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 Impact
Policy, Environmental and Social Management System. AFISA has developed health, safety and environment (HSE) Policy statements detailing the company’s approach to managing their operation in accordance with both host country legislation and good international industry practice (GIIP). The policy covers aspects relating to the identification and mitigation of project specific risks and impacts, labor and working conditions, environmental impacts, occupational health, and safety (OHS), management of third-party service providers, and stakeholder engagement. AFISA flour products are certified by the local Standards and Quality Agency (ANOR) which is recognized within the central African sub-region (CEMAC) and these certifications are valid until June 2025.
AFISA has developed and implemented isolated plans and operating procedures across its operations. Although a formal environmental and social system (ESMS) is not yet in place, the Company ensures all necessary permits, licenses, and authorizations are obtained in accordance with the national law. All staff receive appropriate training, and established procedures and policies are communicated to guide operations. The Company has developed and is implementing an overarching HSE plan and maintains a strong safety culture through constant awareness and risk assessments of all activities are frequently conducted, and identified gaps are progressively addressed. As part of the IFC financing, AFISA will develop and implement a PS1-compliant ESMS to include the following elements: (i) identification and assessment of E&S risks and impacts; (ii) E&S organizational capacity and competence; (iii) community health, safety and security management; (iv) occupational health and safety (OHS) management programs; (v) contractor management procedures; (vi) Supplier Code of Conduct; and, (vii) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs) (ESAP#1).
Identification of Risks and Impacts. AFISA has developed and implemented a risk assessment process whereby key operational risks are identified for their warehouses, flour mills, administration and active construction activities. The process includes a description of the risk, control measures and roles and responsibilities. In addition, the company has mandated the completion of risk assessments by all contractors undertaking activities, whereby key risks and mitigation measures associated with each activity are identified.
As per the requirements of the Cameroonian environmental management legislation (Law No. 96/12 of 5th August 1996) and other relevant statutory requirements, AFISA completed ESIAs for both their grain terminal, silos storage and flour mill facilities in 2021 and 2023 respectively. These ESIAs were approved with associated terms and conditions and the Company was issued a certificate of environmental conformity in May 2024. The ESIAs identify key impacts associated with the operation, including waste management, noise, air pollution, water, and health and safety as well as cumulative impacts. Both ESIAs are compliant with national law and broadly aligned with PS1 guidelines but lack details on the screening and scoping phase, delineation of extended area of influence as well as a robust stakeholder engagement exercise.
Management Programs: The ESIAs for both the grain terminal and silos storage, as well as that for the flour mill, include framework environmental and social management plans. These framework plans feature detailed E&S aspect and impact tables for various activity phases. Whilst the Company’s overarching HSE plan developed from the frameworks is primarily focused on OHS issues including procedures related to hazard and risk identification, design and development, hazardous materials, safety training and only a light touch on air, noise, waste and E&S monitoring and reporting on KPIs.
AFISA will develop a comprehensive ESMP that will describe the mitigation and performance improvement measures and corrective actions that address construction and operations E&S requirements to achieve outcomes consistent with IFC PSs including labor and working conditions, resources efficiency and pollution prevention as well as community health, safety and security management (ESAP #2)
Organizational Capacity and Competency. AFISA has a department responsible for QHSE. This department promotes and oversees compliance with environmental and safety standards in daily operations. The team includes a Quality Manager, a Quality Assurance and Control Supervisor, an Environment Specialist, and a Safety and Security Supervisor. AFISA has also implemented a training awareness and competence program to support capacity building in relation to its overall E&S performance. This includes safety induction and specialized courses on the prevention of occupational hazards in the milling industry. Additionally, the training covers critical topics such as drug and alcohol policies, incident reporting and investigation, emergency preparedness and response, food safety, hygiene and sanitation, basic safety behavior, effective waste management, office ergonomics, first-aid, and firefighting courses.
The environment, health and safety (EHS) organizational structure is supported at corporate level by an HSE Committee of Board Members defining strategies and policies as well as an Audit Team evaluating EHS programs. However, the AFISA QHSSE manager has a competence in quality management with limited exposure to E&S issues. As part of the IFC investment, AFISA will recruit a dedicated suitably experienced EHS manager who will have the responsibility of overseeing the development and implementation of the ESMS, including PS gaps as identified in the attached ESAP and conducting monitoring of E&S performance and reporting to directly to AFISA’s General Manager (ESAP #3).
Emergency Preparedness and Response. AFISA has developed and implemented specific evacuation plans for each of their operational areas visited, including the existing flour mill, silos storage facility and new flour mill project site. The company also has access to trained and certified firefighters and fire truck available at the Douala port. Trained first aiders make up part of AFISA's workforce and fire extinguishers are deployed and inspected regularly. The new silos storage is designed and built to comply with international standards including a life and fire safety system design. However, the other leased mills away from the Douala port do not integrate life and fire safety into their operations in same manner. As part of the IFC investment, AFISA will update its Emergency Preparedness and Response Plan (EPRP) to cover all its operational assets, integrate the new facilities and align it with the requirements of IFC PS1 including; (i) roles and responsibilities; (ii) structure of emergency response organization; (iii) legal and company requirements; (iv) emergency equipment including life and fire safety (L&FS) requirements to minimize risk and help prevent loss, injury, and death from fire; (v) emergency procedures for dust explosion, spills and medical evacuations; (vi) resources required; (vii) physically climate risks associated to heatwaves and flooding; and (viii) drills, monitoring, maintenance and inspection of the emergency equipment, reporting and performance assessment (ESAP#4).
Monitoring and Review. Monitoring requirements within the company are managed under the HSE performance monitoring procedure, and the internal audit procedure. The company’s monitoring of ongoing construction actives as detailed in the HSE plan involves regular site inspections and audits conducted weekly by QHSE officers. Monitoring and tracking of waste is also reported in the HSE annual report. Non-compliances are raised for any breaches identified during the inspections and are investigated and discussed at fortnightly meetings between the construction contractors and AFISA.
As part of the PS1-compliant ESMS (ref. ESAP#1), AFISA will develop an E&S monitoring/reporting procedure which will specify KPIs, OHS leading and lagging indicators (incident records, near miss, hazard reporting and other workplace monitoring data), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and food safety.
PS2: Labor and Working Conditions
Human Resources Policies. AFISA currently employs 300 staff in its existing operations and construction activities, of which 56 are women. This results in a male-to-female ratio of approximately 81 % :19 %. This IFC investment is expected to create some 278 additional direct jobs.
AFISA has developed several policies and procedures in relation to their HR management which complies with local labor code and adopts the food processing sector CBA that sets out comprehensive terms of employment, transparency in rights and obligations, and clear compensation structures. AFISA’s HR process is enforced through the Internal Regulation, Code of Conduct, and Employee handbook accessible to all staff. The company prioritizes internal promotions and conducts performance evaluations to inform compensation reviews. Additionally, vacancies are advertised both internally and within the local community to ensure a fair and inclusive recruitment process. There has been no retrenchment and none is planned. However, TransAfrique Construction, a sister company to AFISA has recruited a construction workforce to facilitate the ongoing development of the flour mill and grain terminal while AFISIA continues to utilize leased mills, despite the potential unpredictability of lease breaches.
As part of this IFC investment, AFISA will update its HR procedures manual to a PS2-compliant HR Manual for its employees and contractors as a management tool for its workforce with clear HR policies and procedures including: (i) retrenchment policy; (ii) procedures for allowing anonymous complaints; and (iii) provisions on subcontracted and supply chain workers (ESAP #5).
Working Conditions and Terms of Employment. AFISA’s labor and working conditions reflect the provisions of the Cameroon Labor Code. Each employee has a written contract which complies with the requirements of the sector wide CBA which outlines the terms and conditions of employment, termination procedures, end-of-work contracts payment calculations and overall provides a structured approach to employment relations for the food processing sector in Cameroon. This CBA is reviewed every six months by the labor inspectorate.
AFISA’s HR process covers key aspects of labor and working conditions, including recruitment, equal opportunity, onboarding, working hours, leave, training, resignation and mandate strict adherence to the Internal Regulations and Employee Code of Conduct. The Company HR procedure manual includes zero tolerance to sexual exploitation and harassment. AFISA operates six-days a week, with workers required to work 8-hours per day, with a one-hour lunch break. The mill operates on 3 shifts of 8 hours each. Where work hours go beyond the stipulated 8-hours but within limits set by the national labor law, overtime is paid at the appropriate rate as stipulated by statutory requirements. Worker remuneration is comprised of a basic salary and various other allowances. In addition, AFISA has implemented various incentives including performance-based bonuses, seasonal support to staff and also provides workers with social insurance, meal subsidies, communication allowances, and transport services.
Workers’ Organizations. AFISA respects the rights of workers to join or form unions or worker’s associations of their choosing. Currently, the company supports employee unionization efforts with 51 out of the 300 employees being members of the union (SYNATIAC or Syndicat National des Travailleurs des Industries Alimentaires du Cameroun). Union dues are deducted monthly, and membership cards are issued to new members and the AFISA’s HR department engages with union representatives regularly. The dockers or day workers organised under the port authority and responsible for loading/unloading and packing at the warehouses belong to a separate union that regulates dockers activities at the port of Douala.
Grievance Mechanism. AFISA has established a grievance redress mechanism (GRM) for its employees which allows workers to voice their concerns and complaints either directly to the HR or through the union representatives to the company management. However, there is no grievance committee, no formal grievance registers and suggestion boxes are not available at all operating sites. As part of this IFC investment, AFISA will formalize its grievance mechanism for all workers, including third-party workers, to address; (i) roles, responsibilities, action timelines and a system to log, track and report grievances; (ii) submission of anonymous grievances and specific channels for gender-based violence and sexual harassment (GBVSH) complaints and (iii) employee awareness of the GRM through inductions, notice boards and online platforms, with specialized training for staff handling GBVSH complaints as per the requirements of IFC PS2 (ESAP #6).
Protecting the Workforce. As per the company’s HR procedure manual, AFISA does not support any form of child or forced labor and does not employ anyone under 18 years of age including interns. Interns are provided an internship agreement and adequate safety training before being granted access to the worksite. Subcontractor employees undergo medical fitness checks, adequate training and the company also ensures that subcontractors provide adequate protective equipment to its workforce and pay their employees regularly.
Occupational Health and Safety. AFISA prioritizes OHS through its safety management system which includes regular risk assessments and monitoring of safety protocols, maintaining of incident records and adherence to a structured approach of incident investigation and resolution. Also, AFISA has adopted a Personal Protective Equipment (PPE) policy defining the company’s minimum PPE requirements and enforcing it at site level. All personnel undergo safety inductions upon mobilization and job specific trainings, followed by general weekly safety meetings and specific daily toolbox talks.
The existing flour mill, Silos storage and new flour mill construction sites features multiple emergency points, security posts, safety personnel who oversee the operations and sanitary facilities segregated by gender, ensuring a respectful and hygienic work environment. Workers are required to wear appropriate PPE at all times and billboards stipulating the minimum safety requirements are erected at the entrance of each site. The company engages in continuous improvement through tracking of its near misses and regular health and safety audits are conducted by AFISA’s QHSE department. A safe system of work is used to ensure risk assessments are completed and permits issued before any works at height, confined space entry and working on energy systems is undertaken. Since the beginning of the silos storage and flour mill construction, the project has recorded two minor incidents related to the workforce and zero fatality. AFISA currently has a lost time injury frequency rate (LTIFR) of zero.
Workers Engaged by Third Parties. AFISA utilizes a limited number of third-party service providers including security agency and warehouse management. The warehouse management at the port relies primarily on manual labor, with port dockers utilized in ship offloading, packing, stacking, and storage of goods. These dockers undergo comprehensive training to ensure efficiency and safety. One shipment employs up to 80 dockers for a period of one week. Also, AFISA implements a contractor management procedure that requires the selection, evaluation, management, and monitoring of third-party service providers and requires each contractor to have a QHSE supervisor as well as monitor and report on its HSE practices and performance. AFISA will formalize the E&S requirement for it service providers in its ESMS manual as per ESAP #1 and as per ESAP #6 will extend it grievance mechanism to cover third party workers.
Supply Chain. In 2024, AFISA imported 200,000 tons of wheat from Lithuania, Romania, Canada, France, Latvia and Baltic Sea area, 28,000 tons of rice from India and Thailand, and 24,000 tons of sugar from Brazil and India. AFISA sources its wheat through international bulk traders. The company’s supply chain management process includes a focus on efficient, transparent, and ethical procurement and distribution of its products. The supplier selection and evaluation process focus on quality, reliability, and ethical standards, conducting evaluations including site visits, financial assessments, and compliance checks with international standards. Wheat suppliers are required to provide phytosanitary certificates and fumigation reports and should be exporting from areas free of risks of forest conversion or child labor. The main wheat supplier used by AFISA is a IFC client with a currently satisfactory E&S performance rating.
A Chain of Custody (CoC) system is utilized to track products from origin to destination and the shipments must obtain a Certificate of Origin verified by the authorized port inspection agency before custom clearance. Detailed records of all transactions, including supplier compliance documentation, are maintained. However, AFISA’s supply chain process does not include traceability audit requirements. As part of the ESMS manual (ESAP #1), AFISA will formalize primary supply chain traceability audit requirement as part of its supplier code of conduct.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. AFISA currently utilizes electricity sourced from the national grid for all its operational assets. The company makes use of back up diesel generators where portable power is needed or during power outage. In 2024, AFISA consumed an estimated 194,212 liters of diesel and 8,080,461 kilowatt hours of energy from the national grid. It is estimated that AFISA’s greenhouse gas (GHG) emissions from the use of grid electricity and diesel for backup generators will remain below 25,000 tons of CO2 equivalent per annum after the IFC investment.
Noise and Air Emission: AFISA has identified and included noise and air emissions as risks associated with its operations but noise monitoring is not completed at pre-selected receptors including within its facilities and at the perimeter of its facilities and at the closest sensitive receptors to determine noise and dust impact on its workforce and the neighboring communities, if any. Millers are provided with suitable hearing protection given the exposure time. As part of this IFC investment, AFISA will include audiometry test as part of the annual health check-up of its milling staff and will include noise monitoring at its facilities and sensitive receptors in ites E&S monitoring and reporting requirement (ref. ESAP #1). Also, AFISA will monior ambient air quality at plant boundaries and the surrounding and analyse for any spike in pollutant levels which may be attributed to its operations including applicable legal requirements for particulate matter; PM 2.5 and PM10.
Water Consumption. Flour milling is a dry process. AFISA sources its water from the national water corporation and uses water predominantly for daily domestic use and in temporary construction activities. As per ESAP #1, AFISA will include water monitoring in the monitoring and reporting procedure under its ESMS. This will include monthly water consumption, as well as the identification, where feasible, of viable water conservation measures within its operations.
Waste Management. AFISA has developed and implemented a waste management procedure that details the production, handling, storage, transport, and disposal of all waste streams generated in its operations. The procedure adopts the waste management hierarchy with the implementation and monitoring responsibility assigned to the QHSE department. AFISA currently segregates waste by type and store the waste in dedicated areas and where feasible, AFISA prioritize the reuse and / or recycling of solid wastes such as plastic, paper and wood while scrap metal is sold to scrap metal merchants. The company uses authorized waste management service providers in managing some of its waste streams.
Hazardous Materials Management. AFISA’s operations include limited hazardous materials such as hydraulic oil and diesel. Most of the hydraulic oil is managed by the maintenance service provider. Also, temporary construction activities use oil base paints procured in tins and stored in separate containers The company ensures that such materials are stored in ventilated places with Materials Safety Data Sheets (MSDS) displayed.
As per the waste management process outlined in the HSE plan, hazardous wastes such as oily rags, paint residues and empty paint containers generated by AFISA are labelled and stored in controlled areas and disposed through accredited service providers. Waste tracking forms for such disposal are not maintained however the full records are available at site. As part of the ESMP development (ref ESAP #2) AFISA will include in its waste process a secured waste management area either at the silos storage or new flour mill for accumulating and managing waste from its different sites and will ensure a waste tracking and recording system (ref. ESAP #1) from cradle to grave is implemented for all its operational assets.
Pest Control. AFISA ensures pest control is implemented at its flour mills. At the Douala port area, general fumigation and pest control are carried out as part of the port operations organized by the port authority. For AFISA’s silos storage and flour mills, this service is subcontracted to accredited service providers. The QHSE manager oversees pest control activities ensuring that the frequency of the fumigation is respected by the service providers. The company’s fumigation procedure requires it to only use the services of providers authorized by the Ministry of Agriculture thus ensuring that only products homologated by the ministry of agriculture are used. AFISA ensures that material safety datasheets are obtained, verified and mitigation measures implemented during pest control operations. Waste generated from the fumigation activity is retained and managed by the service providers.
PS4: Community Health, Safety and Security
Food Safety. AFISA's quality manager oversees food safety inspections, managing the implementation of processes and laboratory testing at the flour mills. Each mill has a lab with dedicated technicians and modern equipment. A baker in each lab tests dough quality by making different bread and doughnut products daily. The annual conformity certifications audit conducted by ANOR is based on AFISA food safety program. However, the food safety processes are not entirely documented. As per ESAP#1, the company will update food safety protocols for implementation across its flour mills and ensure laboratory technicians are regularly sensitized on use of new equipment.
Community Health and Safety. AFISA’s assets at the Douala port are located on three parcels with a total surface area of 55,000 m2 within the perimeter fence. The other leased mills are located in semi-industrial area settings. The flour mill operates 24 hours but impacts of noise to third parties are minimal owing to the industrial nature of the port area and industrial areas with the leased mills. There are no significant additional impacts to the health, safety, and security of the local community expected as a result of the IFC investment.
Traffic Safety. AFISA relies on TransAfrque Logistics, its sister company for its transport operations. This logistics entity has a transport management system with driver safety guideline describing driver behavior and best practices. The fleet is managed and has in-vehicle monitoring systems (IVMS) that provide real time information on driver location and driving behavior. No fatalities have been recorded for AFISA related transport operations. As part of the ESMP development (ref. ESAP #2) AFISA will assess transport risks associated with transferring wheat from the silos storage facility to the flour mills and propose adequate mitigation measures including driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards as well as alcohol and drug testing requirements.
Life and Fire Safety. AFISA incorporates life and fire safety (L&FS) requirements in the designs of the Silos storage facility and new flour mill. The silos design follows international standards to prevent dust explosion and makes provision for life and fire safety measures like reel, hoses, water hydrants and water reservoirs. As per ESAP #4, AFISA will include L&FS measures in its EPRP and communicate emergency response protocols with other operators within the Douala port and other industrial zones where it operates mills including the municipal fire department as well as community within the area of influence focusing on protection and safe evacuation of personnel and stakeholders.
Security Personnel. AFISA utilizes a third-party service provider for security guards. The Company employs a total of 20 unarmed guards covering two shifts and guarding its assets while the overall access control to the port area is under the responsibility of the Port Authority. AFISA will include in the ESMS (ref. ESAP #1) and ESMP (ref. ESAP #2) its approach to security risk assessments, hiring, training, appropriate conduct of security workers toward workers and community members, equipping, and monitoring of security guards and their activities. Also, AFISA will extend its GRM (ref. ESAP #6) to cover third party security guards.
