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 Policies. Astarta has established corporate policies focused on sustainable development, environmental, social and occupational health and safety (EHS) management, compliant to national regulations and consistent with IFC’s Performance Standard (PSs). The policies are binding for all its subsidiaries. Astarta’s Sustainability and Corporate Responsibility Committee established in 2020 supports the Board of Directors to monitor sustainable development and progress and effectiveness of the E&S policies implementation. The company’s policies can be found at the following link: https://astartaholding.com/en/sustainable-development-policies-and-procedures/
E&S Management System and Programs. Astarta has established a corporate level E&S Management System (ESMS) in accordance with Ukrainian legal and regulatory requirements and IFC PS1. The management systems implemented at the soybean processing plant are certified against the requirements of ISO 14001 Environmental, ISO 45001 Occupational Health and Safety, and ISO 22000 Food Safety Management Systems international standards. The company will update its corporate ESMS to address E&S risks and impacts related to the project, including any capex and permanent working capital needs for the soy business segment, and therefore will strengthen its supply chain management (discussed below) and stakeholder engagement. Under the ESMS the company will update its Sustainable Procurement Policy to include requirements for contractor management in line with good international industry practice (GIIP) to manage, monitor and report on contractors’ EHS performance during construction, operations and maintenance of the project (ESAP#1).
As per ESAP#2 and based on the Contractor Management Procedure, Astarta will develop and implement a Construction Environmental and Social Management Plan (CESMP) for its SPC Project aligned with PS requirements. The ESMS will include a requirement to develop an Environmental and Social Management Plan (ESMP) for operations (ESAP#3), which will integrate the management measures, as identified in the relevant E&S assessment studies, and manage E&S performance, including ambient air quality, point source air emissions, odor, noise, effluent discharges, waste management, and workplace OHS monitoring. The ESMP will meet compliance with national regulatory requirements and IFC’s PS and will allow to monitor and report on E&S performance against requirements and GIIP, such as the applicable and relevant parts of the WBG General EHS Guidelines, and the EHS Guidelines for Annual Crop Production and Vegetable Oil Production and Processing.
Identification of E&S Risks and Impacts. Astarta has adopted corporate procedures for identification and assessment of risks and impacts such as those related to climate change, value chain, business conduct, workforce, environmental and OHS management, resource efficiency and pollution prevention, product quality & safety, third party contractors, biodiversity, animal welfare and stakeholder engagement. The company identifies and manages its E&S risks and impacts in accordance with applicable national standards, E&S regulatory permits and requirements. Astarta’s subsidiaries’ existing E&S risks and impacts identification process is largely consistent with PS1.
Astarta maintains a legal EHS registry of the applicable Ukrainian laws and regulations. Astarta contracted an E&S consultancy firm for the preparation of an Environmental Impact Assessment (EIA) study for the soybean protein concentrate plant to produce SPC. In September 2023, the EIA was approved by the relevant authority in line with national regulations. Information disclosure restrictions are being applied in Ukraine under existing martial law. Relevant information normally disclosed by IFC but withheld due to foregoing restrictions will be disclosed upon the lifting of martial law and lifting of such disclosure restrictions. As part of the ESMP under ESAP#3, Astarta will develop workplace risk assessment, which will also take into account climate change considerations, and a plan for workplace monitoring, including, for example, heat-related conditions in the workplace, aligned with local regulatory requirements, WBG General EHS guidelines and WBG EHS Guidelines for Vegetable Oil Production and Processing. Based on the workplace risk assessment findings and monitoring results, the client will take appropriate actions as required.
E&S Organizational Capacity/Competency. At the corporate level, monitoring of implementation of sustainable practices, and compliance with national and international standards and requirements are the responsibility of the Director for Sustainable Business Development. E&S management at each individual facility is responsibility of the respective EHS department reporting to the Executive Director and HR&CSR Director. Astarta is adequately staffed to manage EHS aspects for the implementation o the project. EHS trainings are planned and conducted commensurate with personnel’s qualification and functional responsibilities.
Emergency Preparedness and Response. The company has emergency preparedness and response plans (EPRPs) in place, including appropriate fire safety equipment and systems, in line with local/national regulatory and PS requirements. The EPRPs include response to fire, explosions and accidents, with clearly assigned roles and responsibilities within the organization. Plans cover communication with local authorities in line with legal requirements. As part of the ESMP, Astarta will review and update the facility level EPRP to integrate the relevant aspects due to the implementation of the SPC Project (ESAP#3). The company will also incorporate flood risk management into the EPRP, considering relevant risk and adaptation opportunities due to a changing climate.
Supply chain management system. Astarta has a Sustainability Policy, a Policy on Sustainable Development of Agriculture, and a Policy on Forest Protection and Conservation, which include supply-chain requirements applied to its soybean sourcing operations. The company’s suppliers must follow the principles set forth in these policies, including no deforestation, protection of biodiversity and supporting livelihoods, human right commitments and land rights of farmers and communities. Astarta also implements a Sustainable Procurement Policy and Supplier Code of Conduct and works with qualified suppliers, included in the company’s supplier database as they are meeting the company’s E&S standards. Astarta’s own soybean facilities and some suppliers they purchase soybean from are certified against International Sustainability and Carbon Certification (ISCC EU). As per ESAP#1, Astarta will review and update its Sustainable Procurement Policy and Supplier Code of Conduct to include a supply-chain risk assessment, supplier selection and product traceability process aligned with PS2/PS6 supply-chain requirements. The company will require its suppliers to comply with the provisions of its policies and develop a communication plan to inform all suppliers and train employees. Astarta will continue having annual audits to evaluate compliance of their suppliers with these policies.
E&S Monitoring and reporting. At the corporate level Astarta has implemented procedures for monitoring, internal audits, assessment of compliance and management of non-compliances. Subsidiaries have developed facility-specific programs to monitor, report and review the compliance of their facilities’ operations with the respective national law and standards. Management is regularly updated on effectiveness of E&S risk management and control systems through internal and external audits. The company annually publishes its Sustainability Report on its corporate website.
PS 2 – Labor and Working Conditions
As of December 31, 2023, Astarta Holding PLC employed around 7230 people. Of these, 33 percent were women. Around 96 percent were full-time employees.
Human Resource (HR) Policy and Procedures. Astarta’s HR practices are consistent with Ukrainian labor laws and largely aligned with PS2 requirements. Principles like human rights, equal opportunity, anti-harassment and anti-discrimination are implemented through the Code of Business Ethics, Human Rights Policy, and HR Policy. Astarta has developed corporate HR related policies and procedures covering fair working conditions and terms of employment, labor safety and health protection. Astarta informs employees of these policies and procedures through newsletters, bulletin boards, a corporate portal, employee chatbot, and social media channels.
Working Conditions and Terms of Employment. Astarta was one of the first companies in Ukraine to join, in 2008, the UN Global Compact and sign up to the UN Guiding Principles on human rights, decent work and economic growth, gender equality, and the reduction of inequality. These norms are incorporated in the HR Policies. Under the state of martial law, the Law of Ukraine allows for both written and oral forms of contract. The company issues employees a hiring order, and detailed terms of employment, such as working and remuneration conditions, rights and obligations, potential hazardous factors in the workplace and their health impacts, rights to benefits and compensation for such conditions, and notice period, are stipulated in the company’s local acts (Collective Agreement, Social Policy, and Code of Corporate Ethics) in accordance with the law. These terms are acknowledged and signed by the employee prior to starting work.
Since Russia’s invasion of Ukraine, Astarta’s employee welfare measures have included relocating staff and their families from dangerous locations to safer areas, providing assistance packages to employees who have suffered from the military action, full health coverage for employees injured during the military action and psychological support. Astarta continues to pay wages to all employees drafted to the Ukrainian Army. In addition, Astarta has been focusing on the protection of its workforce and facilities, including provision of shelters for employees.
Workers Organization. The company adheres to the principle of freedom of association and is respectful of employees’ right to form, join, and organize labor unions of their own choice and engage in collective bargaining. Primary trade unions representing employees are established at the subsidiary levels. In 2023 around 99.5 percent of Astarta’s employees were part of the CBA.
Protecting the Workforce. The Ukrainian Ministry of Labor has provisions on prohibition of child labor and forced labor. Furthermore, the minimum age of employment at Astarta is 18 years. As reported in the Sustainability Report for 2022, no person under the age of 18 works was allowed at the production facilities and there were no cases of forced labor at Astarta.
Grievance Mechanism. Astarta has a functioning grievance procedure Trust Line which is available at https://astarta.ethics.help/web/uk and allows for anonymous reporting. The procedure is explained to employees at the time of hire. Astarta will review and update its HR policies and grievance procedure, specifically for addressing sexual harassment/gender-based violence (SH/GBV) grievances. The WGM will include a special procedure for sexual harassment/gender-based violence (SH/GBV)-related grievances and training program to ensure a survivor-centered approach (ESAP#4). It will include multiple entry points to raise and address allegations as well as options to report anonymously if preferred. In order to raise corporate awareness on SH/GBV, the company will develop and implement a training program for all employees on Astarta’s SH/GBV policy and grievance mechanism, as well as for managers, human resources personnel and GBV focal points on how to receive, handle complaints and conduct investigations.
Workers Engaged by Third Parties. Contractors are mainly engaged for construction works, security, maintenance services, etc. Astarta has specific requirements for contractors covering labor and OHS requirements. These stipulate that workers engaged by third parties are managed in compliance with the national requirements and company’s policies, including working conditions, health and safety, and labor protection. All contractors performing works within company’s facilities are subject to inspections and audits by the OHS department. Managers at respective facilities are responsible for monitoring compliance with the above requirements. The grievance mechanism and Trust Line extends to contractors’ employees.
OHS. The company has OHS Management Systems at the level of its subsidiaries in compliance with Ukrainian regulations on labor protection and IFC PS2, certified against the requirements of ISO 45001 Occupational Health and Safety Management System. Hazard identification/assessments are conducted for operational activities. Personal protective equipment (PPE), OHS on-boarding and regular annual refresher training are provided to all workers, commensurate with the job hazards and risks. Additional risk-based trainings are provided on a monthly basis. As described under PS3, the company will update the hazardous material management procedure and the register, to include asbestos containing materials (ACMs). The company recently upgraded corporate incidents investigation procedure by incorporating the root-cause analysis in accordance with internationally recognized standards. The company developed internal tools “that provide effective monitoring of performance and corrective action implementation. Astarta has implemented the lockout-tagout (LOTO) safety interlock system providing the safeguard for workers from electrocution. Astarta tracks lost time incident frequency rate (LTIFR, number of lost time injuries per million work hours) as part of its OHS lagging indicators, reporting a LTIFR of 0.8 for 2023, which is below the reference frequency rates for relevant sectors and country. In last three years no work-related fatalities were reported. Astarta monitors working conditions at the workplace, including temperature, noise and dust, and ambient air quality to safeguard workers' health at each facility. The company has established a Safety Committee to monitor safety performance through monthly internal audits to define corrective actions as needed and to communicate with management on OHS matters.
PS 3 - Resources Efficiency and Pollution Prevention
Resource Efficiency. Astarta monitors its energy and water consumption in line with GIIP and identifies areas for improvement. All facilities have heat-generating equipment, such as boilers, and generator sets to provide backup power during outages of the main energy supply. Electricity supply is provided by the Ukrainian electricity grid, and the company also uses sustainable energy sources such as granulated beet pulp and biogas produced within its facility. In 2023 75 percent of gas consumption in soybean processing was covered by biogas produced internally, compared to 50 percent in 2022. Globynsky Soybean Processing plant certified compliance with requirements of international standard ISO 50001 Energy Management Systems.
Astarta withdraws fresh water from surface and underground sources according to limits and permits from local authorities and adheres to national legislation on water consumption. The soybean processing segment withdraws relatively small amount of water for processing operations. The Company is in the process of identifying and assessing risks related to water consumption, with a plan to develop a methodology for water consumption calculation in line with European Sustainability Reporting Standards E3 “Water and marine resources”.
Greenhouse Gases. In 2022 Astarta developed a comprehensive system of climate corporate governance with GHG emissions inventory and calculation based on IPCC methodologies. Scope 1 emissions for Astarta Holding totaled 530,540 t of CO2eq accounting for 59% of total GHG emissions’ estimate for 2023. Scope 1 emissions from the soybean processing operations amounted to 5,303 t of CO2eq which is 1% of the total Scope 1 emission. Scope 2 emissions for Astarta Holding were 2% of the total GHG emissions or 16,398t of CO2eq in 2023.
Air Emissions. The main sources of air emissions in the soybean processing segment include boilers, biogas combustion plants, and soybean crushing plant. Solvent vapors from the soybean oil extraction process are absorbed in a mineral oil scrubber, condensed and returned to the process. Silos and the soybean crushing plant are equipped with dust suppression and aspiration systems. The treatment of air exhaust in the SPC will include installation of a scrubber for removal of particulate matters from the solvent/water vapor and bag filter after the cooler/drier, which is considered GIIP for reduction and control of air emissions. Astarta has developed and maintains annual monitoring plans for point source air emissions for all identified emission sources and ambient air quality. The company reports compliance with regulated national limit values, with no exceedances reported for 2023, and results were within the applicable levels of the WBG EHS Guidelines. The company regularly monitors ambient air at the border of the Sanitary Protection Zone (SPZ) of the facilities, which, for the Globynsky soybean processing plant, is 100 meters from the emission source, as defined by regulatory requirements. Results of the emission dispersion modeling for SPC, including the cumulative impact from the Globynsky soybean processing plant, are within national legal requirements and WHO Ambient Air Quality Guidelines at the SPZ border.
Noise. Noise modeling included the cumulative impact from the Globynsky soybean processing plant, and the levels calculated were below the thresholds for the nighttime at the SPZ border for SPC, in line with national regulations and WBG General EHS guidelines.
Wastewater. Wastewater streams in SPC project will be separately collected. Before being discharged into the external stormwater collector, stormwater is pre-treated in sand and oil traps. Industrial wastewater and household sewage water are subject to pre-treatment through pre-sedimentation, flotation and removal of particles and fatty substances. The pre-treated wastewater is conveyed to the wastewater treatment unit of the Globynsky Soybean Processing Plant for mechanical, physical and chemical treatment. Wastewater is equalized by composition, passed through a coarse filter, separator, floater, anaerobic treatment unit, aeration tank and secondary settling tanks. Treated wastewater is discharged to filtration fields for biological treatment in aerobic conditions. Filtration fields are equipped with monitoring wells located along the perimeter to monitor groundwater quality. Monitoring is conducted by accredited third-party laboratories according to the permits and Ukrainian legislation requirements. Astarta’s effluent after treatment and before discharging to filtration fields are compliant with permits, local requirements and WBG EHS Guidelines for Vegetable Oil Production and Processing.
Waste management. As part of their corporate EHS management system, Astarta has in place a waste management procedure, that includes cost-effective options for waste avoidance, waste sorting, waste recovery and/or waste disposal aligned with GIIP and g WBG General EHS Guidelines. Waste streams are identified, collected and classified according to national waste codes, aligned with the European Waste Catalogue. Within the production facilities the company has dedicated areas for temporary storage of waste, clearly labeled, secured and protected from external factors. Licensed waste operators are under contract to collect and dispose of hazardous waste, sludge from the oil separator and other sorted wastes.
Hazardous Materials Management. Hazardous substances (oils/fuels/chemicals) are stored in line with GIIP to avoid spilling and land and water pollution risks. Astarta keeps updated records on chemicals used in operations and instructions for safe storage and use and appropriate disposal. Employees are trained to work with them accordingly.
Astarta was in the final phase of implementation of the programs for the gradual replacement of ACMs at all its facilities. As per ESAP#5, Astarta will update the hazardous material management procedure and the register, including ACM survey and management plan aligned with national regulatory requirements and WBG General EHS Guidelines for Construction and Decommissioning.
PS 4 - Community Health, Safety, and Security
The soybean crushing plant is in the industrial zone of the town of Globyno and therefore community health and safety risks associated with the processing facility and the project are limited. SPZ is defined and strictly observed in line with the local regulations. The specific community health and safety risks associated with crop production include a potential exposure to pesticides and increased risk of vehicle or machinery injuries on roads and access routes around communities. As a part of a corporate ESMS, Astarta has implemented an integrated pest management program (IPM) with adequate procedures for use of pesticides in line with the IFC PS3 and GIIP requirements.
Infrastructure & Equipment Design and Safety: Risks associated with soybean processing and grain elevators are combustible dust explosions. To prevent and control fires and explosions from combustible dust in the project facilities, Astarta will use recognized international standards in design and operation, develop and implement EHS operational safeguards and procedures including sensors, atmosphere monitoring, and emergency response to prevent and respond to industrial accidents, as per ESAP#3 and ESAP#6 below.
Emergency Preparedness and Response: Response to emergencies is defined within EPRP and coordinated with appropriate authorities. Evacuation plans are developed and communicated to employees. To identify potential hazards and assess risks in soy protein concentrate production, Astarta will undertake Hazard and Operability Study (HAZOP) commensurate to the nature and scale of its business operation (ESAP#6) and update process safety measures and emergency preparedness and response plans based on HAZOP outcomes.
Road Traffic Safety. Astarta has a corporate procedure on traffic safety management in place. The company introduced transport management procedures across all aspects of its operations and performs regular maintenance of vehicle and machinery to minimize accidents.
Security Personnel. Security for Astarta’s offices and facilities is provided by a private security agency. The contractor is licensed and has staff trained according to the relevant national legal requirements, to act in emergency situations and also to provide first aid. Security staff is unarmed.
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
The project will be implemented at Astarta’s existing facilities, which are located in industrial areas or areas where agriculture has been consolidated for several decades. All areas are in converted habitat with no overlap with priority biodiversity values, Legally Protected or Internationally Recognized Areas. The company has corporate standards, policies and procedures including the Environmental Protection Policy and Biodiversity Corporate Standard, which set forth commitments to ensure avoidance and minimization of impacts on biodiversity, ensuring continuous monitoring and assessment of operational impacts. Astarta is in the process of preparing a study on biodiversity in accordance with requirements of Corporate Sustainability Reporting Standards.
Sustainable Management of Living Natural Resources. As indicated above, Astarta processes soybean that comes from its own agricultural fields in Ukraine and purchases additional soybean from other producers also located in the country.
Astarta’s Sustainability Policy, Sustainable Agriculture Policy, and Policy on Forest Protection and Conservation address requirements for no deforestation and require that suppliers comply with the company policies through monitoring and verification. Astarta’s proprietary software enables the company to manage the agricultural production processes, including purchase and supply. As indicated, Astarta implements a Sustainable Procurement Policy and Supplier Code of Conduct, which will be reviewed and updated as indicated under PS1 (ESAP#1). Astarta’s soybean facilities and some suppliers they purchase soybean from are certified against International Sustainability and Carbon Certification (ISCC EU), ensuring no-deforestation, protection of land with high biodiversity value and traceability throughout supply-chains.
