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 Management System and Policy: EDK Group has recently initiated the development of an Environmental and Social Management System (ESMS), led by the company’s Quality, Health, Safety, and Environment (QHSE) Department. The current system is based upon a combination of documents, procedures and tools, including a Plan de Gestion Environnementale et Sociale (PGES), the annually updated workplace risk register (Document Unique d’Évaluation des Risques Professionnels – DUERP), a corporate-level Health, Safety, and Environment (HSE) Manual, internal safety protocols, and emergency response plans (Plan d’Opération Interne – POI).
The HSE Manual outlines roles and responsibilities in health, hygiene, and safety management, including procedures related to food hygiene, cleaning protocols, the use of protective equipment, and site inspections, aligned with ISO 45001. However, it was observed the implementation of these procedures remains largely limited to corporate-level oversight, with inconsistent application across store locations. Hygiene risk assessments are not site-specific, and internal audit and monitoring systems have not yet been formalized. In addition, the Group does not currently have an overarching Environmental and Social Policy.
As part of ESAP #1, the Group will enhance its current ESMS to align with IFC requirements. This will include: (i) the development of a Group-wide Sustainability Policy that outlines the company’s commitment to good international industry practice, including resource efficiency; (ii) the introduction of a Group-wide environmental and social risk screening procedure to be implemented by all subsidiaries and business lines to identify, avoid, manage or mitigate EHS risks and their associated impacts in line with IFC’s Performance Standards 1 to 8, including risks associated with expansion and land access; (iii) implementation of site specific EHS procedures; (iv) the establishment of tailored life and fire safety procedures for each line of business (as further elaborated under PS4); (v) the development of occupational health, safety, and contractor management plans (described further under PS2); (vi) the implementation of a resource efficiency strategy; (vii) the development of supply chain compliance procedures (as discussed under PS2); (viii) the establishment of a monitoring, review, and reporting framework incorporating key E&S performance indicators; (ix) the implementation of road safety procedures applicable to Group-owned and contracted truck operations (as detailed under PS4); and (x) the introduction of grievance mechanisms at both the community and store level.
All procedures and plans will be integrated into a centralized Group-wide ESMS platform and monitored through measurable key performance indicators (KPIs) and regular internal audits will be conducted to demonstrate implementation and effectiveness of the management system elements (ESAP #2)
Identification of Risks and Impacts EDK’s business model typically combines the Group’s three operational lines—Low Price, Djollof Chicken, and EDK Oil—within a single location, generally measuring around 150 by 200 meters (30,000 sqm). In some urban locations, such as Dakar, standalone Low Price supermarkets are also to be found. Site selection for new locations is led by the Group commercial team and is followed by marketing assessments, which include early-stage engagement with nearby communities and prospective customers. Once the location is confirmed, the legal department conducts a due diligence review of land tenure.
The Group only acquires land through a willing-buyer/willing-seller approach, including verification of private ownership or State domain, identification of titleholders and users, negotiation and payment process. However, this process is not formalized by a procedure or supported by structured stakeholder engagement. To address these shortcomings, EDK will develop a formal procedure outlining the entire land purchasing process, including specific roles and responsibilities of those engaged in the practice and a mechanism for receiving and resolving grievances from communities adjacent to the proposed new location. Additionally, the Group will develop a centralized database to consolidate land tenure and permitting information across all current and future sites (ESAP #3). Land-related considerations will also be integrated into the broader E&S screening process ( ESAP #1).
Organizational Capacity and Competency the QHSE Department reports to senior management and is responsible for oversight of workplace safety, emergency preparedness, and regulatory compliance. However, roles and responsibilities related to E&S management are not consistently defined across departments and sites, and there is no formal E&S staffing or training plan in place. To address this, and as part of ESAP #4, the Group will enhance its organizational capacity by (i) appointing someone to the role of senior Sustainability Manager to oversee ESMS enhancement and implementation across all operations, (ii) designating and building capacity of site-level E&S focal points, and (iii) developing and rolling out E&S training standards to ensure consistent implementation of procedures Group-wide. HR responsibilities are overseen by a Group HR Director, supported by a dedicated HR Manager for LOW PRICE. At the site level, store managers serve as the primary focal points for labor-related matters.
Emergency Preparedness and Response At present, EDK has in place a corporate-level Plan d’Opération Interne (POI) and fire response plan aligned with national legislation. However, these plans are not adapted to the operational realities of individual store locations. It was noted that emergency drills are not conducted on a consistent basis, and training on response to emergency situations is not systematically provided to staff. In addition, the POI does not assess risks to adjacent communities or contain formal procedures for coordination with external emergency authorities. Fire safety equipment—such as extinguishers, alarms, and evacuation signage—is to be found at operations but was observed to be in poor condition at some sites.
In 2024, a fire incident occurred at the Group’s headquarters in Ngor. A post-incident report was produced and identified the root causes, including behavioural lapses, and documented corrective actions and lessons learned. Going forward, and in line with ESAP #1, the Group will (i) develop and implement site-specific emergency response plans for all retail and operational locations, (ii) ensure that annual emergency drills are carried out with full staff participation, and (iii) provide regular training for all employees on emergency protocols, including coordination with local fire and safety services. Site-specific plans will include evacuation procedures that take into consideration the needs of vulnerable individuals, including persons with disabilities, elderly customers, and children, and will ensure that appropriate facilities—such as wheelchair ramps—are available where necessary.
Supply Chain Labor Risk Management: The Group has a procurement agreement (“Convention d’approvisionenement) with its suppliers. The agreement includes detailed provisions on product quality, hygiene, food safety, traceability and EDK’s right to conduct site inspections with its suppliers. A formal process to assess labor or social risks is not included in the agreement. To improve supply chain oversight and as part of its ESMS enhancement, EDK will (i) develop and adopt a supplier code of conduct reflecting PS2 and PS6 principles and (ii) establish a risk-based suppliers management system, including labor risk screening, social audit protocols, a supplier performance rating framework and corrective measures in case of non-compliance. (ESAP #1).
PS 2: Labor and Working Conditions
HR Policies, Procedures and Working Conditions: LOW PRICE employs approximately 340 workers, all of whom have contracts registered with the Labor Inspectorate and are subject to medical screening and onboarding procedures. The Group has developed core human resources (HR) policies, including those for recruitment, internal regulations, salary and leave procedures, and a Code of Conduct. A formal onboarding process is in place to inform new hires of their roles, conduct expectations, and basic safety measures at the site level.
The Group’s HR policies incorporate commitments to non-discrimination, diversity, and equal opportunity, including gender equality and a prohibition of workplace discrimination. However, these policies are not yet consolidated. As part of ESAP #5, the Group will compile its existing HR practices into a comprehensive HR Manual accessible to all employees and subject to regular updates. The HR Manual will be disseminated in appropriate languages through induction and ongoing communication.
While overtime is voluntary and compensated in accordance with national law, there is no centralized system to monitor cumulative working hours, breaks, or legal limits across stores. To improve compliance, and under ESAP #6, the Group will implement a centralized time-tracking system and conduct regular internal audits of overtime and shift management.
Freedom of association: Staff delegates have not yet been formally elected at LOW PRICE or other EDK subsidiaries. The absence of worker representation has been flagged by the national Social Security Authority (CSS) as a non-compliance issue under Senegalese labor law. The Group has recently initiated the formation of Comités d’Hygiène, de Sécurité et des Conditions de Travail (CHSCTs) across subsidiaries. However, these committees are still in a setup phase and lacked clear mandates, meeting schedules, and integration into the ESMS. As per ESAP #8, EDK will (i) organize transparent staff delegate elections at all eligible sites in line with the national labor code procedures; (ii) operationalize CHSCTs by defining terms of reference, (ii) establishing meeting schedules, and (iii) ensuring staff input is integrated into HR and ESMS processes.
Grievance Management LOW PRICE relies on informal channels—such as direct reports to store managers or periodic satisfaction surveys—to collect worker concerns. There is no standardized grievance mechanism that ensures confidentiality, accessibility, timely resolution, or documentation. To address this, and under ESAP #7, EDK will establish a formal, documented grievance mechanism applicable to all employees, including contractors. The system will include anonymous reporting options, safeguards against retaliation, and a tracking system integrated into the ESMS. Procedures for handling sexual harassment complaints will be clearly defined to ensure confidentiality and appropriate redress. All staff will be trained on harassment prevention, and the grievance mechanism will be widely communicated across all subsidiaries.
LOW PRICE currently outsources approximately 61 non-core roles—including construction for new stores, security, cleaning, and cashiering—through two staffing firms operating under formal contracts. While these contracts contain basic provisions on labor and hygiene, oversight remains informal and based on periodic site visits, payroll checks, and internal feedback. Third-party staff are not systematically included in grievance systems, safety training, or HR monitoring. To close these gaps, the Group will develop a formal contractor management procedure including (i) documented onboarding processes, (ii) periodic audits of contractor labor conditions in line with national law, and (iii) expand of the Group’s grievance and safety protocols to all third-party workers (ESAP #8)
Occupational Health and Safety (OHS) OHS risk management is formalized through the Document Unique d’Évaluation des Risques Professionnels (DUERP), which is regularly updated and tailored to the specific risks associated with each activity, including fuel stations and Djolof Chicken outlets. At store level, OHS risks at store level are relatively limited
, with key risks concentrated in the construction phase, which typically lasts up to five months per supermarket. No specific environmental, social, or OHS provisions are currently included in construction or fit-out contracts. The Group will address this by incorporating relevant clauses into all future construction contracts and establishing procedures to monitor contractor compliance on-site. During the operational phase, the QHSE Department will implement a work permit system to manage safety for all maintenance and repair activities
During site visits, the use of basic PPE for supermarkets—such as gloves and slip-resistant footwear—was observed, particularly in the butchery areas.
In the central warehouse, a procedure aligned with the DUERP has been defined; however, implementation was inconsistent, and PPE were not properly used by all personnel. Some goods were noted to be improperly stored, and while forklifts were in operation, risk assessment protocols were not consistently applied. Going forward, QHSE department will strengthen supervision and enforcement of existing procedures through regular audits and implement work permit system to manage safety for all maintenance and repair activities (ESAP #9).
PS3: Resource Efficiency and Pollution Prevention
Energy Supply and Air Emissions The primary source of electricity for retail operations is the national grid, supplemented by back-up diesel generators (DGs) installed at each location. Due to their limited use, emissions from DGs are expected to remain below national regulatory thresholds and are not currently subject to air quality monitoring requirements.
Resource Efficiency and Refrigerant Management Low Price does not currently monitor energy or water consumption at the store or corporate level. Cold storage units are widely used across the retail network for food preservation, but the Group has not established an inventory of refrigerants nor implemented maintenance or leak detection protocols. As a result, greenhouse gas (GHG) emissions associated with refrigerant leakage remain unquantified and unmanaged.
Waste Management The Group has developed a Waste Management Procedure that distinguishes between common solid waste, expired products, and hazardous waste such as used oils, batteries, and chemical cleaning agents. A separate Returns Management Procedure governs the handling of damaged or expired goods, which may be either disposed of or returned to suppliers. Waste bins are available at most locations, with basic separation of recyclable and hazardous materials in place.
Hazardous waste is temporarily stored on-site and collected by licensed third-party providers. However, the Group does not currently maintain a hazardous waste inventory, verify contractor compliance, or systematically track final disposal. During site visits, it was observed that waste—particularly hazardous materials—was frequently stored improperly, with instances of leakage and contamination of surrounding areas. To address these gaps , as part of the ESMS development the Group will enhance its Waste Management Procedure by : (i) developing and implementing standardized waste storage protocols applicable to all sites, including designated storage areas, sealed and labeled containers, and segregation of hazardous and non-hazardous materials; (ii) upgrading on-site storage infrastructure with appropriate spill containment, weatherproofing, and signage; (iii) conducting regular inspections of waste storage areas through designated site-level E&S focal points; (iv) providing staff training on proper handling and storage of all waste types; (v) documenting and respond to non-compliance through the ESMS incident tracking system; and (vi) establishing a hazardous waste inventory system and procedures for verifying third-party disposal contractors. These improvements will be and monitored through KPIs and internal audits as part of the ESMS.
PS4: Community Health, Safety and Security
Life Fire and Safety: At the time of the site visits, basic fire safety measures had been implemented across several Low Price stores, including the installation of fire extinguishers, emergency staircases, evacuation maps, and periodic staff training. A corporate-level emergency response plan (Plan d’Opération Interne – POI) is also in place. However, fire safety procedures are not applied consistently across the store network. Variations were observed in the availability and visibility of evacuation signage, the condition and maintenance of safety equipment, and the frequency and comprehensiveness of staff training.
Most Low Price stores are located in densely populated urban and peri-urban areas, where operations such as food preparation, fuel storage, deliveries, and high customer traffic may pose health and safety risks to surrounding communities. While internal emergency procedures exist, there is no site-specific assessment of risks to nearby residents, informal vendors around the gas stations, or other third parties, nor formal coordination with local emergency services. To address these gaps, the Group will develop site-specific Life and Fire Safety (LFS) management procedures for all supermarket subsidiaries as part of ESAP #10. These programs will define (i) minimum LFS requirements for all store types, (ii) incorporate a standardized checklist covering design features, operational controls, internal inspections, and emergency preparedness, and (iii) integrate Community Health Safety (CHS) risk considerations—including safe fuel storage, customer traffic flow, and interaction with informal vendors—in coordination with municipal fire and health authorities.
Security forces: Security services are provided by licensed third-party contractors, who are trained in access control, fire prevention, and site monitoring. The Group will require all contracted security guards to undergo enhanced training modules on human rights and gender-based violence and harassment (GBVH), in line with IFC Performance Standards and Good International Industry Practice (GIIP). This training will prioritize respectful engagement with customers and community members, with particular attention to vulnerable groups and informal vendors, and will be integrated as a contractual obligation in all future security agreements (ESAP #11).
Transport Safety: Low Price operates an internal logistics system to supply its retail network; however, no road safety procedures or transport risk management protocols were identified during the E&S review. The Group lacks documented procedures related to vehicle operations, fleet maintenance, driver training, or accident prevention. As part of the broader ESMS upgrade, EDK will establish road safety policies to manage risks associated with its transportation activities (ESAP#1).
