IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
E&S Policies and Management System
BMT has a set of E&S policies which are applicable to all project activities, and employees, contractors, subcontractors, and visitors. Additional standalone policies cover non-discrimination, anti-bribery, compliance and business ethics. All policies are available to all workers in English and Arabic. BMT also developed an Integrated Management System (IMS) which includes procedures and plans addressing E&S risks and impacts related to Terminal 1 activities. The system formed the basis of T2 construction phase documentation and will be extended to its operational phase. The QHSSE Management System was certified between 2018 and 2024 with three major certifications including ISO 9001, ISO14001 and ISO 45001 & ISO 26000. The company is in the process of preparing for recertification expected to be completed in early 2026.
Going forward, as per ESAP #1(a) BMT will continue to improve and implement its QHSSE Policy and all aspects of the updated IMS to address project risks and impacts in line with the provisions of IFC Performance Standards, good international industry practice (GIIP) and the applicable World Bank Group (WBG) Environment, Health and Safety (EHS) General Guidelines, and the sector specific Guidelines for Ports, Harbors and Terminals. BMT will also update the Project’s ESMP and associated management plans, procedures, and KPIs including occupational health and safety (OHS), management of air emissions and noise from project construction, terminal equipment and transport vehicles, GHG emissions, treatment, containment and management of discharges on land or sea including storm water, sewage, spills and waste disposal.
Identification of Risks and Impacts
BMT commissioned an environmental and social impact assessment (ESIA) study in 2018 supplemented by a PS compliant ESDD covering T2 construction, operation, and decommissioning phases in alignment with PS1 requirements. The ESIA included a framework (ESMP) for T2 construction and operation. For this repeat investment, BMT will assess the potential risks and impacts for T2 development in an ESIA addendum together with other T2 additional or revised design components (i.e., dredger service berths, associated facilities, etc.). BMT and its contractors will also develop comprehensive risks assessments for all planned activities (ESAP#1b).
Management Programs
As part of ESAP #1(a), BMT will formally integrate the ESMP and other management plans in the IMS, notably in relation to the new project scope of work in line with IFC PS. BMT will be responsible for the implementation of the construction phase mitigations and relevant undertakings, provisions and agreements with GCPI relevant to the operations, consistent with PS1 requirements on associated facilities.
Organizational Capacity and Competency
BMT will enhance its organizational capacity and competency by adding dedicated QHSE resources and deploying additional dedicated personnel to (i) monitor and report on the company’s E&S performance and relevant KPIs; and (ii) oversee contractor management procedure implementation including E&S audits and review of contractors E&S performance (ESAP #1c).
Emergency Preparedness and Response
BMT developed emergency preparedness and response procedures that address the management of environmental and OHS emergencies within the site and address external emergencies including natural disasters (except flooding), fire control, emergency evacuation, security and health/medical emergencies. With climate change expected to intensify flooding events, BMT will integrate flooding risk management into the EPRP to strengthen preparedness for possible future climate-induced floods. In addition, BMT and its contractors will fully implement EPRP and conduct planned training and emergency drills (ESAP#1d).
Monitoring and Review
Performance monitoring related to the operations activities at Terminal 1 and construction activities of T2 are tracked and recorded, including contractors and OHS performance and environmental monitoring. Based on the project monitoring, BMT’s annual IMS review and reporting on different KPIs is not undertaken in line with the GIIP, ISO 14001 and ISO 45001 recommendations. Going forward, BMT will undertake an annual IMS external audit (ESAP #1e). BMT will also undertake an external audit to assess the implementation of its Contractor Management procedure, in alignment with PS1 as outline under ESAP#2(f).
PS 2 – Labor and Working Conditions
Human Resources Policies and Procedures
As of end of December 2024, BMT’s existing workforce includes 351 direct employees (four of which are women) and 253 contract workers. The number of direct employees is expected to increase to around 400 employees once the new terminal becomes fully operational. The company has a Human Resource (HR) policy outlining workers’ rights under national labor and employment laws. The policy provides detailed procedures and approach to workers management in line with international standards and is appropriate to the size and workforce of BMT. Furthermore, the company’s Labor Management Plan addresses workers’ rights, induction, wages, overtime, working hours, social security, workplace hygiene standards, commitment to freedom of association, and non-discrimination and harassment aligned with PS2 requirements. BMT adopted these to cover T2 activities for direct employees and contractors’ personnel.
Working Conditions and Terms of Employment
The HR policy, labor management procedures and employee handbook are made available in English and Arabic to all workers. Based on the monitoring of the existing project, national legislation does not require permanent, occasional and contractor workers to have a written contract. As per ESAP #2(a), BMT to provide contracts in writing to all workers. BMT will also commission an independent labor audit to confirm that BMT’s HR policies and procedures including working conditions and terms of employment are in line with IFC PS2 requirements.
During the construction phase, labor was contracted locally; Due to the temporary nature of this new terminal construction needs, the project established a temporary workers’ camp, located within the project yard, to accommodate 130 workers. BMT, as part of the construction labor management plan, developed a detailed accommodation plan that incorporated GIIP and relevant IFC guidelines. BMT accommodation standards are also required to be implemented by all contractors. In addition, contractors are required to adhere to the same labor and working conditions as the company. BMT will continue to undertake QHSE audits of all main contractors and workers accommodation camp on a quarterly basis (ESAP#2b).
Workers’ Organization
Freedom of association and the right to collective bargaining is protected by Article 6 of the Iraqi Labor Law and BMT complies with such national requirement.
Non-discrimination and Equal Opportunity
The HR policy and procedures include a non-discrimination policy. The Code of Conduct and Business Ethics Policy state that the company has zero tolerance to harassment and bullying. BMT has appointed the QHSE manager as the dedicated focal point to receive any complaints related to sexual harassment in the workplace. Furthermore, BMT communicates these policies through various channels and will conduct formal in-house trainings, including on gender equality issues for all employees and contractors while managers are being trained on how to respond to incidents of sexual harassment in the workplace. Based on IFC’s latest review, Gender Based Violence and Harassment (GBVH) provisions are not fully integrated in BMT’s HR procedures. As per ESAP 2(c), BMT will explicitly address GBVH in its existing HR policy or adopt a standalone GBVH policy, including specific GBVH and discrimination disciplinary measures into the Code of Conduct. BMT will also amend the grievance mechanism to include a channel to report “sensitive cases” (harassment, GBVH, discrimination, mobbing, etc.), and will provide training on harassment, discrimination and GBVH.
Grievance Mechanism
BMT has a grievance mechanism (GM) in place for employees working at Terminal 1 and 2 (for operations and construction) to ensure that workers’ complaints are considered and resolved. All project workers, including contracted workers (as stated in the employers’ requirements policy) have the right to file a complaint by telephone, email, or handwritten note. In addition, BMT uses other communication channels including inductions, to cater for all employees including unskilled workers. As per ESAP #2d, BMT will take measures to ensure the grievance mechanism, and all available channels are disseminated and well understood amongst direct employees and contractors’ workers and all grievances are addressed within established timelines.
Protecting the Work Force
Child and forced labour are prohibited under the Iraqi Labour Law and are included in the company’s business ethics policy and code of conduct. BMT will continue to implement these procedures and, regular and random controls, to ensure compliance with minimum age requirement as applicable to its own workforce and the contractors’ personnel, as well as service suppliers.
Occupational Health and Safety
BMT established, as part of its IMS, a safety management system, which was ISO 45001 certified until February 2024. The company is in the process of preparing for recertification expected to be completed in early 2026. The management system addresses areas such as training, auditing, personal protective equipment (PPE) management, risk assessment, drills scheduling, hazardous substances management, KPI identification, and recording. As part of ESAP #1(a) OHS implementation and reporting, including KPIs establishment and monitoring, will be updated and incorporated in the new IFC investment.
BMT requires its construction contractors to submit, 28 days before the starting date, a site safety plan. Contractors are required to review and update the plan as necessary during the construction phase. Furthermore, the company requires contractors to develop a project specific E&S management plan, including but not limited to, all relevant OHS procedures and plans, training matrix, and KPI. The contractors are required to appoint a site safety officer and attend monthly safety meetings. Site safety plan, project E&S management plan, and appointment of the safety officer appointment are subject to BMT approval.
The review of operational performance at Terminal 1 in the past two years identified areas of improvement to further reduce lost time injury frequency rates, including fatality in 2022. Going forward, BMT will enhance training of the QHSE team and workers in line with improved training targets. (ESAP#2e). BMT also conducts OHS meetings and periodic auditing, however these are not sufficient. As part of this investment, BMT will undertake comprehensive internal and external (contractors) audits and implement corrective actions related to identified gaps and non-compliances within established timelines including aligning the Contractor’s ESMS with Project requirements, procedures for emergency drills, workers accommodation, and OHS management. as outlined in ESAP#2(f).
Workers Engaged by Third Parties
All BMT contractors and main suppliers’ workers are bound by employment agreements to provide fair working conditions and terms of employment compliant with BMT human resources and non-discrimination policies as well as the company’s code of conduct and business ethics policy, all of which are in line with IFC Performance Standards. Furthermore, they are required to have a functional EHS management system that complies with BMT's requirements. BMT’s contractor contracts include specific reference to BMT EHS policies, and applicable local or international standards and regulations of Republic of Iraq.
PS 3 – Resource Efficiency and Pollution Prevention
Pollution prevention and control are covered under the IMS and the project’s ESMP, as updated under ESAP #1(a), including: management of air emissions and noise from project construction, terminal equipment and transport vehicles, GHG emissions, treatment, containment and management of discharges on land or sea including storm water, sewage, spills and waste disposal.
Air Emissions and Ambient Air Quality
In line with the Engineering, Procurement and Construction (EPC) contract and the construction ESMP requirements, BMT completed baseline air quality monitoring before the start of construction. Air Monitoring records for the construction phase indicate concentrations within national limits. During the operation phase of T2, limited to container handling and Ro-Ro activities, air emissions are mostly expected from mobile sources associated with terrestrial and maritime traffic and operational vehicles; stand-by diesel generators will be available but operated only on as needed basis in case of power outage from the electrical grid. BMT will continue to implement air quality and emissions management and monitoring procedures in line with EPC contract and ESMP requirements.
Noise
As part of the ESMP, BMT developed a Noise and Vibration Management Plan which outlines noise control and mitigation measures to reduce construction and operational noise levels in line with applicable requirements. The company will continue to monitor noise and vibrations levels during operations and will define action thresholds consistent with national requirements and relevant and applicable WBG guidelines.
Resources Use
During the construction phase of T2 electric power was provided from the national grid as well as by diesel generators installed at the construction site. During operation, both Terminals 1 and 2 will receive power from the national grid via an underground cable with an estimated annual consumption of around 6,000,000 KwH (6,000MwH) based on a volume handled of 320,000 TEUs.
Water supply will be provided through existing groundwater supplies for non-human consumption with appropriate sanitation and stored in tanks. Non potable water will be used where possible. Fresh water for human consumption is provided by 3rd parties.
Greenhouse Gas Emissions (GHG)
Based on a yearly Throughput of 320,000 TEUs, the terminal undertakes a combination of 975,465 container moves across all operations, from quay lift, yard operations, empty container handling, using a range of diesel-fueled container handling equipment, with total emissions of 9,563 tCO2e in 2024, or 9.6 kgCO2e per move. The project will introduce electric and hybrid-electric equipment which will reduce diesel use and increase electricity use. Emissions with the project are expected to be 6,927 tCO2e per year, leading to emissions reductions of 2,636 tCO2e per year.
Waste Management
BMT developed a waste management plan including guidelines for hazardous waste management applicable to its contractors, which is an integral part of the IMS. During the construction of T2, the project-generated waste includes waste from construction activities (e.g. scrap metal, plastic, glass, paper and cardboard, packaging, etc.); domestic waste from the construction area and base camp; and a limited amount of hazardous waste (e.g. used oils). Secondary containment will be provided for fuel and hazardous material storage with containment capacity accommodating 110% of the largest container. Spill kits are available at the site and disposal of hazardous waste will be undertaken by an authorized entity. Vessels do not discharge/dispose of any waste at the terminals. Oil separators are installed along the drainage system to avoid the release of oil into the environment. Construction waste management will be strengthened as part of the project ESMP and waste management plan (WMP) as per ESAP #1(a).
The key issues identified during the monitoring of waste management at both T1 and T2 relate to waste disposal practices. While there are designated waste disposal areas in southern Iraq, they do not meet the characteristics of engineered landfills as defined under international standards. These areas are, however, indicated and managed by the municipal authorities. In line with ESAP #3, BMT will engage with the Port Authority and relevant municipal authorities to assess the compliance status of the current waste disposal arrangements and explore opportunities to enhance alignment with IFC Performance Standards. If a compliant facility cannot be identified despite reasonable efforts, BMT will document the limitations encountered and, in coordination with local stakeholders, pursue practical and environmentally sound waste management solutions for T2 and associated new investments.
PS 4 – Community Health, Safety and Security
Community Health and Safety
The port is located adjacent to two main roads leading to/from Basra and Bagdad. T2 operation will result in a measurable increase of truck traffic that will further increase pressure to an already stressed situation given the incremental growth of the port activities in the last few years. As per ESAP# 4(a) BMT will continue to improve and implement a land management plan for the operational phase incorporating mitigating measures outlined in the ESIA including, but not limited to, identification of key stakeholders, both within the local/national authorities and local representatives, drivers training and safety measures, signage, and control measures.
While some labor influx took place during peak construction of T2, most non-local labor was housed at the on-site workers camp with minimal impact on the local communities and their infrastructures.
Emergency Preparedness and Response
BMT has communicated its emergency, and evacuation plans to district/local government emergency authorities. Based on the monitoring of the existing project, Life and Fire Safety (LFS) practices require improvements at both T1 and T2. As outlined in ESAP#4(b). BMT will implement all correctives actions identified by LFS audit at both T1 and T2 such as installing comprehensive fire alarm systems and firefighting equipment across various locations within the terminal's premises.
Security Personnel
At the port, external security (e.g. roadblocks and checkpoint leading to the port) is under the responsibility of an Iraqi naval division, headquartered at south of the port, while perimeter and internal security is under the Iraqi port security department (IPSD) including all port access gates and internal checkpoints. BMT has its own security within the terminal area and the project site. Project security providers, whether directly contracted by BMT, or indirectly by a contractor, are screened by BMT. All security personnel undergo formal induction and special awareness training on project risks. Training is reinforced through regular debriefings and performance reviews. The internal security team has been vetted through the Minister of Interior, or by senior tribal leaders in the region and receives regular training and toolbox talks. Armed guards are required to be trained to the standard of conduct armed guard force duties.
BMT developed a security plan and related procedures (e.g. operational security procedure, crowd control procedure, emergency evacuation plan) generally aligned with IFC PS4. The plan is constantly updated/adapted to reflect current risk situations and considers consultations with security contractors. However, these documents are not fully integrated within the IMS, are not cross-referenced or linked to BMT policies and relevant procedures. BMT will continue to implement the existing security in line with IFC PS4 provisions related to use of security forces including the sensitivity analysis as well as the community grievance mechanism and will continue to meet the security training requirement and matrixes for the company’s own security team. All new recruits are subject to a background check by BMT as required by the company security plan.
