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
Policy and Management System.
The Company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. VICAT Group Sustainability Framework, E&S policies and management procedures are cascaded down to SOCOCIM. SOCOCIM adopted a QSE & CSR Policy and established an Integrated QSE Management System covering plant and quarry activities. The SOCOCIM plant is ISO 9001-certified (quality) since 2009 and ISO 14001-certified (environment) since 2010. The efficiency of the QSE Management System is annually audited by external auditors.
Identification of Risks and Impacts.
An Environmental and Social Impact Assessment (ESIA) was completed in March 2022 for the construction of kiln 6 in line with the national legal requirements, including consideration of cumulative impacts. To complement the ESIA, SOCOCIM conducted complementary air quality, noise, vibrations and traffic impact assessment studies for the kiln 6 construction in December 2023, and defined additional mitigation measures, aligned with the requirements of IFC PS and WBG EHS Guidelines. SOCOCIM will ensure all necessary authorizations and regulatory approvals are in place prior to starting kiln 6 operations (ESAP #1).
Part of the Bandia quarry, measuring 250 ha and authorized in 2019, has not been in use yet. Before the starts of the operations, the Company will prepare an additional ESIA, including the development of mitigation measures, in line with the national legal requirements and IFC PSs (ESAP#2).
The compensation process of the residents affected by the Bargny quarry concession from the Ministry of Mine to the company in 2006 is still ongoing. The company deposited the compensation amount into an account managed by a public notary. Recently the Company also carried out a series of community outreach meetings requesting the concerned parties to file a request for compensation. However, only 33% of the concerned parties have been successfully compensated to date. Reasons for the delay include, among others, (i) the inability to secure title; (ii) lack of required IDs to support validation by the public notary. SOCOCIM will prepare a compensation close-out report including: (i) a brief description of the compensation process following the award of the Bargny quarry concession; (ii) status of the compensation process to date; (iii) a detailed breakdown of the compensation awards and specific constraints to access compensation and (iv) a tracking tool to monitor the completion of the compensation process to be shared on a quarterly basis with IFC (ESAP #4).
For the last 10 years, SOCOCIM has granted access to some farmers for small vegetable gardens purposes in the unused portion of the Barry quarry extension area. The company signed an agreement with the farmers allowing them access to the fenced area until the quarry is ready for exploitation. SOCOCIM will develop an informed consultation procedure defining clear messages, responsibilities and an agreed notice period before reclaiming the quarry land. The procedure will also define the process guiding SOCOCIM before reclaiming the land by (i) assessing any remaining dependencies in the targeted plots; and (ii) setting up a community grievance mechanism to addressing any potential complaints (ESAP #13).
Management Programs.
SOCOCIM has been updating the kiln 6 Environmental and Social Management and Monitoring Plans (ESMMP), for both the construction and operations phases with additional mitigation measures identified in the complementary ESIA studies for air quality, noise, vibrations and traffic management. The EPC contractor prepared an Environmental, Health and Safety Plan for the construction phase that is consistent with the requirement of the PS and WBG EHS guidelines. As per ESAP#3, SOCOCIM will finalize the updating and implement its operational ESMMPs before the start of the kiln 6 operations.
Organizational Capacity and Competency.
SOCOCIM has dedicated Quality-CSR and Health, Safety and Environment (QCSR & HSE) Departments. A separate Quarry Department manages all 4 quarries. The EPC contractor has an HSE Manager to supervise construction activities.
Emergency Preparedness and Response.
SOCOCIM has documented an emergency preparedness and response (EPR) plan for the cement plant. The plant has the necessary fire safety emergency detection and alarm systems, and response equipment, tested periodically. The EPR is being updated to reflect the operation of the new kiln 6 (ESAP #3).
Monitoring and Review.
As part of the plant QSE management system, the company monitors periodically key performance indicators (KPIs) such as regulatory compliance. The QSE Management System Manual has a provision for regular EHS monitoring performed via internal audits and performance assessments including parameters such as, among others, lost time accidents and related statistics, training, solid and hazardous waste, air, pollution and noise and resource use. In the last two years, the Company also set up a system to monitor contractor’s compliance with national labor requirements.
PS2: Labor and Working Conditions:
SOCOCIM employs 372 workers directly and relies on 1,010 temporary workers provided through 5 labor agencies. In addition, around 150 primary third-party contractors support SOCOCIM’s operations, employing around 1,000 contracted workers. The majority of contacted workers are hired in security– (102 workers); cleaning services (183 workers); transportation– (305 workers); and mining and drilling (40 workers). The majority of contracted workers are from Rufisque and neighboring local communities as part of SOCOCIM local content requirements for contractors to prioritize employment from local communities.
Currently, the kiln 6 construction phase currently mobilizes 1,200 workers, contracted through the EPC contractor and its subcontractors. When in operations, kiln 6 will rely in large part on the redeployment of approximately 50 existing employees and 100 subcontracted workers, it still requires the hiring of half a dozen new technical and management staff.
Human Resources Policies and Procedures.
SOCOCIM adopted and implemented the VICAT Group HR and Procurement policies and strategies as described in its Declaration of Non-Financial Performance (DPEF). Its Supplier Code of Conduct and Ethical Charter prohibits forced labor, child labor and discrimination and proactively seeks to favor inclusion, employ local populations and train teams on occupational health and safety. In addition, SOCOCIM adopted and implemented site-specific HR procedures and regulations including: Quality, Health and Safety Manual, the Human Resources Manual, and as required by national labor regulations, the Internal Rules (which applies to all direct workers). Since 2022, the Company established a mechanism to monitor sub-contractor’s compliance with the national labor requirements and has been updating its grievance mechanism (to be discussed in the section below).
Working Conditions and Terms of Employment.
Employees’ working conditions and terms of employment are largely defined and aligned with the Senegalese labor law and the collective bargaining agreements (CBA) currently in force. For direct workers, SOCOCIM relies exclusively on workers that have an open-ended contract (CDI, Contrat à Durée Indéterminée). However, short-term contracts may be used on an ad-hoc basis to meet occasional operational needs.
Each employee is provided with a contract outlining the terms and conditions of their employment including, but not limited to, payments, working hours, rest periods and leave, benefits, overtime, disciplinary procedures.
Workers’ Organization.
SOCOCIM direct employees are members of two main unions : the CNT-FC (Confédération Nationale des Travailleurs du Sénégal) and the CSA (Confédération des Syndicats Autonomes). Union members are represented by 14 elected worker representatives and seven alternates, elected for a 3-year term. The 2019 interprofessional collective bargaining agreement (CBA) is still applicable and additional items can be negotiated on an ongoing basis through the monthly meetings between Sococim management and the workers’ representatives.
Non-discrimination and Equal Opportunity.
Although female staff represent around 10% of the workforce, they are present in all job categories, including in operations and in management positions. In addition to the Group policy on non-discrimination and inclusion and the Internal Rules against bullying and sexual harassment, SOCOCIM supported the creation of a female workers ‘group to organize activities related to health prevention, job and skills development for all its members.
Grievance Mechanism.
VICAT group’s Alert Platform is available under the Ethics section of the Group’s website for workers to report on non-compliance against the Ethics Charter or Codes of Conduct. The internal workplace grievance mechanism (GM) has been recently updated to also cover third-party workers, to facilitate reporting, management of worker grievances and anonymous reporting. Other updates include (i) a differentiated approach to address sexual harassment and gender-based violence, (ii) anticipating the involvement of female staff members and (iii) the involvement of the company’s medical staff in managing certain complaints.
Since its launch in July 2023, communication about the grievance mechanism has been limited, with only a small number of complaints received by the Company. Complaints were generally well managed by the HR Director, though communication of the specific actions taken could be strengthened for greater transparency. SOCOCIM will further enhance its internal grievance mechanism by detailing the process for filing and managing grievances including (i) timelines; (ii) escalation pathways; (iii) documentation protocols for greater transparency and (iv) communication protocols with the affected workers. SOCOCIM will also ensure that all persons in charge of handling internal complaints are adequately trained (ESAP #5).
Occupational Health and Safety.
SOCOCIM has recently strengthened and expanded its OHS monitoring and supervision for contracted workers. An OHS risk assessment and management plan has been prepared and implemented by the EPC contractor as part of the kiln 6 construction ESMMPs. Work-related accident statistics for direct and contracted workers show a significant decrease in the last several years.
Workers Engaged by Third Parties.
As required in the contracts with SOCOCIM, labor agencies and contractors shall respect their fiscal and social obligations to its workers including tax payments, retirement, social security and health insurance and maintains the right to audit worker contracts. Recently SOCOCIM has extended the application of its Internal Rules also to workers hired through labor agencies. In the contract with the kiln 6 EPC contractor, SOCOCIM included specific labor provision such as (i) workers be hired in accordance with the Senegalese law; (ii) respect of SOCOCIM health and safety policies and procedures; (iii) right of workers be informed of health and safety risks related to their work by the contractor; and, (iv) the requirement for the workers to use appropriate PPEs while on site.
Working conditions among SOCOCIM’s labor agencies and contactors vary significantly. SOCOCIM has recently developed a contractor management procedure and a monitoring tool to oversee the terms and conditions of its indirect workforce, including labor agencies and contactors. Audits conducted as part of the procedure already revealed some non-compliance with the national labor requirements (such as registration to social security; evidence of contracts in place, duration of contracts).
However, the nature of the audits performed is limited only to five temporary agencies and four construction companies, excluding their daily workers. Furthermore, the audit process and monitoring tool do not cover aspects such as non-discrimination, workers representation and grievance mechanism. The Company will enhance its contract management procedures and monitoring tool by (i) finalizing the mapping of all service providers and workforce operating on site; (ii) including the number of companies covered by SOCOCIM’s internal audit procedures; (iii) ensuring that daily workers are included in the process; (iv) expanding the audit process to include all aspects related to non-discrimination, workers representation and grievance management procedures (ESAP #6).
Supply Chain.
The Company has recently started a supply chain mapping and risk assessment covering its suppliers of biomass and alternative fuels. SOCOCIM will implement the mitigation measures resulting from the assessment and develop a code of conduct for the suppliers to address the potential risks (ESAP #7).
PS3: Resource Efficiency and Pollution Prevention;
Energy Consumption.
The main fuels for the kilns are coal and pet coke (up to 240kt/yr). Since 2009, alternative fuels for the kilns have been used as a replacement for fossil fuels. The current substitution rate is approx. 28%, consisting mainly of biomass, used tires, used oils and solid recovered fuel (SRF). The new kiln 6 aims at substituting up to 70% of fossil fuels. Thermal consumption of new kiln 6 will be within the range reflective of Best Available Techniques (BAT) defined by the 2013 EU BAT Reference Document for the sector, and within the benchmark set by the WBG EHS Guidelines for Cement and Lime Manufacturing.
In addition, the electricity requirement for the new kiln 6 will be within the guidelines provided by the WBG EHS Guidelines for Cement and Lime Manufacturing. 50% of the electricity will be provided through the national grid and the remaining by onsite supply including a 24 MW HFO fuelled plant, a 3 MW gas fuelled plant and a 6.9 MW solar plant.
Water Supply. The SOCOCIM plant uses about 400,000 m3/year of water, provided by the network (SEN Eau) and rainwater reuse. The manufacturing process is essentially dry, and most of the water is used primarily for cooling, grinding, high pressure cleaning, dust suppression, fire network, sanitary facilities. The plant water needs after kiln 6 installation will be significantly reduced due to kiln 6 design, leading to savings of 150,000 m3/year as compared to current plant usage.
Greenhouse Gas Emissions.
Gross emissions are estimated at 1,700k tCO2eq/year for kiln 5 and 6. For comparison, GHG emissions under the business-as-usual scenario (kiln 3 and kiln 4 in operation) would be over 2,000k tCO2eq/year. Hence, the kiln 6 project would generate a reduction of more than 300k tCO2eq/year of greenhouse gas emissions.
Air Emissions and Ambient Air Quality.
The principal sources of air emissions at the SOCOCIM plant are the clinker production and grinding operations including limestone quarrying activities and transfer to site (via truck haulage), storage and handling of clinker, limestone, basalt and coal at the plant, transfer and bagging of cement, as well as transportation along the site access road. Measures are implemented to reduce dust levels such as filters, roads cleaning and watering. Also, the existing conveyors are enclosed, to reduce dust emissions. The latest monitoring results of the kiln 5 and the on-site power plant stack air emissions are aligned with WBG EHS Guidelines, except for a slight exceedance of NOx at kiln 5. SOCOCIM has installed continuous air emissions monitoring at kiln 5 to best identify needs for process optimization and will continue current and future stack emissions monitoring to identify and address any non-compliance with national and WBG EHS Guidelines, per ESAP #8.
Results of biannual ambient air quality monitoring show elevated dust levels within the site, at the site boundary and in the surrounding residential areas, as a result of both site-related and non-site-related sources. The kiln 6 project is designed to significantly reduce dust emissions (by 41% according to the complementary studies on air quality) with: best available technology (including single bag filter design); replacement of existing coal mill; no more clinker imports resulting in less clinker handling; increase of inside clinker storage capacity; and one single crusher for raw materials instead of two, equipped with a powerful bag filter. The complementary impact assessment study on air quality shows a degraded airshed for particulate matter due to regional background and human activities, as well as a decrease in particulate matter (PM) concentrations as a result of the kiln 6 project. Considering site emissions only (excluding background concentrations), no Ambient Air Quality Standards (AAQS) exceedance is observed for the modelled PM concentrations at sensitive receptors (such as residential areas). In order to align with WBG EHS guidelines relevant to degraded airsheds and continue reducing SOCOCIM contribution to dust emissions as much as possible, SOCOCIM will implement its ambient air monitoring program and identify any action needed to align with WBG EHS Guidelines (ESAP #9).
Noise and vibration.
Noise is generated by operation of plant equipment, quarrying activities including infrequent blasting, and operations-related traffic. Annual ambient noise monitoring results indicate noise level exceedance of Senegalese standards and WBG EHS Guidelines in the resident areas close to the plant boundaries, as a result of both site-related and non site-related sources. The kiln 6 project includes the implementation of improvements and embedded mitigation measures for noise and the complementary noise impact assessment shows that the kiln 6 project has an overall positive impact on noise levels around the site. When considering site emissions only, no exceedance of daytime limit values has been modelled in residential areas for the future scenario. However, modelling results show potential exceedances of night limit values in residential areas. SOCOCIM will implement its noise monitoring program and identify any action needed to align with Senegalese standards and WBG EHS Guidelines (ESAP #9).
Monitoring of blasting vibrations is systematically conducted at the Bargny quarry, with a maximum of 3 blasts per day in Bargny carried out only during daytime in a fixed time that is previously communicated to the neighboring communities. Monitoring for the past five years shows no exceedance of the defined threshold (French standard to avoid damage). Nonetheless, mitigation measures have been implemented to reduce impacts on surrounding communities including (i) the installation of buffer corridors and evolution to multi-detonation shot charges); (ii) the development of a Bargny quarry Mining Plan and (iii) blasting management plan including blasting procedures and mitigation measures to be implemented by the operator of the quarry. SOCOCIM will continue the monitoring of vibration levels to follow vibration exposure of communities and identify and implement any action needed to align with applicable standards (ESAP #9).
Solid Waste Management.
Waste is segregated at the site and and most waste streams are recycled (Objective: zero waste to the landfill) in line with SOCOCIM’s Waste Management Procedure. All waste with calorific value (paper and cardboard, used oil, oiled rags, solvents, plastic, wood etc.) is collected and used in the kilns as combustible material as well as used tires from garages and parking lots and waste from health-care activities from the internal infirmary. Scrap metal is sent out for recycling. Raw material residues (as well as waste clinker and cement) are collected and recycled in the process at a rate of 90%. Fuel and hydrocarbon storage areas are equipped with oil/water separators.
Wastewater Management.
There are few wastewater sources at the plant other than sanitary facilities. Sanitary wastewaters are directed to septic tanks that are regularly maintained. Liquid waste from workshops or spills are collected in drains for energy recovery. Stormwaters from the plant are collected in drains discharging in an onsite basin, then overflow without pre-treatment to an open canal outside the site (regularly scraped by SOCOCIM). Kiln 6 project installations will be equipped with a stormwater drainage system equipped with grates to minimize the quantity of suspended solids in the water, connected to the existing network. As part of the kiln 6 project, there is a plan to improve rainwater recuperation in the quarry and add treatment (filtration) for improved use in the plant. Stormwaters from the quarry are drained to lakes located within the quarry, to be reused within the process (for firewater and dust suppression mainly). SOCOCIM will update the documentation on stormwater management and treatment at the site, as well as its monitoring program and will identify any action needed to align with Senegalese standards and WBG EHS Guidelines (ESAP #10).
Hazardous Materials Management.
The main hazardous materials in production include energy sources (coal and pet coke, fuel), engine oils and lubricants, laboratory materials. Hazardous materials storage and the gas fuelling area are equipped with secondary containment. Emergency response equipment including absorbents is available. During construction, hazardous materials will include fuel, lubricants, hydraulic fluids, paints, solvents, concrete additives, forming oils and detergents. The construction ESMMP includes measures for the proper storage and handling of hazardous materials.
Quarry Closure & Rehabilitation.
Some (limited) sections of the quarries are rehabilitated as the exploitation works progresses. SOCOCIM prepared quarry closure and rehabilitation plans that will be finalized to align with WBG EHS guidelines and Good International Industry Practice (GIIP) (ESAP #11).
PS4: Community Health, Safety and Security:
Infrastructure and Equipment Design and Safety.
The project ESIA includes a Hazard Study to assess technological risks associated with the new kiln 6. The study assessed major accident scenarios such as vehicle accidents and fires at combustible storage areas (e.g., tires, biomass), the coal mill, silos, and conveyor belts. Results indicated no off-site effects and that the organizational, prevention and protection measures in place (such as fire detection, alert and firefighting equipment and procedures) are adequate to mitigate the risk.
Community Health and Safety.
As described in the PS3 section above, the operation of the plant and quarries has the potential to cause air quality, noise and vibration impacts in the neighboring communities. SOCOCIM commissioned additional impact assessment studies to further evidence the impact of the kiln 6 project on ambient air quality, noise and vibrations and identify mitigation measures to align with the requirements of the WBG EHS Guidelines. SOCOCIM has disseminated the findings of these assessments to the nearby communities and will continue to monitor air quality, noise and vibration levels and track any related grievances via the community grievance mechanism (refer to ESAP #10).
Transport and traffic safety.
The majority of site-related transport routes pass through the already busy public roads of the nearby Rufisque settlement. SOCOCIM owns some vehicles used for bulk product transportation and outsources haulage trucks for raw material transport from the quarries to the plant. Transport of cement products in bags is the responsibility of the buyers.
SOCOCIM established a transport safety protocol, which identifies the site-specific loading/unloading risks within the plant and proposes associated mitigation measures. The complementary impact assessment study on road traffic shows that kiln 6 project will result in an increase in heavy truck traffic, but SOCOCIM contribution to the global road traffic in the study area will remain relatively low (about 3% of the global traffic). SOCOCIM will enhance existing protocols by developing a traffic and transport management plan to address aspects of travel planning, vehicle conditions/management, driver certification, training/awareness, documentation of road incidents, selection and control of transportation suppliers to mitigate the potential community health and safety impacts (refer to ESAP #3). In addition, Traffic and transportation-related accidents will be compiled and analyzed and mitigation measures will be established in in alignment with WBG EHS Guidelines (ESAP # 12).
Security Personnel.
The Company’s security is provided by two third-party contractors employing approximately 335 unarmed security personnel distributed across two daily shifts. Private security is predominantly responsible for access control, asset protection and monitoring of strategic points around the plant, the quarries and other facilities. Security risks are mostly related to potential theft, trespassing and safety related issues at the plant and quarries. SOCOCIM has security procedures for receiving and managing customer trucks onsite and registering visitors. Procedures will be expanded to cover the security management of the quarries and interfacing with communities (ESAP #3).
