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 and Social Policies and Management Systems. SONOCO Group has established a corporate QHSE policy and Environmental and Social Management System (ESMS) that is aligned with the requirements of IFC Performance Standard 1 and integrated with internationally recognized certifications, including ISO 14001 (Environmental Management) and ISO 9001 (Quality Management), forming a comprehensive Integrated Management System (IMS).
In 2025, SONOCO Group further strengthened its commitment to sustainability and food safety by achieving FSSC 22000 certification for its milling operations.
The current ESMS framework is applied across all SONOCO subsidiaries, including:
• Flour milling operations (LMA).
• Seasoning cube production unit (AFI producing Nestle products)
• Water and soft drink manufacturing unit (CBA)
• Metal shell production unit (Metal Import)
• Construction division (SOHA)
As part of the FERMAV new investment initiative, SONOCO will develop and implement a site-specific ESMS tailored to the integrated poultry farm, which encompasses both the slaughterhouse and the feed mill. This dedicated ESMS will be fully compliant with IFC Performance Standard 1 and will incorporate specialized protocols such as heat stress management and other relevant environmental and social (E&S) plans (ESAP#1).
Identification of E&S Risks and Impacts. SONOCO identified E&S risks and impacts associated with the construction and the operational phase in line with the local regulation and international standard and site specific ESIAs were developed for the feeding mill, the agricultural-avicultural farm and the slaughterhouse. These ESIAs are aligned with IFC Performance Standards. All environment permits have been granted in September 2024.
E&S Management Programs. The E&S risk assessment as defined in the ESIAs include framework E&S management plans (ESMPs) for the proposed feeding mill, slaughterhouse and avicultural farm, covering both the construction and operation phases including E&S monitoring and review. The ESMPs outlines key operational risks and corresponding management and monitoring measures including air emissions, water use and effluent management, solid waste, and noise. It defines roles and responsibilities, applicable legal requirements, and includes provisions for emergency preparedness and response, as well as staff training. As per ref. ESAP#1, SONOCO will develop and implement each E&S management program to cover new E&S monitoring parameters reflecting the integrated poultry farm including the slaughterhouse and the feeding mill activity.
Organizational Capacity / Competency. SONOCO Group has a corporate E&S manager who reports directly to the Chief Executive Officer (CEO). Each subsidiary has E&S officers assisted by QHSE supervisors and agents. The E&S officer rolls out the corporate E&S program in each unit, and QHSE supervisors and agents monitor the day-to-day implementation. To meet the E&S capacity of IFC investment (avicultural farm, slaughterhouse and feeding mill), SONOCO is planning to hire a total of sixteen (16) QHSE agents and supervisors. As per ESAP #2, SONOCO Group will hire one E&S officer for each unit (one for feeding mill and one for the integrated poultry farm) to operationalize the ESMS and implement site specific ESMP’s and ESAP’s.
E&S Training Plan. SONOCO Group has a corporate E&S training plan that is implemented in each subsidiary. The E&S training is delivered to its staff and contracted/temporary workers as part of the employment onboarding process. SONOCO Group has a QHSE training program that covers themes related to health and security at work, evaluation and risk management, defensive driving, first aid kit, working at height, electricity security. As per ref. ESAP #1, the company will develop site specific E&S training plans to integrate risks related to the integrated poultry farm including the slaughterhouse and feeding mill.
Emergency Preparedness and Response. SONOCO Group has a corporate EPRP Plan in line with IFC Performance Standards covering aspect of risks identification, communication, roles and responsibilities and training and drill. As per ref. ESAP #1, SONOCO will develop and implement a site-specific emergency preparedness and response plan for its new FERMAV integrated poultry farm including the slaughterhouse and feed mill in collaboration with local authorities for support and disclosure to local communities. The plan will identify potential emergency situations and accidents that could occur at the different areas of the project; potential impact on the environment and assign responsibilities and related actions. Other key measures to prevent or mitigate accidents, fire outbreaks, electrical shocks, dust explosion, spillage and pollution prevention, management of events related to refrigerants, and other potential hazards like climate risk, biohazard risks and contamination of finished products.
Monitoring and Review. As per ref. ESAP#1, SONOCO will develop site specific E&S monitoring/reporting procedure which will specify Key Performance Indicators (KPIs), including occupational health and safety (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 related to the new business activities.
PS2: Labor and Working Conditions
At the time of the appraisal, SONOCO Group workforce at the group level comprised 551 employees with permanent contracts across all the subsidiaries, and 2000 temporary workers hired via third party labor agents. An additional 400-600 permanent workers will be hired based on the forecast (integrated poultry houses including slaughterhouses and farms). Women represent 13% of current workplace mostly in HR, finance and technical tasks related to quality control in the production line.
For the proposed feed mill, the company intends to recruit around 100 additional contracted staff for the construction phase and 9 for operation phase. The construction phase will last around 7-9 months for the feed mill and 6 months for the integrated farm.
Human Resources Policies and Procedures. SONOCO Group has a HR manual in place (internal regulation), its employees manual, and a code of conduct which are all aligned with Guinean labor laws. They cover employment terms and conditions, workers’ responsibilities and define the processes related to discipline and dismissals. To align with IFC PS2, the company will enhance its HR manual to include standalone policies and procedures on non-discrimination, equal opportunity, prohibition of harassment including sexual harassment, freedom of association, prohibition of child and forced labor, Gender Based Violence and overtime. The Human Resources Manual will be communicated to the current employees, including temporary workers and at the time of hiring. Training on how to report any situation of harassment, discrimination, violation of law, and misconduct through the worker’s grievance mechanism will be conducted. Constructions will be executed by SOHA, the construction subsidiary of the group. The group human resources management principles will also apply to SOHA (ESAP#3).
Working Conditions and Terms of Employment. Standard working hours are from 09:00 to 17:00hrs, Monday through Friday, depending on departments and position, with some employees required to work on Saturday mornings. For shift workers (there are two or three shifts depending on departments) and the shift is assigned to workers on a rotation basis. Night shifts are paid extra as per legislation, and workers have 2.5 days of leave per month worked. The same conditions apply to third-party workers.
Grievance Mechanism. SONOCO Group has developed a dedicated grievance mechanism channel for both employees and external stakeholders. Currently, the reporting options are limited to telephone and email. However, the scope of the mechanism does not include complaints related to sexual harassment or gender-based violence. Complaints are managed directly by the HR manager. The company will upgrade its existing corporate grievance mechanism with separate channels for anonymous, internal and external grievances. The mechanism will indicate (i) available channels to submit grievances (including separate channels for grievances related to gender-based violence and 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 in accordance with IFC PS2 requirements (ESAP#4). The mechanism will also include a differentiated procedure and management of GBV and sexual harassment related grievances. The company will sensitize its workforce and disseminate information on online platforms and notice boards with additional specialised training provided to staff managing GBV and sexual harassment grievances.
For the proposed investment and as per ref. ESAP#1, site specific grievance mechanism will be integrated into the site-specific ESMS based on the upgraded corporate grievance mechanism.
Workers Engaged by Third Parties. SONOCO Group has signed contracts with several labor agencies that provide workers to support production and logistics operations. Social contributions are mandatory for all workers including third-party workers. SONOCO establishes wages and benefits for the workers engaged by the labor agencies and monitors that wages and benefits are paid according to the company’s requirements and labor laws. A monthly verification is done by the company and confirmed by official payment slips delivered to workers. The two main labor agencies are present onsite to manage the workforce. SOHA will engage contracted service providers to recruit contractors for building the feed mill and slaughterhouse.
Occupational Health and Safety. SONOCO Group has a QHSE policy that covers OHS risks mainly mechanical and health hazards, fire and explosion. OHS plans are implemented and aligned with the group commitment. SONOCO has defined its OHS commitments and requirements as part of its HR manual, which includes proper use of PPE tailored to specific risks, including exposure to noise, cuts, and electrical work, annual medical check-ups including audiometry tests, training requirement for fire management and accident investigations. SONOCO has an OHS committee in place and regular meetings are held. As per ref. ESAP#1, FERMAV will develop and implement site specific EHS management plans to manage OHS risk related to the construction and operation of the integrated poultry farm including the slaughterhouse and the feed mill. The plan will also cover heat stress management protocols covering both direct employees and sub-contractors.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and GHG emissions: The project’s main energy sources are grid electricity and diesel for small scale steam generation and backup generators. The feed mill will rely on the national grid for its electricity with a 500kVA standby generator to be installed for use in the event of power outage. The feed mill will also use diesel to fuel a 5kw boiler that will be used to generate steam for drying the products. The integrated poultry farm will also rely on the national grid for its activities with 6 generators for the different facilities installed for backup. The Project emissions are estimated to remain below 25,000 tons of carbon equivalent per year. As part of their ESMS’s (Ref. ESAP#1), FERMAV will develop and implement a resource efficiency management plan to monitor, manage, and establish target for resource efficiency for the integrated poultry farm including the slaughterhouse and the feeding mill.
Water.: For the feed mill, the process being mainly a dry process, a limited amount of water is expected to be used in the process, and no wastewater will be generated except for sanitary wastewater. Water will be supplied by Societe des Eaux de Guinee (SEG) through the industrial zone water network. The integrated poultry farm, especially the slaughterhouse house, is heavily dependent on water. Water will also be supplied by SEG for the slaughterhouse, and the other facilities will be supplied by the existing boreholes on the sites. FERMAV will develop water management plan and procedures to be included in the site specific ESMS (ref. ESAP#1). Stormwater and surface runoff will be directed through drainage ditches and discharged into the natural spillway. Domestic wastewater will be collected in septic tanks and removed by a licensed operator.
Wastewater. The slaughterhouse, currently under construction, will generate significant wastewater volumes and will be equipped with a wastewater treatment plant. Following treatment, wastewater will be reused for irrigation on company agricultural land. According to ESAP #5, the client will assess soil, groundwater, and surface water in areas planned for effluent use from the slaughterhouse station. Based on the site-specific ESMS (ref. ESAP #1), the Company will follow all recommended actions to comply with national laws and IFC EHS guidelines for poultry processing, ensuring the water is safe for agriculture.
The process of the feeding mill is dry with no waster discharged. At the feeding mill, stormwater and surface runoff will be channeled through drainage ditches within the industrial zone. Domestic wastewater will be collected in septic tanks and removed by a licensed operator.
Noise: Due to the nature of the process, the feed mill is expected to generate a high level of noise. However, the impact on neighboring communities will be limited as it is located in an industrial zone with the nearest receptors located more than one kilometer from the site boundary. Additionally, SONOCO will ensure low noise rating equipment is procured for the milling process.
Air monitoring. The major air emissions from the feed mill will be mainly particulate matter. To manage emissions, the plant will be equipped with dust filters. Additionally, regular ambient air quality monitoring will be undertaken as part of its E&S monitoring program.
At the slaughterhouse, the main air emission will be the broilers used for the steam as part of the cooking and cleaning process. For the integrated poultry farm, the Company will develop an odor management program that will aim at reducing the odor nuisances out of their sites. The plan will include preventive measures but will also deal with potential complaints from neighboring receptors.
Solid Waste and Hazardous waste management. Typical wastes generated during construction for each side includes concrete and rubble. Operational waste from the feed mill includes packaging material, plastics, cans, paper, mill waste, food remnant, while hazardous waste will be mainly used oil. Both waste streams will be collected and stored in a dedicated and locked storage area. The waste will be collected on site temporarily and carted away by an authorised waste management company.
Biological waste management. Typical poultry farm waste consists of manure, bedding (litter), dead birds, feed waste, feathers, and hatchery waste. The waste will be processed in a rendering unit (20 tons of waste pe day) with high temperature steam and packed into 50 kg bags to be exported to Morocco (or elsewhere depending on demand) in special tanks by boat, where it’s used in agriculture and complies with local regulations. As per ESAP#6, the company will construct a state-of-art storage ensuring impervious surface, structure integrity, dry stacking to avoid any soil and water contamination.
Hazardous Materials management. FERMAV will have fuel storage with a capacity of 10,000 litres at the feed mill site, 5,000 liters at the slaughterhouse, and 1.500 liters at hatchery and broilers houses. The fuel tank will be installed above the ground and equipped with a secondary containment and leak tested prior to commissioning.
Potentially hazardous substances used in poultry production activities may include pesticides, disinfecting agents, minerals, antibiotic, vitamins, vaccines and hormonal products.
As part of the IFC investment, the Company will implement proper hazardous material storage protocols including storage of hazardous materials including fire prevention and ensure that adequate spill kits and firefighting equipment are deployed and readily available at appropriate locations (ESAP#7).
Refrigerants gases. Slaughterhouses utilize a range of refrigerated facilities, including chilling rooms, meat cutting and deboning rooms, blast freezers, long-term storage warehouses, and refrigerated trucks for product distribution. Under their Environmental and Social Management System (ESMS) (Ref. ESAP#1), the company will implement a gases management plan, focusing on engineering controls to prevent leakage and manage potential releases. The Emergency Response Plan will also cover procedures related to the management of gases during transportation.
PS4: Community Health, Safety and Security
Life and Fire Safety (LFS). Control measures for the prevention and response to dust explosions are detailed in the ESIA such as the use of intrinsically safe equipment, prevention of static electricity and sparks, temperature monitoring in silos, hot work permits, prohibition of smoking and emergency response equipment. As per ESAP #8, FERMAV will recruit a qualified independent LFS consultant to review the LFS design of the feed mill and refrigerated areas including compliance with explosion-proof requirements (e.g., ATEX regulations and certification) and conduct a post commissioning audit of the LFS system prior to start of operation. The new slaughterhouse, feed mill and processing areas will be reviewed under this task, in terms of adequate of means of egress, fire alarm and fire suppression systems. Also, ammonia detection systems in refrigeration machine rooms, and areas served by the ammonia systems.
Traffic Safety. The feed mill will be constructed in an old industrial zone located outside of Conakry, with relatively low traffic in that area. The plant does not expect to generate a high level of traffic as raw material will be brought in only twice per month, and finished products will be supplied to their chicken farms and potentials retailers via large trucks, hence reducing the need for large number of trucks.
For the poultry activities, the project is heavily dependent on traffic. The intrants will be transported to Kindia, and the chicken will be distributed nationally via refrigerated trucks. Manure will also be transported to the port of Conakry by truck. The company relies on its own fleet for its operation. To meet the anticipated transportation need for Fermav, SONOCO will purchase 6 trucks with 2 chillers. As part of its ESMS, the company will develop and implement a traffic management plan applicable to its transport fleet, its suppliers and distributors (ref. ESAP#1). The plan will address 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. Also, SONOCO will provide a detailed induction session on the E&S provisions of its Code of Conduct, including zero tolerance to gender-based violence and sexual exploitation, abuse and harassment for its own truck drivers and transport service providers.
Security Personnel. All the sites are fenced, and the company employs unarmed security personnel for access control through a third-party security agency. The Company will establish necessary measures for background checks and training requirements for security personnel as part of its ESMS (ref. ESAP #1), as well as expand the workers’ grievance management to cover its third-party security agents (ref. ESAP #4).
Food safety. For the poultry operations, including the slaughterhouse, the Company will certify its processing facilities in accordance with an internationally recognized food safety standard consistent with the principle of Hazard Analysis and Critical Control Point (HACCP) system. In addition, the HACCP program will specifically address key poultry- processing risks, including potential contamination of pathogens (e.g. salmonella, campylobacter, and listeria monocytogenes); drug and chemical residues; and metal fragments from processing machinery ESAP#9.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resource
Biodiversity Conservation: The integrated poultry farm sites are located within modified and degraded habitats, previously affected by cultivation, forest clearance, and other land use activities. During construction and operation of these sites, the project will minimize its potential impacts on biodiversity through the development of ad hoc measures in the site-specific ESMPs.
Supply Chain Risk Assessment and Management: The operation will need to import feed from Ivory Coast until the feed mill is operational. IFC has not been provided with information on where the raw materials that are used to produce this feed are sourced. Once the SONOCO feed mill is operational, the raw materials that will be sourced to produce feed will be wheat, maize, soya and peanuts. While sourcing plans have not yet been confirmed since the feed mill has not yet been constructed, it is anticipated that wheat will be sourced from Germany via a trader, soya will be sourced from South America with potential sourcing locations including Argentina and/or Uruguay; and maize and groundnuts will be acquired in the local market. To ensure that those raw materials – including soybeans and maize for feed production – are not sourced from areas at significant risk of natural/critical habitat, SONOCO will develop a Responsible Sourcing Policy and an associated supply management system. Prior to any sourcing, SONOCO will ensure that the third-party supplier will abide to the Policy and mitigations will be identified in the supply chain risk management (ESAP#10).
Sustainable management of living natural resources: The integrated poultry farm will also be required to achieve a credible certification for sustainable management practices over the course of the investment (ESAP#11).
