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
NSG Group policies, including those relating to Sustainability, Environment, Health and Safety, and Human Rights, and their Code of Ethics, apply to the company and its subsidiaries. Under the ISO 14001 certified E&S management systems (which form part of the integrated Management Systems (IMS)) for each asset, procedures are established to identify all national environmental laws, regulations and rules that apply, and to manage and report on E&S risks and impacts accordingly. These procedures include an E&S screening process for proposed investments, and measures relating to training, monitoring, auditing, reporting and staffing. Although not certified, similar OHS risk management systems also form part of the IMSs for each asset.
Both sites have documented emergency response plans (ERPs) focused largely on fire risk but also on terrorism, evacuation from heights, hazardous material leaks etc. Training, tests and drills are regularly undertaken (internal and with local emergency services). Both sites face increased risk from climate related hazards, notably flooding, extreme heat and droughts. As per ESAP#1 the ERPs will be further developed to address risks for workers and those associated with pollution arising from flooding and other extreme events related to climate change
The NSG Group Chief Sustainability Officer has overall responsibility for EHS performance, including asset and Group level compliance and reporting. He reports directly to the President and CEO and is supported by the Regional Sustainability Directors (two in Europe) who in turn provide oversight of, and support to, asset based EHS coordinators, ensuring the relevant standards are met, appropriate data collated, and records kept. The Group Chief Human Resources Officer has a similar role with respect to working conditions and labor force management, and delivery of the Group Diversity Inclusion and Equity (DEI) Policy.
A Sustainability Committee, chaired by the CEO or his nominee, develop the sustainability strategies, preside over all of the Group’s sustainability related activities, and ensure effective communication with various internal stakeholders including the Strategic Risk Committee, and reports to the Board of Directors
All suppliers must sign the Group Supplier Code of Conduct that commits them to comply with the Group Health and Safety Policy and a range of environmental, labor and human rights standards. They also undergo evaluations (for environmental labor and human rights, ethics and sustainable procurement performance) carried out by Ecovadis, a rating agency. Suppliers identified to be in a high environmental risk category are required to obtain ISO 14001 or equivalent certification. The Group Sustainable Supply Chain Charter aims to align supplier EHS and labor performance requirements with those of the NSG Group, and follow the ISO 20400 sustainable procurement standard; the company is currently developing action plans to work with its suppliers to enable their compliance with the Charter.
The company collates E&S and OHS data including those relating to: accidents and near misses, fuel and water consumption, CO2 emissions, waste to landfill, recycled materials, employee engagement, employees by gender, and supplier spend. These are discussed monthly at Company Board Meetings and every six months at the Regional Safety reviews.
The company’s E&S and OHS management systems were noted to be commensurate with the scale and E&S risks and impacts of its operations and the project, and their implementation at asset level to be robust.
PS 2 – Labor and Working Conditions
The Group Human Rights Policy, which is aligned with the Universal Declaration of Human Rights and the ILO Conventions, and the Key Group Employment Standards, as set out in the Code of Ethics, are generally consistent with IFC PS 2 and apply to all employees. Together they ensure: safe and healthy work environments; compliance with national labor legislation including on working hours, worker age and retrenchment; pay and employment terms at or better than the legal minimum; no use of forced labor; recruitment based on ability; regular employee consultation and communication; training for safe work and staff development; freedom of association, collective bargaining and union membership rights; and zero tolerance of harassment. About 12 percent of the Polish workforce is unionized.
The Group Human Rights policy aims to create equal opportunities for all employees and establishes zero toleration of harassment. Currently 29 percent of the workforce, and 20 percent of managers at Sandomierz and Chmielow are women, significantly higher than the 17 percent and 14 percent (in 2022) respectively across the Group. The Group has a target 30 percent of management positions being filled by women by 2030. The DEI policy promotes training of all managers and country specific action plans for DEI. The Polish plan focuses on gender, mental health, LGBTQ++ and awareness, and is being rolled out by local DEI ambassadors. Under ESAP#2 the company will update its Polish DEI Plan and other documents as relevant to explicitly address GBVH risks.
The Group Ethics and Compliance Hotline, operated in multiple languages by a third-party, enables employees, and contractors to report, without fear of retaliation, any grievances. While this process addresses many of the requirements of an IFC compliant worker grievance mechanism, there are several gaps, notably the specification of the process and time taken for analyses and resolution of grievances and of KPIs for reporting back to those raising the grievance and to company’s management, including the sustainability committee. The grievance mechanism should also explicitly provide a mechanism and focal point for receiving and addressing GBVH complaints, as well as access to a referral pathway for survivors. Under ESAP#3 the hotline will therefore be further developed into an IFC PS2 compliant worker grievance mechanism to be applied to Polish operations.
The Group’s Health and Safety Policy, which applies to both direct and contracted workers at all its assets, establishes safety at the core of its activities with the NSG Improvement Strategy being a key process in its implementation, through leadership training, accountability, communication and involvement of all employees. The EHS teams at Sandomierz and Chmielow have, with oversight from the Regional Sustainability Directors, implemented site- based procedures for preparedness and management of OHS risks in compliance with national laws in their respective Integrated Management Systems. These include regular staff training, risk assessments (updated after any accidents, technical changes or new guidance, and as a minimum once per year), working methods, regular safety walks, CCTV observation, audits, automatic shutdowns, and recording of such processes in internal systems.
The most significant OHS risks relate to exposure to heat, noise, physical, electrical and respiratory hazards. All accidents, incidents and root cause analyses are logged, and improvements developed, in the central reporting and investigation system, which is available to senior level management for onward reporting at Group level. The system is being further developed to support the OHS program through introduction of behavioral measures and auditing systems. There have been no fatal accidents or significant incidents at either asset in the last four years. Near misses are also reported.
Workplace noise and air quality monitoring is undertaken at both sites. While the nature of the specific activities results in exceedance of workplace noise standards, appropriate control measures (time limits spent in noisy areas, ear protection etc.), to reduce noise exposure and hearing related risks to acceptable levels, are implemented
The use of on-site contractors is generally limited to tooling, warehouse maintenance, cleaning and logistics functions. Through signature of the Supplier Code of Conduct all such contractors must comply with national labor laws, the Group Health and Safety Policy and a range of Human Right standards and provide their workers with details of, and access to, the Ethics and Compliance Hotline. Further OHS measures and monitoring are implemented through NSG produced contractor specific health and safety plans and the appointment of an OHS professional to ensure that NSG requirements and local regulations are followed by the contractors. Such requirements will also apply to the contractors that will supply and install the new plant at Sandomierz and Chmielow under the project.
PS 3 – Resource Efficiency and Pollution Prevention
The Group is working to ensure maximum resource efficiency in its own operations.
Production losses at Sandomierz and Chmielow are minimized by recycling waste glass as cullet which also reduces the melting energy required, and hence also GHG emitted. The small amounts of solid waste (comprising grinding sludge, dust and general waste) generated are sorted and to the extent possible and either sent for reuse or recycling or handled by approved local waste management companies as per the specific local regulatory requirements. The Group is also working with customers to improve the circularity of its products to enable them to be recovered and reused in glass production.
Various measures to minimize fuel use and to recover and reintroduce energy are in place, including optimization of furnace chamber shapes to maximize heat radiated back into the melting batch, heat recovery systems, and oscillating firing directions. The furnaces are also capable for being fueled by biofuels or hydrogen in the future. Energy audits are undertaken every 2-3 years with an objective to achieve ISO 50001 certification by 2027.
Cooling water is recycled at Sandomierz using a closed loop system requiring minimal top up. Closed systems and optimization of water use for glass washing have contributed to a 50 percent reduction in water use at Sandomierz between 2019 and 2021.
The use of natural gas as a fuel for the furnaces at both Sandomierz and Chmielow limits sulfur content in the air emissions, while NOx emissions are minimized through the use of modern burners, some of which are oxygen fired. Pollutant levels are consistently within the applicable national requirements and within the guideline values specified in the WBG EHS Guidelines for Glass Manufacturing. The plant emission monitoring is in compliance with permit conditions and its frequency (twice per year) is within the minimum frequency recommended under EU Best Available Techniques (BAT) Reference Document for float glass manufacturing.
Waste process water is associated primarily with glass cleaning. After treatment it is either reused or discharged, as is surface water runoff, to local watercourses. Discharges are regularly monitored and are compliant with the national limits and within the levels specified in the WBG EHS Guidelines for Glass Manufacturing. Domestic wastewater from both sites is released directly to the public sewage system.
Production of float glass and automotive glass products has minimal use of hazardous materials, with coating and coloring products handled in air cleaning enclosures and stored and disposed in accordance with local legal requirements which comply with those of PS3.
The Group’s Road map for carbon neutrality by 2050 has interim targets for 2030, recognized by the SBTi, to reduce Scope 1 and 2 and Scope 3 GHG emissions by 30 percent compared to those in 2018. The Scope 1 and 2 emissions for Sandomierz and Chmielow were 128,745 tonnes CO2-eq in 2023, a reduction of 43 percent since 2018, achieved through a virtual power purchase agreement with a renewable provider. Plans are also being developed for a 4MW CdTe PV farm at Sandomierz. The annual CO2 equivalent emissions from the new coater at Sandomierz will be 2700 tonnes i.e. 2 percent of those arising in 2023 and hence unlikely to affect achievement of the targets. The Sustainable Supply Chain Committee is working on reducing Scope 3 emissions, which is also a key focus of the new Sustainable Supply Chain Charter.
PS 4 – Community Health, Safety and Security
Since both the Sandomierz and Chmielow facilities are located in dedicated industrial sites some distance from the nearest residential areas and with good access to the main highway network, company operations and implementation of the project have and will have minimal impact on its neighboring communities. Noise levels at the closest properties are within national standards and IFC guideline values and no outstanding community complaints associated with company operations were reported. The company security personnel are unarmed.
