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
CBI has established an Environmental and Social (E&S) Policy dated 2021 detailing its commitment to comply with applicable legal and regulatory requirements, efficient use of energy, and the training and equal opportunities for all employees. The company has also developed an OHS policy that is undated. According to the project’s fourth EHSS Monitoring Report (July 2024) by external consultants, CBI has developed a preliminary ESMS, E&S/OHS policies for the on-going operations and adopted EHS policies and standards from its new shareholder (Heidelberg Materials). As part of ESAP #1, CBI will update the ESMS to reflect the increased complexity of operational risks at the expanded plant and clay extraction quarry. The ESMS will comply with the requirements of IFC Performance Standards 1, incorporate shareholder standards and will cover the following elements: (i) updated EHS policies; (ii) identification of risks and impacts; (iii) management programs such as the updated contractor management plan, comprehensive incident and accident investigation procedures, quarry management plan (including close-out audit on the Land Acquisition and Livelihood Restoration Plan (LALRP) covering the land assets, community consensus and cultural heritage), emissions monitoring plan, traffic management plan; (iv) organizational capacity and competency to include quarry operations; (v) updated emergency preparedness and response; (vi) stakeholder engagement (SEP) and external grievance mechanism, and (vii) monitoring and review. CBI plans to get ISO certification once commissioning commences, which will be implemented to manage operations.
Identification of Risks and Impacts & Management Programs
The company keeps a legal register for its permits and licenses at the plant in Tema. CBI has completed a project environmental and social impact assessment (ESIA) for the construction of the plant in Tema and the quarry in Torgome aligned with the requirements of the Environment Protection Agency (EPA) Act of Ghana. The company was subsequently granted environmental approval from the EPA in 2022 for the plant in Tema and in 2024 for the quarry in Torgome. The ESIA identifies key project related impacts, including those related to air quality, noise, land use, hydrology, waste management, and socioeconomic impacts. The ESIA also includes an environmental management plan (EMP) that has been developed to manage residual impacts and ensure compliance with regulatory requirements during construction and operation. Management programs include weekly inspections, compliance audits by third party external consultants, awareness training, air and noise quality monitoring, with quarterly and annual reports.
E&S Organization Capacity
CBI has a dedicated environmental, social sustainability and compliance manager who is responsible for overseeing the environmental and social compliance for the company. CBI also has a health and safety (H&S) Manager who oversees implementation of health and safety management programs on site. The H&S manager is supported by two safety supervisors and a safety officer at the cement plant. The quarry manager is trained as the H&S Manager on the Togorme quarry site and is supported by the H&S manager from the plant. As part of ESAP #2, CBI will recruit a suitably qualified and competent Environmental & Social officer to support the H&S Manager of the quarry to implement the conditions on the schedule of environmental permit related to the environmental management, monitoring and reporting required by the regulatory authority, livelihood restoration plans, community engagement plans, quarry rehabilitation plan and any tree nurseries to be established on site for rehabilitation.
CBI has a comprehensive training schedule in place which covers induction, medical emergency response, Gas HAZOP, fire safety, lock-out tag out procedures, first aid, risk assessment, driving rules, basic safety and quality control at the cement production plant and the quarry, production processes, maintenance, product and quality, software, administration and sales. Staff training is generally led and planned by HR. The Health and Safety team are responsible for leading general HSE training covering awareness and safety which are held monthly and sometimes weekly.
Emergency Preparedness and Response
CBI’s plant in Tema, is located in a predominantly industrial area. Life and fire safety measures have been integrated in the design of the cement plant firefighting facilities, fire detection and warning devices, and evacuation facilities. CBI has received its fire permit which is pending inspection upon commissioning of the plant. The Emergency Preparedness and Response Plan (EPRP) described in the EMP for the cement plant details procedures for occupational health and safety (OHS) related emergencies, environmental related emergencies covering roles and responsibilities, fire outbreak, and equipment/machine failure amongst many others. CBI has also developed a health, safety and environment emergency response plan (ERP) for the clay quarry in Torgome. The plan covers most of the aspects in the EMP as well as medical emergencies, pit wall and ground collapse, and security. As part of ESAP#3, CBI will review and update the EPRP for both the cement plant and the clay quarry to incorporate climate risks such as heat stress management, hydration protocols for workers, flooding risks and early warning mechanisms in compliance with IFC PS1 requirements. All workers will be trained on the revised EPRPs and the procedures will be periodically reviewed and updated as new risks are identified.
Monitoring and Review
The EMPs require CBI to compile monitoring reports which are submitted to the EPA of Ghana. These reports cover key performance indicators (KPIs) such as ambient air and noise monitoring, solid waste, liquid waste, hazardous waste, and electricity and water usage. The KPIs are reported on a monthly basis to the management team. As part of ESAP #4, the company will update the EHS monitoring procedure to include KPIs during operations such as OHS leading/lagging indicators (Lost Time Incident Frequency Rate (LTIFR), fatalities) and gender equality (percentage of woman employees), incident report, SEP, livelihood restoration programs as well as reporting conditions in the EPA Quarry Permit.
PS2: Labor and Working Conditions
CBI Ghana currently has 154 permanent staff and 114 employes who are contracted employees hired through a third-party agent. Third party staff include 74 employees working in production, 16 working in sales and 24 working on general admin (security and cleaning). Of the 154 staff, there are 25 females and 129 males. At commissioning the company expects to hire an additional 21 employees with a resultant headcount of 175 employees on site.
Human Resource Policies & Procedures
The Human Resources (HR) department is responsible for overseeing recruitment, employee development, workplace policies, and compliance to align the workforce with organizational objectives. As part of its HR management, CBI Ghana implements a Personnel Policy covering the code of business conduct, employment equity, compensation, leave, medical benefits, disciplinary procedures, grievance procedures, performance appraisal, and retirement amongst other topics. The policy is accompanied by a Personnel Policy addendum that details the following policies: Gender-based violence and harassment (GBVH), child labor, forced labor, grievance mechanism, freedom of association, whistleblowing, Covid-19, and the HR channel of communication. Each policy includes a policy statement and guidelines and procedures for implementation. In line with the requirements of IFC PS2, CBI will review the HR Personnel Policy and policy addendum to incorporate explicit references to non-discrimination and anonymous reporting in the grievance mechanism (ESAP #5). These updated HR policies and procedures will be communicated to workers and contractors through various channels including induction, regular training, and refreshers.
Working Conditions and Terms of Employment
CBI provides written contracts to all employees and contractors. The company operates on four shifts and does allow for limited overtime in compliance with the local labour laws. Employees are paid above the Ghanaian minimum wage as established by the labor act and are eligible for medical benefits. The labor office conducts annual audits covering working conditions as well as internal audits on the third-party contractors’ payments. The results of the statutory labor audits will be included in the Annual Monitoring Report (AMR) to IFC. The company has also conducted a tax health audit performed by a third-party on its payroll.
Worker Organizations
The company does not prohibit the workers’ right to freedom of association and right to form and join workers organizations, however none of the workers are unionized. CBI has established the Employee Voice Council (EVoC) which is an internal staff association which has its terms of reference. The company meets with the council every quarter. The council is made of 10 members including two female employees. Third-Party workers are not represented by EVoC Topics covered in the meeting include medical benefits, loans, HR issues, and OHS issues.
Grievance Mechanism
CBI has an official mechanism in place to address internal and external grievances/complaints for employees and external stakeholders. The company has also developed an Employee Suggestion Policy which allows employees to contribute suggestions and feedback to the organization with the options using a suggestion box, a green QR code or a link to make the submission. The company maintains a grievance database for tracking and resolving all grievances. The procedure requires that an aggrieved person submit the complaint in writing or walk into his/her supervisor or HR and lodge a complaint. Suggestion/grievance boxes have also been provided at vantage locations to receive anonymous grievances. The grievance mechanism encompasses not only the internal workforce but also extends to encompass all third-party contractors associated with CBI.
Occupational Health and Safety
As noted under the ESMS section above, CBI has an Occupational Health and Safety (OHS) policy in place which is implemented via non-documented procedures for all employees and contracted staff at the plant. The policy describes the company’s commitment to prevent occupational illness and injury by providing safe workplaces and equipment, training employees on H&S issues, supervising and monitoring health and safety performance on sites. As part of the EHS management plan to be developed under the ESMS (ESAP #1), the company will develop and implement occupational health and safety procedures for plant operations. The OHS procedures will include existing OHS elements such as a construction safety plan, fall protection plan, PPE requirements, site safety induction procedures, incident register management procedure, site safety meeting minutes, and near misses and lost time injuries rate (LTIR) tracker, incident/accident investigation and reporting amongst others. As part of ESAP #6, CBI Ghana will develop and implement a noise management and monitoring plan within the workplace and at potentially sensitive receptors, once the LC3 plant is operational. The OHS procedures will be in line with country regulation and Occupational Health and Safety sections of the WBG EHS General Guidelines, Industry-Specific Impacts and Management section of the EHS guidelines for cement manufacturing, and IFC Performance Standard 2.
Third-Party Workers
The company makes use of third-party workers to provide driving, cleaning, security, and heavy-duty equipment operation. Third-party contractors are required to adhere to the Ghanaian Labor laws. In addition to reviewing contractors’ relevant permits, licenses, authorizations and agreements, the company will develop a Contractor Management Plan as part of its ESMS, to have oversight and manage its contractors. The management plan will also include a screening procedure, which requires contractors and sub-contractors to comply with the company’s code of conduct, the EMP, and management programs developed, as part of the ESMS (ESAP #1).
Supply Chain
As noted above, CBI currently sources clinker from Egypt, Turkey, Morocco, and Pakistan. Additional additives such as calcined clay are sourced locally. A supply chain assessment indicated the potential use of child labor for clinker production in Egypt. All suppliers and contractors are selected based on their technical and financial competitiveness, and credibility. They must comply with CBIs Code of Conduct, which emphasizes the importance of correct and transparent conduct in the performance of their activities. As part of the HR policy review (ESAP #7), the company will update the Supplier Code of Conduct to explicitly prohibits any form of child and/or forced labor and includes specific requirement in relation to OHS in accordance with the requirements of PS2, reporting requirements for suppliers, consequences of non-compliance with such requirements, and mechanisms through which requirements will be formalized and monitored.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
CBI Ghana utilizes energy from Enclave Power company, the electricity distribution company for Tema Free Zone. Gas is sourced from Ghana gas, and water from Ghana Water company Limited (GWCL). The average electricity consumed from the national grid was 1,894,479.29 kWh between July and September 2024. The average water consumption was reported as 2,127 m3 between July and September 2024. The company has two boreholes which have shifted the reliance of water from GWCL. The company monitors its resource consumption and records it through the monthly monitoring reports.
The company prioritizes resource efficiency through the promotion of energy efficiency through low fuel consumption, achieved by effective heat transfer and efficient heat recuperation. By utilizing the FLSmidth clay calciner system, the project will achieve significant reductions in energy consumption and CO2 emissions through advanced heat recovery and thermal efficiency measures.
Greenhouse Gas Emissions
Flash clay calcination is an advanced process that produces calcined clay with an emissions intensity of 125 kg CO2e per ton, offering a sustainable alternative to clinker, the most carbon-intensive component of cement with an emissions intensity of 856 kg CO2e per ton. By partially replacing clinker with calcined clay, the carbon intensity of the resulting cementitious material (Limestone Calcined Clay Cement or LC3) is reduced by 19%. The system’s energy-efficient design and use of heat-resistant materials further enhance its environmental benefits.
CBI Ghana consolidated its GHG emissions monitoring and reporting system to verify the actual carbon footprints of its operations. Scope 1 gas emissions resulting from generators and vehicles as well as Scope 2 emissions associated with the use of purchased electricity were estimated at 257,600 tons of carbon dioxide equivalent for 2023 (without the project scenario). The average absolute GHG emissions associated with the project over the period from 2026 to 2032 is estimated to be 354,590 tCO2e per year. This represents a reduction of 195,030 tCO2e per year compared to the baseline emissions for the same period.
Ambient Air Emissions
During construction, particulate matter was from civil works and movement of trucks, storage, transfer, and handling of raw materials. Gaseous emissions are expected from the calciner, diesel generator, and raw material. As part of the ESIA, air dispersion modelling was conducted, and results were benchmarked against Ghana Standards for Environmental and Health Protection. Emission rates for Sulphur Oxide (SO2), Nitrogen Oxide (NO2), Carbon Monoxide (CO) and particulate matter recorded in September 2024 were found to be in compliance with ambient and fence line air quality standards and were within recommended limits of the Environment section of the WBG EHS General guidelines. CBI will need to monitor and confirm that NO2 emissions from clay calciner are within WBG EHS guideline limits through continuous monitoring once the plant is operational. As part of ESAP #8, the company will develop an air emissions management and monitoring plan to be aligned with the WBG General EHS guidelines and the Industry-Specific Impacts and Management section WBG EHS guidelines for Cement and Lime manufacturing. The monitoring reports submitted indicated that noise pollution levels were within the WBG EHS guidelines. The plan should be aligned with the WBG General EHS guidelines and the WBG EHS guidelines for Cement and Lime manufacturing.
Water Management
CBI’s operational processes are largely dry and hence the company do not utilize significant quantities of water. Primary water consumption relates to general sanitary, office, and equipment cleaning. Water was initially sourced from the local water company and now the company is sourcing from an existing borehole as noted above. Water consumption at the plant is monitored monthly as part of the KPI reporting, The project may be exposed to climate risks such as extreme temperatures, intense precipitation leading to pluvial flooding, and severe short-term droughts.
Waste and hazardous waste Management
Waste generated by the project primarily includes solid waste such as wood, steel, paper, and other general waste. In 2024 22,315 kg were recorded. The company also generates small quantities of hazardous wastes such as waste oil, oily rags, and contaminated soil. The company currently utilizes an authorized third-party service provider for the disposal of waste. The cement manufacturing process is dry and only sanitary wastewater is generated from the offices. CBI Ghana has a septic tank on site which is regularly dislodged and disposed by a third-party contractor.
Quarry management and reclamation
The ESIA for the quarry in Torgome provided guidance for the reclamation and decommissioning of the site, as well as monitoring requirements for decommissioning. As indicated in #ESAP 1, CBI will prepare a Quarry Management and Reclamation Plan for the quarry in Torgome. This plan will include the final contouring of the quarry landscape once each segment is exhausted, five years rough utilization plans, and rolling yearly utilization and rehabilitation plans. The rehabilitation plan will include reapplication of top soil as appropriate and replanting with local endemic plant species. The quarry rehabilitation plan and conditions of permitting will be monitored in the annual monitoring report.
PS4: Community Health, Safety and Security
Traffic and Transportation
CBI has developed a Traffic and Transport Management Plan for the quarry that describes roles and responsibilities, transportation restrictions, guidelines on equipment, parking procedures, vehicle inspections, and driver code of conduct amongst other items. The company owns 5 trucks that it uses on the cement plant and will use a third-party service provider for the supply of 25 trucks that will transport the clay from the quarry to the plant in Tema. Each truck driver is accompanied by a support driver. As part of ESAP #9, CBI Ghana will develop a Transportation and Traffic Management Plan for the cement plant in Tema which should include, as a minimum, a route risk assessment, driver training (for both direct and contract workers), vehicle maintenance requirements, in-vehicle monitoring, and delivery requirements of clay. The company will need to consider associated traffic risks for delivery of completed product in the updated Transportation and Traffic Management Plan.
Security Personnel
CBI currently utilizes a third-party service provider for the provision of unarmed security guards. There are 4 security personnel stationed at the quarry in Torgome and 42 stationed at the cement plant. As a part of ESAP #10, CBI will develop and adopt a Security Management Plan (SMP) guided by the principles of proportionality and good international practice. The SMP will define the company’s approach to risk assessments, hiring, rules of conduct, training, appropriate conduct toward workers and community members, equipping, and monitoring of security guards and their activities.
PS5 Land Acquisition and Involuntary Resettlement
The company will lease the 304-acre property belonging to the Torgorme community. The company has signed a 50-year lease agreement with the Government of Ghana for use of the quarry. In addition to the leasing process, the company engaged 21 families with customary freehold rights within the affected 304 acres and came to a negotiated compensation settlement between the company, the affected families and the Torgorme community traditional authorities. In accordance with the negotiated agreement, the company will make 4 payments over 9 years to both the affected families and the Traditional Authorities. The company undertook a livelihood assessment to determine the economic impacts on other users of the land and developed a Land Acquisition and Livelihood Restoration Plan (LRP) that is partly aligned with PS 5 requirements with the exceptions indicated below.
The LRP determined that the area targeted for clay extraction was not clearly demarcated at the time of the study, hence the scope of the LRP covered the entire 304 acres owned by the Torgorme community. Farmers planting seasonal crops such as maize and vegetables and perennial crops such as mango and oil palm were affected by the project. The land is also used for extraction of clay for pottery by a self-organized local group of women, with approximately 100 registered members and shrines were identified within the 304 acres. To meet PS 5 requirements ESAP #11, the company develop a supplemental LRP to demarcate the areas affected by clay extraction and appurtenant infrastructure and the areas within the 304 acres which will be left untouched by the project. The supplemental LALRP will incorporate preparation of a land and asset inventory and census of impacted persons or groups within the affected area and build up on the level of agreements between the company and the affected farmers, pottery groups and general community with regard to impact on shrines. The supplemental LALRP will provide the plans and procedures that the company will undertake, as well as the key stakeholders to be involved in LALRP implementation, monitoring and evaluation. The client will need to conduct a close out audit of the LRP to confirm implementation of the plan.
