility have been assessed against Guinean E&S legal and regulatory requirements. An E&S Impact Assessment (ESIA) study was completed for the existing facility in Meneah in 2019. As part of the ESIA process, an E&S Management Plan (ESMP) and E&S Monitoring Plan were developed. Key mitigation measures identified in the ESMP included the (i) implementation of a waste management system, (ii) implementation of soil pollution management plan, (iii) annual medical checkup for permanent workers, (iv) establishment of an on-site first aid clinic and awareness of permanent and casual workers on infectious and sexually transmitted diseases (ITD/STD) including COVID, (v) implementation of safety traffic management within/around the facility. An environmental audit was conducted by the Ministry of Environment in 2022 to verify implementation status and effectiveness of the mitigation measures in the ESMP which noted of satisfactory implementation of the ESMP and accordingly Environmental License (“Autorisation Environnementale ") was granted from Agence Guineenne d’Evaluation Environnementale (AGEE) until July 2025 and which will hold valid for the proposed expansion.
For the new mattress facility in Kassognah, Menema will similarly conduct an ESIA as required by local regulations and meeting IFC PS requirements (ESAP#3). The Terms of Reference for ESIA will be shared with IFC for review prior to commissioning the study followed by sharing of ESIA report and ESMP. Menema will implement the ESMP for the new facility as part of their ESMS (Ref. ESAP#1).
Organizational Capacity and Competency: Currently, Menema has an acting environment, health and safety (EHS) manager who oversees Menema’s EHS activities and is supported by a part time independent consultant and the six (6) head of departments at the facility level. Going forward, Menema will strengthen its EHS capacity by: (i) recruiting a full-time E&S manager (reporting to Menema’s senior management) with EHS background and qualifications to lead implementation of the ESMS and ESAP; (ii) ensure adequate annual budgetary allocation for the E&S management function to implement the ESMS and ESMP; and (iii) contract an EHS officer to support the E&S manager considering the level of efforts required to complete the ESAP and multiple locations (Meneah for the plastics goods and Mattress at Kassognah) (ESAP#4).
E&S Training: In 2024, Menema, with the support of their EHS consultant, conducted training on hazardous material dangers, hygiene at work, food hygiene, and risks associated with the rainy season. Menema has yet to develop a training plan for its operations. As part of its ESMS ( Ref. ESAP#1), Menema will develop and implement a EHS training plan, which in addition to the existing topics, will include training modules on its E&S policies, E&S management system and ESMP, EHS SOPs based on employee roles/responsibilities and workplace risk assessment and control, including use of PPE, good housekeeping practices, work permit system (hazardous material, hot environment, confined space, use of sharp knife (in the plastic good factory), heavy lifting), electrical safety (lock-out/tag-out system), fire prevention, first aid and training on infectious and sexually transmitted diseases, and defensive driving course .
Emergency Response Planning: Menema has an Emergency Preparedness and Response Plan (EPRP) developed in July 2024 for the current facility but is still pending validation by local authorities and implementation. Also, no fire drills have been completed since starting operations. The company, under its ESMS (Ref. ESAP#1) will develop and implement the respective EPRP’s for the existing factory and the new facility. The EPRP will cover the probable risk scenarios, including fire and explosion, earthquake, equipment failure, extreme weather, civil unrest, as well as other feasible events, and include a complete emergency drill and training plan. The plan needs to be operationalized by identifying and installing key life and fire safety equipment's, identification and marking of risks and hazardous areas, and selection of safe assembly points to be used during evacuation of the premises, as well as the required medical facilities. Additionally, per local requirements, Menema will certify the plans for both facilities with the competent authorities and will socialize it with the affected communities and establish a collaboration agreement with local fire authorities in case of emergency situations.
Menema’s existing processing facility is equipped with portable fire extinguishers installed throughout the facility. To mitigate the L&FS risks and non-compliances identified during appraisal, Menema engaged a specialized consultant that conducted a L&FS assessment of their existing installation and developed a corrective action plan. Based on the assessment, and as part of the CAPEX defined under ESAP#2, Menema will implement the L&FS corrective action plan, including installation of fire detection and alarm system, fire hose reel system supplied by water reservoir and pumping system, adding safety and evacuation signage, and other actions within the agreed timelines. After the installation of these elements has been completed, Menema will engage the L&FS consultant to confirm that the systems are adequately implemented at both the facilities in line with the Guinean building codes and international L&FS standards (ESAP#5).
E&S Monitoring and Review. As part of the ESMS ( ref. ESAP #1), Menema will develop and implement an E&S monitoring and reporting procedure, specifying Key Performance Indicators (KPIs) such as compliance with E&S legal and regulatory requirements, relevant parameters of the WBG EHS guidelines, leading and lagging OHS indicators (including Loss-Time Frequency Injury Rate - LTIFR), resource efficiency (energy and water consumption/efficiency per ton of products), pollution control (ambient and point source air emissions, noise monitoring, water quality guideline values and compliance with relevant parameters of the WBG EHS guidelines, volume of liquid effluents monitoring, proper storage of solid/hazardous waste management and disposal with licensed service providers). Menema will ensure time-bound corrective actions are implemented (refer ESAP#2), as necessary, based on monitoring results.
Supply Chain Risk Assessment & Management System. Menema purchases its raw materials (polyolefin, toluene, calcium carbonate, ethyl methylamine) via third-party suppliers who in turn purchase from big companies based in UAE, UK and Saudi Arabia.
Going forward, Menema will develop and implement a supply chain management system (SCMS) for its sourcing operations, including (i) the adoption of a supplier code of conduct which will define the E&S and OHS responsibilities and be included into all purchase agreements (to be signed by all suppliers), explicitly mentioning the prohibition of child labor, forced labor, clean working environment, and the protection of biodiversity values (ii) requirement of annual audit of the implementation effectiveness of its updated supplier code (ESAP#6).
PS2: Labor and Working Conditions
Menema has 337 members of staff, of which 35 (10%) are female and 302 (90%) are men. The percentage of females in management positions is about 3%. 28 employees are on permanent contracts, 186 on fixed term contracts and 123 on tasks specific contracts including casual workers. No additional workforce is anticipated for the expansion of the plastic consumer goods facility. For the greenfield mattress facility, about 150 construction workers would be deployed and between 800-1000 workers during the operational phase.
Human Resources (HR) Policies and Procedures. Menema defines its internal HR Policies and Manual of Procedures via an Internal Regulation approved in February 2020 by the general inspector. The policies and procedures are aligned with the Guinea Labor Code. The Manual of Procedures is applicable to all workers but is currently not aligned with IFC PS2 requirements. Menema commits to fair and equitable wages, benefits, and other conditions of employment, recognizes employees’ right to freedom of association, provides safe and healthy working conditions. As per ESAP # 7, Menema will upgrade its internal regulation to include policies on non-discrimination, non-deployment of forced and child labor, prevention of gender-based violence and sexual harassment.
Working Conditions and Terms of Employment. Menema defines the terms and conditions of employment in line with Guinea Labor Code which is consistent with PS2 requirements. All direct employees have a signed labor contract, which states the nature and category of employment, start date and duration, working hours, renumeration, leave, benefits, and employee rights obligations, as applicable. All direct employees can track and see their pay slips showing the number of hours worked, wages (including overtime provisions), statutory social security deductions and other HR information. The labor inspection conducted in 2022 and 2023 confirmed this information. The minimum wage and the working hours at Menema facility aligns with the statutory labor law requirements in Guinea. Overtime is voluntary and paid based on the national scale.
Workers Organizations. As per the provisions of the Guinean Labor Code, Menema recognizes employees’ right to freedom of association as explicitly outlined in its Internal regulation. However, there is currently no union in Menema.
Grievance Mechanism: As per ESAP #8, Menema will develop and implement a worker’s grievance mechanism in line with PS2 requirements for both facilities, including identifying suitable mechanism for complaints related to Gender Based Violence (GBV), establish suitable referral pathway for such services and facilitate external training for the gender committee to execute its role effectively and sensitively. The gender committee will take cognizance of complaints related to GBV, conduct proper enquiries, help and redressal to the victims. The worker grievance mechanism and referral pathway will be accessible to all workers, including casual /daily/ occasional workers. The mechanism will allow for anonymous complaints to be raised and addressed.
Occupational Health and Safety. Inherent hazards and risks of a mattress and plastics goods processing plant include working in hot and noisy environment, confined spaces entry, with energized equipment, ergonomic hazards, or with hazardous materials such as calcium bicarbonate, polyolefin, toluene. Menema’s mattress processing will be significantly automated and will minimize such workplace risks. Menema provides personal protection equipment (PPE) to the workforce including casual workers (e.g., gowns, gloves, mask) however enforcement on use of PPEs was noted to be inadequate. In addition, workstation hazards, such as ergonomic issues at the plastic blow out station, high temperatures and noises (above 80 dBA) at the mattress injection station, issues with access to potable water at hot environment areas, insufficient gender-sensitive changing rooms and toilets for the casual workforce, among others, have been identified. These will be addressed through a corrective action plan/implementation plan as referred in ESAP#2.
As part of the ESMS (Ref. ESAP#1) mentioned above, Menema will develop an OHS management system for both facilities, including an OHS policy, OHS risk assessment, management plan and procedures, OHS monitoring framework and definition and monitoring of OHS leading and lagging indicators. Menema will also establish an OHS Committee to promote the health and safety policy and program by identifying hazards and making recommendation at the processing facilities and develop and implement a comprehensive training plan based on workstations hazards for all worker categories.
Menema will invest in EHS infrastructure to minimize workplace hazards through the installation of fans and/or heat extraction/ventilation system at hot working stations and stations with hazardous chemicals throughout the facilities, install enclosures around machines to reduce the amount of noise, especially for noise levels above 80dBA, provide easy access to potable water through the plant, and provide rest areas for its workforce. With the anticipated increase in workforce, Menema will: (i)improve its first aid clinic with the recruitment of an additional nurse, expand the services of the clinic day-to-day/night shifts, establish a contractual agreement with a neighbouring health clinic (including access to ambulance and (ii) strengthen its current pre-recruitment and annual check-up of its workforce and include tests for eyes, chest, and audiometry test including any tests to be conducted for workers working in areas with hazardous materials (ESAP#9).
Workers Engaged by Third Parties: All the current workers (permanent, fixed terms, task specific and casual) have been directly hired by Menema. Menema will rely on contractors for the construction of its new mattress production facility. Menema will develop and implement E&S and OHS provisions for bidding documents and contractual agreements with all contractors. It will also develop a contractor management plan including contractor labour management monitoring activities and a contractor training plan for effective implementation (ESAP#10). The contractor management plan will also include specific requirements from the biodiversity management plan, described in PS6 section below.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. The processing of mattress and plastics goods is a resource (energy) intensive process. Menema’s processing plant is connected to the national electricity grid through a transformer and has a backup 500 KVA diesel generator in case of power outages. The new facility is expected to have similar arrangements.
As per ESMS (ref. ESAP#1) going forward, Menema will develop and implement a resource (energy and water) efficiency management plan and establish KPIs for assessing its energy/water usage and efficiency per tons of products for the current and future facility.
Greenhouse Gas Emissions. Total GHG emissions for both facilities is estimated to be 4,148 tCO2eq (scope 1 emission of 36 tCO2eq and scope 2 emission of 4,112 tCO2 eq).
Pollution Prevention
Air emissions and noise. Regular (monthly) maintenance is conducted on the machineries. Going forward, as included in ESAP#1, Menema will develop and implement an E&S monitoring and reporting procedure for both facilities including for: (i) ambient air quality (AAQ) levels to monitor compliance with Guinean’s Air Quality Decree and air emissions from DG sets (compliant with WBG EHS Guideline values) (monitoring to be done through licensed service provider and in case of exceedances, Menema will implement actions to meet the AAQ and emissions standards); and (ii) ambient noise mapping during day and nighttime at the closest sensitive receptors across all its working stations and provide earmuffs to its workers, in case of noise levels above 70 dBA.
Wastewater. Wastewater from the existing operations includes wastewater generated from cooling process which is a closed loop process and recycled. Sanitary wastewater is stored in septic tanks and collected by a licensed private service provider. Going forward as included in ESAP#1; Menema will develop a wastewater management plan for both facilities. As part of its monitoring plan under the ESMS, Menema will monitor and report on volume of wastewater generated and ensure that the treated effluent meets the value specified in WBG EHS Guidelines.
Management of solid and hazardous waste. Menema has developed a waste management plan in July 2023 to manage its solid and hazardous waste. Menema will upgrade and operationalize /implement its waste management plan as part of its ESMS (ref. ESAP#1) at both facilities to address medical waste management. Medical waste produced at the on-site first aid clinic will be stored in appropriate bins; collected and handled by a licensed service provider and disposal at sites authorized by the local authorities.
PS4: Community Health, Safety and Security
Traffic Safety. Menema currently uses its own fleet of eleven trucks and drivers for distributions and also outsources transport to external providers for inland deliveries. Menema will acquire additional twenty-five delivery truck exclusively for the mattress factory at exploitation phase. As part of the ESMS (Ref. ESAP#1), Menema will develop a road safety management plan at both facilities for both internal and contracted fleets. This plan will cover driver fitness, competence, training, speed limits, emergency response, vehicle maintenance and safety standards to be adhered.
Security. Menema's existing facility is in an industrial area with a fence to prevent illegal entry. They have a contract with an unarmed security guard agency. As per ESAP#1, Menema will develop and implement a security management plan for both facilities, including background checks, training, and a code of conduct for security guards.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Menema’s existing facility is located in the Western Guinean lowland forest’s region of the Tropical and subtropical moist broadleaf forests ecoregion. No risks in terms of PS6 are identified for the existing plant expansion which is situated in an industrial area.
The proposed greenfield mattress factory and showroom site is situated in a peninsula occupied by secondary vegetation re-growth, surrounded by adjacent mangrove forest. A Biodiversity assessment was conducted in December 2024 by The Biodiversity Consultant (TBC) (third party consultant) and per the study, vegetation of the peninsula in which the site is located was cleared between 2023 and 2024, before Menema purchased the title deed. Prior to clearance, the peninsula was characterised by open, degraded (formerly cleared) areas which are considered Modified habitat, interspersed with some patches of remnant secondary forest habitat in the centre and northeast (amounting to approximately 2 hectares (ha)). The recent clearance of aapproximately 3.3 ha of mangrove (Natural habitat) outside the northeastern boundary of the area; covered by Menema’s title deed is understood to be unrelated to the project. The cleared secondary vegetation within the site is considered modified, since the original forest habitat that was present around 2004 was effectively cleared by 2014. The project does not overlap with any protected areas (PA); the closest PA is the nationally protected Kaloum classified forest which lies approximately 7 km southwest of the site.
Priority biodiversity values with potential to occur in the proposed project’s area of influence (AoI) (particularly adjacent mangroves) include the threatened and migratory turtle species Hawksbill Turtle (Eretemochelys imbricata – Critically Endangered), Green Turtle (Chelonia mydas – Endangered), Loggerhead Turtle (Caretta caretta – Vulnerable), Leatherback Turtle (Dermochelys coriacea – Vulnerable), Olive Ridley Turtle (Lepidochelys olivacea – Vulnerable,), African Softshell Turtle (Trionyx triunguis – Vulnerable), Black-legged Kittiwake (Rissa tridactyla – Vulnerable, Migratory), and a range-restricted gecko (Hemidactylus albivertebralis – Data Deficient). However, no species were identified as being likely Critical habitat values or having any impact due to the project activities. No threatened ecosystems are likely to occur within the project’s AoI. Mangroves in the AoI are considered Least Concern by the International Union for Conservation of Nature (IUCN).
Considering the proximity to the adjacent mangrove habitat, a biodiversity management plan (BMP) for the construction phase will be developed and implemented prior to commencement of construction at the greenfield mattress facility (as per recommendation outlined in the biodiversity assessment study) and also for the operation phase. The plan will include measures to mitigate the construction phase impacts and manage operation phase activities in a way that avoids any adverse impact on the adjacent mangrove habitat. A biodiversity monitoring plan will be included in the BMP to measure the effectiveness of the mitigation measures and set out procedures for adaptive management where a need for improvement of mitigation and management actions is identified. The BMP will be implemented by Menema within agreed timelines (ESAP#11).
