IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S Policies. FAC adopted a sustainability policy (2024) which defines the company’s objectives to reduce its electricity consumption and GHG emissions, plastic waste, and improve resource efficiency practices as per GIIP. FAC also adopted a Quality policy which highlights its commitment for food safety and quality of its products. A sustainability action plan has been adopted in 2024 which includes (i) the revision of the current sustainability policy, (ii) definition of KPI for the three sustainability targets mentioned above, (iii) preparation of an energy / cleaner production audit, (iv) installation of solar panel, (v) socialization of the internal labor regulation with its employees and (vi) development/implementation of workers training plan. The time-bound implementation schedule for these six actions have yet to be implemented. Aside from the sustainability strategy, FAC has yet to develop corporate E&S policies (Environment, Occupational Health and Safety, Supplier Code). FAC will develop/implement such policies in alignment with PS requirements. Upon approval, FAC will socialize these policies with its workforce, contractors, and service providers (ESAP#1).
E&S Risk Assessment. E&S risks and impacts of FAC operations has been assessed against Cameroon E&S legal and regulatory requirements. FAC commissioned its production plant in 2010. To meet legal E&S requirements, a regulatory environmental audit was undertaken in December 2011, which audit findings was summarized in a Corrective Action Plan (CAP). Main non-compliance findings were related to the lack of (i) quality/food safety manual; (ii) environmental management system (EMS) manual; (iii) waste management procedure and noise pollution management. Based on implementation progress of this CAP, an environmental license (known as “Certificat de conformite environnementale et sociale”) has been issued in 2012. In April 2024, as per the environmental license renewal, FAC underwent a joint ministerial inspection which recommendations included the requirements for (i) HAZOP (Hazard and Operability) study, (ii) implementation of a integrated pest management (IPM) plan by a licensed service provider, and (iii) monitoring of the production plant’ effluent guidelines values. To meet Terms and Conditions (T&C) of its renewed environmental license, FAC will implement a time bound E&S CAP with assigned CAPEX/OPEX to implement the above-mentioned recommendations (ESAP#2).
E&S Management System and Programs. FAC has yet to develop a PS-compliant E&S Management System (ESMS). FAC will develop and implement a plant-level ESMS consistent with the IFC PSs requirements and Cameroon’s legal and regulatory requirements. This ESMS will include (i) policy, (ii) identification of E&S risks and impacts, (iii) E&S management programs (and relevant Standard Operating Procedures (SOPs)), (iv) E&S management organization, (v) Emergency Preparedness and Response Plan, (vi) E&S monitoring and reporting, (vii) stakeholder engagement, and (viii) community grievance mechanism (ESAP#3). To ensure full institutionalization of its food and beverage products safety requirements, FAC will develop and implement a Food Safety Management System (FSMS) which will be certified against ISO 22001 (refer to PS4. Food safety section below). FAC will share a timebound implementation plan for the ESMS and FSMS and will undertake a compliance verification audit report and certificate of the FSMS once implemented. The FSMS will be developed with the support of an expert consultant and include the relevant SOPs on sanitation, Good Manufacturing Practices (GMP), staff hygiene and training, and a customer complaint mechanism (ESAP#4).
E&S Organizational Capacity and Competency. FAC has a quality manager function in its current organization chart which mission is to reduce and control industrial risk through safe working conditions and food contamination. The implementation of the regulatory E&S Management Plan (ESMP) and related CAP, defined as a result of the above-mentioned 2024 environmental audit, is under the responsibility of the quality manager. FAC will recruit a full-time and competent E&S manager to lead the completion of the attached ESAP and the implementation of the ESMS. The E&S management function will be provided with annual budgetary allocations to implement the E&S action items and maintain the ESMS, including continuous performance improvement. The E&S manager will report directly to FAC’s CEO. Considering the level of efforts required to complete the ESAP, FAC will contract a full time OHS officer (ref. PS2. OHS section below) and a qualified Food Safety consultant to support the E&S manager to complete the ESAP as per agreed timeline (ESAP#5).
E&S training. As part of the implementation of its ESMP, FAC has documented training record related to waste segregation, use of extinguisher, working permit (e.g. confined space) and electrical hazards, including tag out lock out procedure. FAC has yet to establish a formal E&S training plan. As part of the conditions agreed for this proposed IFC financing, FAC will develop and implement a E&S training plan, covering an induction on hygiene, environment and OHS management aspects, and FSMS principles. FAC will includes specific training modules on its E&S policies, E&S management plan, EHS SOPs based on employee roles/responsibilities and workplace risk assessment and control, including use of PPE, good housekeeping practices, work permit system (working at height, hot environment, confined space, rigging and scaffolding, heavy lift), electrical safety (Lock-Out/Tag-Out system), fire prevention, first aid and training on infectious and sexually transmitted diseases, defensive driving course (ref. ESAP#3).
Emergency Preparedness and Response Plan. Major emergency risks at the factory include fire, explosion, and hazardous materials spills. The administrative office is equipped with fire extinguishers with documented records of regular maintenance by a licensed contractor “GLC international”. The food production areas are not equipped with extinguishers, fire detectors, alarm systems nor fire-fighting equipment. There is no documented emergency preparedness and response plan (EPRP) validated by local authorities nor drill exercise conducted. As part of the ESMS (ref. ESAP#3), FAC will develop and implement an Emergency Preparedness and Response Plan (“Plan d’Operation Interne” - POI) consistent with PS1, applicable/relevant section of the WBG EHS Guidelines and the provisions of Cameroon’s building codes and life and fire safety (LFS) standards. Upon completion of the EPRP, including the risk of flooding, FAC will seek the validation of the plan with the competent fire authorities and will socialize it with the communities neighboring its plant. FAC will establish a collaboration agreement with local fire authorities in case of emergency situations (ref. ESAP#3).
E&S Monitoring and Review. Joint ministerial inspections (Environment, Water and Energy) are conducted bi-annually as part of CAP monitoring. E&S audits are also conducted as part of the renewal of the environmental compliance certification every three years. Inspections related to the renewal of underground water extraction and discharge of wastewater permits have been conducted in February 2024. As part of its ESMS (ref. ESAP#3), FAC will develop and implement an E&S monitoring and reporting procedure, specifying Key Performance Indicators (KPIs) including 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, volume of liquid effluents monitoring, proper storage of solid/hazardous waste management and disposal with licensed service providers) and Food Safety KPIs (ref. ESAP#4). FAC will ensure time-bound corrective actions are taken, as necessary, based on monitoring results.
Supply Chain Risk Assessment & Management. Key raw materials required for FAC’s beverage operations include raw sugar, juice concentrates and skimmed milk powder. Sugar is mainly supplied from the local market on a spot purchase basis. Juice concentrates are imported from the USA as per TAMPICO License Terms & Conditions. Skimmed milk powder is purchased via a supplier “Eden Foods” that sources mainly from Holand, New Zealand, Argentina, and Uruguay. Based on the supply chain risk screening, the regions of dairy production in these origins have low risk of natural habitat conservation. FAC will develop and implement a Supplier Code which will define the social and OHS risks as defined in PS2 requirements. The Supplier Code will be included into all purchase agreements (to be signed by all suppliers), explicitly mentioning the prohibition of child labor, forced labor, the promotion of fair and equal treatment, of freedom of association and collective bargaining, working hours and wages; safe and clean working environment, and the protection of biodiversity values, including no-conversion of natural habitats (ESAP#6).
PS2: Labor and Working Conditions
FAC has a workforce of 205 permanent workers. In terms of gender breakdown, 71 workers are females (35%) and 134 men (65%). Women have a strong presence in the production and marketing segment of the plant. There is no use of casual workforce. All workers are paid via bank transfer. FAC anticipates that the expansion project will create an additional 50 direct jobs.
Human Resource Policy and Procedures. FAC has an HR manual and procedures that include Hiring Management Plan, Annual Leave Management Plan, Maternity Management Plan, Performance Evaluation Plan, Accident at work- and work-related disease Management Plan, Disciplinary Management Plan, Pay slip Management Plan and Staff Management Plan. FAC has also a Code of Conduct and Welcome kit pack updated in 2021 to reflect maternity leave policy and medical insurance extension to all workers. As part of the conditions agreed upon for this IFC financing, FAC will upgrade its HR manual policies and procedures consistent with PS2 requirements and national labor law to address child labor/ forced labor, sexual harassment, discrimination, grievance mechanism, gender-based violence. All employees will be required to confirm their understanding of FAC’s upgraded HR manual by signing an acknowledgement letter (ESAP#7). The implementation of the HR Manual of Procedures is led by the HR manager.
Working Conditions and Terms of Employment. FAC’s permanent workers receive written contracts established in accordance with Cameroon labor regulations, which specify entitlements and obligations, including working hours, probationary period, remuneration package and leaves. FAC’s payroll records confirm that the lowest grade employee salary is above the defined Cameroon legal minimum salary; workers are paid overtimes as per approved rates. FAC contributes to the national security bank for all its employees. Based on national labor law, providing private medical insurance is not mandatory. However, FAC has adopted a policy to provide private insurance to all workers earning more than US$134 equivalent when the minimum wage in Cameroon is set at US$70 equivalent. The company bears 50% of the cost and the employee the other 50%. Insurance coverage is just for the employee not family policy. The contribution is fixed at US $8 per month. As of today, around 80% of the staff is insured. The factory operates 6 days a week, 24 hours through three 8hr-shifts to meet production targets. Shift workers take alternate breaks and Sundays are off. Shifts arrangements are aligned with local legislation and confirmed by the company’s labor inspection report (2022). Recommendations from latest labor inspection report included, among others, (i) update structure's opening declaration; (ii) establishment of an OHS committee, (iii) upgrade on-site clinic. Implementation of these recommendations could not be verified during this appraisal. FAC will implement the labor audit recommendations to be aligned with national labor regulations (ESAP#8).
Non-discrimination and Equal Opportunity. FAC has a Code of Conduct which defines the obligation of each employee toward the company. FAC will develop policy to prohibit forced labor, child labor and sexual harassment as per IFC PS2 requirements (ref. ESAP#7). Workers will be trained to report any situation of harassment, discrimination, violation of law, and misconduct to the worker’s grievance mechanism managed by the HR manager which will closely monitor implementation of corrective and disciplinary actions and resolution of such cases (ref. ESAP#7).
Grievance Mechanism. FAC does not have a grievance mechanism for workers. The company will develop and implement a grievance mechanism in line with PS2 requirements applicable to all employes, contractors and service providers indicating (i) available channels to submit grievances (including separate channels for grievances related to sexual harassment, and for confidential and anonymous complaints); (ii) roles and responsibilities for treating and responding to grievances; (iii) timelines for taking action; and (iv) system to log, track and report grievances and their status. FAC will also (i) implement support services for affected workers (e.g., medical services, counseling, legal assistance, job reassignment, etc.) and (ii) appoint a committee to monitor, channel and resolve received grievances. This procedure will be documented, and appropriate worker sensitization undertaken through in-person sessions and dissemination of information on online platforms and notice boards. Staff involved in managing sexual harassment grievances will receive additional specialized training (ref. ESAP#7).
Workers Organizations. Cameroon’s Labor law has embedded a provision of freedom of association. Currently at FAC, there are two workers’ organizations. Staff are free to attend. The staff delegate is elected for 2 years with an option to be reconducted once. There are three (3) mains delegate and three (3) delegate deputies who are meeting at least twice a year as per the provision of the labor law. HR does not attend the meeting. Minutes are kept in the labor register and shared with the HR Director and CEO. Based on the type of requests, the CEO meets with the HR Director and operational managers to address these issues. Worker’s contributions are deducted directly from the salary payment. The amount is 1000F CFA per month. After 30 months, the 1000F CFA is considered as a saving and pay when the employee leaves the company or resigned.
Protecting the Workforce. FAC will develop a HR policy which establishes a Company minimum working age and age verification process aligned to IFC PS2 requirements (ref. ESAP#7).
Workers Engaged by Third Parties. FAC uses labor agent “Le Pro-HR”, a local business for temporary workers (one year contract). During that first year, the employee is managed directly by Le Pro-HR (payroll, social security registration and contribution to public social and health benefits). After completion of the one-year contract, a performance evaluation is conducted by the supervisor. Upon satisfactory performance, the workers are hired as permanent worker. FAC uses contractors for waste collection, extinguishers control, wastewater disposal and service providers for training (e.g. internal audit training, use of extinguishers). FAC will rely on its internal maintenance team for the installation of the ancillary equipment. FAC will develop/implement labor and OHS related requirements for qualification, selection and contractual agreement with its contractors. Upon selection, the contractors will prepare and implement a Contractor Management Plan including contractor labor management monitoring activities for effective implementation (ESAP#9). A formalized contractor training plan for contractors on FAC’s E&S policies, EHS SOPs, working permit, and other issues (e.g. Code of Ethic and Conduct, anti-discrimination policy, grievance mechanism, performance evaluation) will be developed.
Occupational Health and Safety. Potential OHS risks are associated with food and beverage production are cut, burn, lifting, repetitive work, posture injuries, hygiene and falls on slippery surfaces. FAC’s production lines are fully automated using modern machines with adequate safety features and limited moving parts. Workplace risk assessment is conducted at all working stations in each section (production, quality control) annually. Workers are provided with Personal Protective Equipment (PPE) such as hearing protection, masks, footwear, hygienic caps, gloves and working overalls according to their assigned workstations. There is an infirmary on site with a full-time nurse. FAC has signed a contract with a private clinic “Clinique des Cites” to handle workers that require medical attention. FAC has a non-conformity procedure but limited to the quality aspect of their production. During the IFC site visit, the use of PPE was not strictly enforced. In addition, workstation hazards, such as ergonomic at the packaging station, high temperatures and noise (above 80 dBA) at the bottle blowing station, issues with access to potable water in hot environment areas, insufficient gender-sensitive changing rooms and toilets for the workforce, among others, have been noticed. As part of the ESMS (ref. ESAP#3) mentioned above, FAC will develop an OHS Management System for its processing plant, including an OHS policy, OHS management plan and Standard Operating Procedures (SOPs), and definition and monitoring of OHS leading and lagging indicators. FAC will also strengthen its OHS function through the recruitment of a full-time and competent OHS officer (ref. ESAP#5), establish an OHS Committee at the facility, and develop and implement a comprehensive training plan based on workstations hazards for all worker categories (ref. ESAP#3). Finally, FAC will invest in EHS infrastructures to minimize workplace hazards through the installation of fans and/or heat extractors at hot working stations throughout the plant, 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. FAC will measure temperature and noise levels through its plant through a specific OHS monitoring framework and take corrective actions, such as the development and implementation of heat-stress management plan, including access to potable water and fans, ear plugs and strict usage of PPEs. The annual health check-up of workers is done. FAC will strengthen its current pre-recruitment and annual check-up of its workforce for eyes and audiometry test (ESAP#10).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. The factory uses electricity sourced from the national grid, diesel/petrol, and water. The year-to-date electricity consumption for 2023 is 381 kWh for the yogurt production, and 808 kWh for the juice production unit totaling around 1200 kWh per year. As per the proposed expansion, the estimated GHG emissions of the future production line are expected to be 998 tCO2e/year while current GHG emissions are 740Tco2e/ year. FAC has a 200 kv backup genset used only in case of power outage in dry season (June to December). The backup generator is for yogurt production line as electricity shortage can last up to eight (8) hours per day. The diesel storage tank is equipped with secondary containment. With the proposed expansion, FAC will acquire two additional diesel-generators of 300 kv each.
FAC distribution fleet are constituted of thirty (30) vehicles. FAC monitors its fuel consumption. For 2023, FAC used 51723 liters of gasoline and 12931 liters of petrol.
FAC relies on water in its production processes. Water is obtained from a permitted on-site borehole. The permit to extract underground water have been renewed in 2024 for five years after a public inquiry that took place in February 2024 to verify the implementation of the permit’s T&Cs, including tax payment, installation of water pump for the neighborhood community and monitoring of the consumption limited to 3.6 cubic meter per hour. Water from the borehole is tested by the Centre Pasteur au Cameroon and an independent laboratory for physio-chemical parameters, microbiological parameters and verified to the national drinking water standard. A water meter has been installed at the borehole to monitor permitted water extraction volume. As the production of dairy products will increase with this proposed expansion, FAC will upgrade its extraction underground water permit based on anticipated debit to meet its production target and conduct underground water analysis against WHO drinking water standard (ESAP#11). As part of the ESMS (ref. ESAP#3), FAC will develop and implement a resource (energy and water) efficiency management plan and establish KPIs for monitoring and reporting its energy/water usage and efficiency per ton of products.
Wastewater. Wastewater effluent is generated by the manufacturing process and the periodic flushing out of production lines and cleaning-in-place (CIP). These effluents are tested by a licensed laboratory for microbiology and physio-chemical parameters then sent to external drains before discharging into the environment. FAC secured a wastewater discharged permit; it was reviewed during the February 2024 audit before its renewal for five (5) years. Sanitary effluent is disposed of in septic tanks. A certified licensed operator empties the tank when full. FAC will develop and implement a wastewater management plan, as part of its ESMS (ref. ESAP#3). As part of its monitoring plan under the ESMS, FAC will monitor and report on volume of wastewater generated from its production and the sanitary effluent.
Air Emissions and Noise Monitoring. The main source of air emissions from the factory is the 200 kv diesel generator and the boiler fed by diesel. No record of boiler maintenance has been shared during the appraisal. Noise emissions are significantly high in the juice production unit, at the blowout machine. Ambient air is monitored in the production area as part of its ANOR& ISO certification by the internal laboratory staff. The company will implement an air quality and noise monitoring program consistent with WBG EHS Guidelines and national regulations (ref. ESAP#3).
Management of Solid/Hazardous Waste. Solid waste generated by FAC’s operations include plastic wrapping, empty juice concentrates containers & boxes, and general waste. Beyond the site boundaries, there are significant quantities of PET bottles and plastic sachets generated by end-consumers. As part of its sustainability manual, FAC has put in a place a recycling operation that is conducted once a year. FAC’s is considering increasing the frequency of this campaign to have a significant recycled volume contributing to its sustainability target. During these operations, FAC compensates in cash for plastic waste collected at the different collection points. The plastic waste is in turn collected by a licensed service provider. The last campaign resulted in the collection of one thousand two hundred and fifty kilos (1250kg) of used plastic and eight hundred and twenty-six kilos (826kg) of cartoons. There is no formal waste sorting currently in place, but quantity of waste generated and recycled are monitored since 2016. FAC will formalize its waste management plan consistent with GIIP and WBG EHS Guidelines (ref. ESAP#3).
Hazardous Materials. The main hazardous materials stored at the facility include fuel, lubricants, welding, nitric acid, chlorine. There is a dedicated area for chemical storage. Hazardous materials are adequately labelled and stored safely. FAC will develop and implement a hazardous materiel management plan as of its waste management plan (ref. ESAP#3)
Pesticide Use and Management: Currently, there is no pest management. FAC will develop and integrate the Pest management plan in line with GIIP and WBG EHS Guidelines. To implement its plan, FAC will contract the service of a licensed service provider (Ref.ESAP#3).
PS4: Community Health Safety and Security
Food Safety Management System. FAC holds a “ANOR’ certification (until February 2025) from the National Standard and Quality Agency for its brand TINO stirred yogurt and drinking yogurt and TAMPICO juices. The certification process includes (i) sampling testing of the product, (ii) label inspection and (iii) production site inspection. FAC will implement a FSMS which will be certified against ISO 22001 and implement required control measures (ref. ESAP#4).
Traffic Safety. FAC factory is well fenced, located in a mixed urban area setting, and all operations are confined within the boundaries. Traffic at the factory includes supply and distribution logistics trucks. The site is located near neighboring communities, which increases traffic risks to off-site distribution operations. FAC will develop a Road Safety Management Procedure, applicable to its own transport fleet, and to its suppliers and distributors. The procedure will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards (ref. ESAP#3).
Security Personnel. FAC relies on unarmed security agents that are employed by FAC (permanent contract). As per the proposed ESMS (ref. ESAP#3), FAC will develop and implement a security management plan.
