PS5 Land Acquisition and Involuntary Resettlement does not apply as BHC’s Dong Nai Sugar Refinery plant and the Tay Ninh site were established on leased government land in 1969 and 2001 respectively. Both sites are well fenced and there would not be any physical or economic displacement due to this project.

PS8: Cultural Heritage does not currently apply as no potential cultural heritage areas have been identified or impacted within the Project’s Area of Influence through document review and site visits.

This is a Category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability, as the proposed project is expected to have limited adverse E&S risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures, as described in the following sections. Key E&S risks and issues for this investment are: (i) capacity and Environmental and Social Management System (ESMS) undertake the project aligned with IFC PSs including standard operation procedures and procedures for dismantling, transport and re-installation of existing plant/equipment; (ii) labor and working conditions, particularly relocation, accommodations, grievance mechanisms, and occupational health and safety (OHS) and oversight management of construction contractors, (iii) energy and resource efficiency; (iv) fire hazard and emergency preparedness and response; (v) stakeholder engagement and grievance mechanism; (vi) Supply chain management for raw sugar.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental & Social Policies. BHC adopted the E&S corporate-level policies, including the (i) Environmental Policy (2020); and (ii) Policy of Management System (2020), and tailored to fit their businesses in Vietnam. The policies were endorsed by BHC senior management team. These policies partially align with IFC PS with notable gaps, such as the lack of commitments on managing social risks for all operations of BHC. As part of a potential investment with IFC, TTCS has developed and issued a Sustainable Development Policy dated 24 July 2023, replacing the Policy of Management System (2020), and applicable to all business units and staff of the corporate. The Sustainable Development Policy has explicit commitments to comply with applicable national laws, and requirements of voluntary management system standards, IFC PS and WBG General EHS Guidelines, including the commitments towards managing social risks (e.g., grievance mechanism, right to voluntarily join worker unions, prohibition of child labor and forced labor, and adequate training/safety equipment). BHC will communicate its Sustainable Development Policy to all employees and contractors and relevant stakeholders, disclose on its website (ESAP#1.1).

Identification of E&S Risks and Impacts. BHC identify and manage E&S risks and impacts associated with their sugar processing and refining operations in line with applicable national standards and E&S regulatory permits and requirements, independently audited assessments based on customer requirements, and those from international voluntary standards. E&S risks and impacts are identified through formalized auditing programs and informally through frequent inspections. All the internal/external audits and inspections are summarized into documented corrective action plans with address timeline and responsible unit. The regulatory environmental and social impact assessments (ESIAs), however, did not follow the content, detail and rigor required by IFC PSs. The major gaps identified include lack or insufficient impact/risk assessment and mitigation/preventive plans and procedures for (i) the relocation activities; (ii) potential sugar dust fire and explosion; (iii) community health and safety (e.g., transportation safety, fire safety); and iv) supply chain E&S risks. BHC will develop an IFC PS-compliant ESIA to address the impacts from the relocation of the sugar refinery from Dong Nai to Tay Ninh. The new ESIA should address key community concerns related to (i) dust and fly ash; (ii) construction and operational noise; (iii) odor from wastewater discharge; (iv) temporary traffic risks of equipment relocation; and (v) any impacts from the decommissioning of the facilities in Dong Nai. The ESIA will also include a quantitative risk assessment (QRA) for fire and explosion risk, particularly from organic/sugar dust, for the sugar refinery plant in Tay Ninh, and provide a corrective action plan (CAP) for the upgrade of its fire and explosion prevention system, as required, with time-bound implementation. BHC will disclose the ESIA documents locally and on its website. BHC will update its ESMS to align with IFC PSs by reviewing and implementing all supplementary risks/impacts assessment, and management measures, including community health and safety (refer to ESAP#4.1); and supply chain E&S risk assessment (refer to ESAP#1.7). BHC will prepare an implementation plan to fulfill all E&S Action Plan (ESAP) requirements (described in the following sections) with timelines and committed CAPEX/OPEX, endorsed by senior management. (ESAP#1.2).

E&S Management System (ESMS) and Programs. BHC has established and been certified for ISO 9001:2015 (Quality MS), ISO 14001:2015 (Environment MS); ISO 45001:2018 (OHS MS); and FSSC 22000:2018 (Food Safety MS). BHC have respectively developed EHS-related management procedures, adopting the corporate-level system, covering standard operating procedures (SOPs) and work instructions, internal codes of EHS performance, inspection programs, human resources management, etc. However, as mentioned above, the current E&S management program lacks assessment processes and measures for various operational risks and impacts of BHC (e.g., organic dust explosion, community health and safety, supply chain). BHC will develop (i) specific E&S management plan (ESMP) to address the impacts from the sugar refinery plant relocation as part of the IFC PS-compliant ESIA; and (ii) specific E&S management programs as described in below sections to ensure compliance with IFC PSs and its own corporate E&S requirements (refer to ESAP#1.2).

E&S Organizational Capacity/Competency. BHC’s Quality, Health and Safety, and Environment (QHSE) department is responsible for ensuring compliance with corporate EHS policy and implementation of plant’s EHS management programs, with the support from HR staff (Operation Department), Production Department, and Procurement Department. The QHSE department reports directly to the plant’s general manager and the corporate QHSE. The QHSE team at BHC consists of (i) the QHSE Manager; (ii) Head of HSE; and (iii) five other supporting staff. BHC expects additional onsite EHS/OHS staff and capacity to manage E&S aspects and to implement the attached ESAP at both Dong Nai and Tay Ninh facilities. BHC has one HR staff to carry out paper works including filing and statutory registration works respectively, with support and guidance from the corporate HR department in the process of recruitment. As part of this investment, BHC will develop a staffing strategy mapping to identify (i) the additional number of staff needed; (ii) roles and responsibilities; and (iii) the necessary qualifications and skills required to effectively implement the EHS/HR management programs and fulfill the requirements set in the ESAP. At minimum, BHC will ensure to have one EHS Manager at each of its facilities in Dong Nai and Tay Ninh. This EHS Manager will be responsible for developing EHS staffing strategy mapping to identify sufficient supporting E&S staff, focusing on OHS capacity, to manage E&S risks at each facility (ESAP#1.3).

EHS Training. BHC provides mandatory internal and external EHS induction training to all sugar processing workers, including permanent employees, contractors and service providers in accordance with the national regulations or based on the operation needs. A training plan is prepared and approved annually, and record/evidence of provided trainings are kept to tracking the complete implementation. Training programs include (i) regulatory OHS requirements (e.g., workplace hazard identification/risk assessment), and specialized trainings (e.g., first aid, fire prevention and firefighting, food safety) by external service providers; and (ii) internal departmental specific training (e.g., HR policies, internal safe operation and maintenance procedures, including lockout tagout, permit to work, equipment safety procedures, reporting/recording accidents, internal monitoring/audit). The training plan also includes daily/monthly refreshers trainings. Contractors and visitors are also required to attend mandatory OHS induction. As part of this investment, BHC will review and update its EHS training plan to integrate relevant trainings required related to the IFC PS-compliant ESIA/ESMP for the sugar refinery plant relocation, the updates of E&S policy, technical and procedural updates and management practices required as part of the ESAP (e.g., water & energy saving, supply chain management, dust explosion prevention, etc.). In particular, BHC will provide a specific training for its EHS staff regarding IFC PSs requirements and WBG sector specific EHS Guidelines (ESAP#1.4).

Emergency Preparedness and Response (EPR). BHC has emergency response procedures (ERP), fire prevention and firefighting plans in place, prepared by QHSE teams and approved by relevant authorities. The emergency response team established with clear role and responsibilities. The refinery is stationed with 24/7 trained firefighting teams. Fire drills are carried out once per year with participation from firefighting police in accordance with local regulations, and one internal fire drill per year. Firefighting equipment are checked and tested on a monthly basis. Fire prevention and firefighting system including fire extinguishers and fire hydrant system and protection systems such as sprinklers, fire and gas detection systems in processing areas, storage warehouse and power plant are provided/installed as recommended by the WBG General EHS Guidelines at high fire-risk areas at the BHC facilities. No fire incidents occurred in the last five years at existing facilities. However, as mentioned above, the risk of sugar/organic dust explosion has not been fully assessed and has not been considered as an emergency scenario at BHC. BHC will update the facility-level ERPs, including procedures to manage Organic Dust Fire and Explosion, as required, based on the outcomes of the ESIA’s QRA (ESAP#1.5).

E&S Monitoring & Reporting. BHC maintains various E&S monitoring and reporting mechanisms as part of their ESMS. Specific reports are prepared to meet the requirements from various governmental authorities and voluntary standards’ auditors. Internal quarterly and semi-annual reports include contents of QHSE aspects, including environmental quality (emissions, wastewater, noise, soil, waste/hazardous wastes, sludge), QHSE key performance indicators (KPIs) and implementation status, HSE risks identification and corrective actions. Instant software applications (e.g., WhatsApp, Viber) are used by QHSE teams as an immediate intervention to take quick correction actions for readily addressable HSE or operation issues identified on daily inspections. Going forward, BHC will ensure using formal daily monitoring, reporting and corrective action tracking platforms instead of software applications (e.g., Whatsapp or Viber) (ESAP#1.6).

Supply Chain: BHC has a supply chain department responsible for yearly planning and purchasing. BHC imported raw sugar for its refinery operations through Global Mind Commodity Trading Pte. Ltd. (GMA), another TTCS’ subsidiary in Singapore. GMA purchases and supplies raw sugar to BHC from various international sugar traders through a trading platform of Intercontinental Exchange, Inc. (ICE). From July 2023 to June 2024, BHC sourced the majority of raw sugar from Australia, and to some extent from Thailand and Laos. BHC adopted the TTCS’s Suppliers Code of Conduct (SCOC), which is generally aligned with IFC PS requirements on supply chain. BHC’s current supplier assessment procedure involves either document reviews (e.g., Bonsucro and equivalent certifications and reports) or onsite direct verification of origin, focuses on quality aspects and certain E&S aspects such as E&S permits, waste/effluent management and PPE provision. Going forward, BHC will conduct an E&S risk assessment associated with its above-mentioned primary raw sugar suppliers against IFC PS1, PS2 and PS6 supply chain requirements and not source sugar from high-risk suppliers identified through the risk assessment (ESAP#1.7). BHC will formalize a supply chain management system and procedures. The supply chain system and procedures will be implemented from mid-2025 and include (i) adoption of TTC AgriS’ Supplier COC; (ii) traceability system; (iii) supplier risk assessment screening procedure on the risks from harmful use of child labor, forced labor, OHS aspects and conversion of natural/critical habitat; (iv) training requirements; (v) supplier monitoring, auditing, verification system and reporting requirements; and (vi) define roles and responsibilities. The supply chain system and procedures will be extended to all suppliers, including those providing biomass materials for future biomass boilers. BHC will conduct monitoring of suppliers for verifying their compliance with contractual requirements, including child and forced labor and safe working conditions and no deforestation requirements (ESAP#1.8).

PS2: Labor and Working Conditions

Workforce. BHC employed 431 employees in Vietnam. All workers at BHC are direct employees and are all Vietnamese, including those working in catering, gardening, and security.

Human Resource Policy and Procedures. TTC Group has recently (in 2022) completed an upgrade of its corporate-level human resources (HR) policies and procedures for consistency with IFC Performance Standard 2 (PS2) requirements. These updated policies and procedures cover hiring and recruiting, probation, working hours and minimum age, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and dismissal, leave and other benefits, and retirement. The corporation has policy requirements set out regarding the minimum working age for contractors and sub-contractors, and developed a contract template articulating these requirements in legal form.

BHC has adopted TTC AgriS’ HR policies and procedures. All direct employees have access to HR documentation and payroll systems, documents related to HR policies and procedures. As part of IFC's investment, BHC will formalize TTC AgriS’ position on gender-based violence and harassment (GBVH) and developing related procedures applicable to all workers (ESAP#2.1) and will communicate these requirements to all its workers, contractors and key suppliers.  HR staff will be trained on how grievances received on GBVH are handled, respecting the confidentiality of the survivor, and ensuring a survivor-centric approach.

Working Conditions and Terms of Employment: BHC has two types of direct employment contracts: indefinite-term contracts and termed contracts. BHC has adopted a corporate salary schedule that sets out the pay for distinct categories of workers. The minimum wage at BHC aligns with the statutory minimum wage. All newly recruited employees are required to sign a termed employment contract upon entering employment. This contract includes details relating to conditions of employment, such as wages, working hours, paid leave, employee rights, benefits, social security funds, and duration, in accordance with labor laws and TTCS HR requirements. The termed contract can be renewed once, after which staff will enter permanent employment with an indefinite-term employment contract.

Terms of employment - Overtime hours. In Vietnam, the normal working hours are forty-eight (48) per week, with overtime limits of 30 hours per month and 300 hours per year. Dong Nai refinery workers work in 3 teams with 12-hour per team shift, and each team have 24 hours of rest before taking their next shift. Workers work 56 hours per week and receive regulated premium rates for overtime. All employees receive a daily summary of hours worked and categories of overtime hours in Vietnam and use it to check the payment they receive at the end of each month. The weekly 8 hours of overtime are within the limits permitted by Vietnam labor law but may exceed the monthly and yearly limits. BHC will seek a regulatory exemption from overtime limits in the short-term and develop a management program to reduce working hours to a legally acceptable level if the current overtime hours exceed the limits (ESAP#2.2). The working hours arrangement in Tay Ninh will be established in line with regulatory requirements, including the overtime hour limits.

Workers Organization. BHC recognize and respect employees' right to form trade unions. A trade union was established in BHC. The union has a Workers' Representative Committee (WRC), with the chairperson and vice-chairperson elected directly by the workers and the rest of the members assigned by the unions from the body of workers. The election takes place in a town hall gathering of workers, with credible witnesses (including representatives from local union and provincial union) and is followed up by a verification process. The WRC serves as a forum for communication and consultation on working conditions, working hours, company regulations, recreational activities, and welfare.

Non-discrimination and Equal Opportunity. BHC has adopted a corporate policy of zero tolerance for discrimination, which is outlined in their Code of Conduct. BHC has 40% female employees. BHC has set the same terms of employment for male and female employees in recruitment procedures and training plans to prevent gender discrimination.

Protecting the Workforce. BHC has strict provisions prohibiting child labor and forced labor. The company has set the minimum age of employment at 18 years old. To ensure compliance, all potential direct employees are required to present proof of age in the form of an official government-issued document. BHC has a process to verify through document review, observation and employee interviews.

Retrenchment/relocation. The TTC AgriS has a retrenchment policy consistent with IFC’s PS2 requirement in place. BHC has no plan to retrench its workers. In response to a request from the Vietnamese governmental authorities, BHC is preparing to relocate its refinery facilities and boiler from the Dong Nai site to the Tay Ninh site, which is located 120km away. The actual move of equipment is expected to take six months, during which production workers will either assist with the equipment move or attend training sessions. BHC has no plan for retrenchment during this relocation process, however this will be confirmed in the ESIA and if needed mitigation measures developed. BHC is developing a relocation package for its workforce, including free accommodation, home travel allowances, and incentive benefits. However, it is expected that some workers may not want to relocate. In such cases, BHC will offer alternative positions within the company or a separation package in accordance with national labor laws and regulations. BHC will develop a  workers' relocation plan with clear objectives and strategies, share essential and meaningful information in a timely manner with workers such as 1) option to relocate, and a relocation package, 2) options of alternative positions without relocation on equivalent terms and conditions of employment; 3) a separation package per the law regulating involuntary separation or retrenchment, and 4) a clear consultative and decision making process centered around joint problem-solving and a specific channel to raise questions and concerns regarding the relocation (see section below). All proposals put forward during the consultation will be registered and must be seriously considered and reflected in the relocation package (ESRS#2.3). The consultation approach ensures that workers are fully informed with prior notice and involved in the relocation process in which their concerns and proposals are considered. The company will a) develop a retrenchment guideline (in the event of future retrenchment); b) develop a retrenchment plan for employees who might be retrenched in the relocation process if retrenchment is inevitable. The relocation of staff/employee (and any potential retrenchment) will be monitored by an independent third party to ensure compliance to PS 2 requirements (ESAP#2.4).

Worker’s Grievance Mechanism (WGM). TTC AgriS has a corporate labor grievance mechanism framework that specifies the process for managing grievances. BHC developed a WGM which enabled its employees to raise their grievances through HR personnel, the trade union, or through grievance collection boxes located in places where workers have easy access to, or hotline. All received grievance are documented as per grievance handling procedure and resolution status. This grievance mechanism will also be used in the process of Dong Nai plant relocation (refer to ESRS#2.3), as a platform to hear and address workers concerns, and grievances. BHC will disclose how grievance could be raised, the process of re-addressing and timeline, and confidentiality and non-retaliation provisions. When grievance related to GBVH, BHC will follow through the GBVH related procedures (refer to ESAP#2.1 above) and refer to HR personnel who had been trained to handle sensitive issues of employees, including third-party workers.

Workers Accommodation. BHC will provide free accommodation to all direct employees after relocated to Tay Ninh. BHC will: 1) develop a worker accommodation standard checklist in line with IFC/EBRD Workers’ Accommodation: Processes and Standards; 2) incorporate the worker accommodation requirements in the BHC’s Dong Nai relocation plan (refer to ESAP#2.3).

Occupational Health & Safety. BHC has established an OHS management system (MS), which has been certified for ISO 45001:2018. Workplace environment is monitored annually at specific production locations in the sugar processing facilities for relevant parameters, including relevant toxic gases (e.g., CO2, CO). BHC will re-assess and update the OHS management plans/SOPs to (i) include provision of monitoring and reporting schemes and management review (refer to ESAP#1.6); (ii) review and apply monitoring methods and thresholds for applicable workplace environment parameters to ensure compliance with national standards or the WBG General EHS Guidelines (e.g., methods from OSHA’s database and ACGIH/OSHA thresholds), whichever is more stringent; (iii) revise incident investigation procedures with recording and triggering investigation of all incident cases (including first aid incidents, near misses) with clear guidance, template and a root cause analysis; (iv) implement an asset integrity and maintenance plan to ensure integrity and reliability of machinery and equipment; (v) update the permit to work (PTW) Procedure with detailed checklist for PPE requirements, required inspection, list of competent PTW granting authorization; and (vi) monitor the quality and frequency of training programs emphasizing on using PPE and designated smoking area (ESAP#2.5 ).

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency. The BHC’s facility in Dong Nai is currently running on a roof-mounted solar power system with an installed capacity of 768.6kWp connected to national grid. The coal-fired boilers will be replaced by biomass boilers when BHC relocates to Tay Ninh Province. Key performance indicators (KPIs) relating to energy usage and efficiency (e.g., steam and power consumption per tons of sugar) are annually set and be monitored/recorded to evaluate the performance at BHC facilities, mainly for cost reduction purposes. Calculated water use efficiency from measured data that BHC used 5.74 m3 of water per ton of sugar product in 2022, including pipe water for refinery process and river water for cooling purposes. This is comparable to the water usage footprint of sugar refineries in the region. Going forward, BHC will develop and implement systematic energy and water use efficiency/conservation management plans and set the annual resource efficiency targets for all operations toward achieving the good international industry practices (GIIPs) benchmarks applicable to sugarcane refinery production (ESAP#3.1).

Greenhouse Gases. BHC conducted annual GHG emissions estimate based on data of annual fuel combustion (coal, natural gases and diesel oil, purchased heat and electricity), industrial wastes, water consumption and wastewater generated. Calculated 2022 GHG emission for BHC amounted to 47,056  tons CO2 equivalent (tCO2eq), including (i) 653 tCO2eq from Scope 1 emission (i.e., the consumptions of Diesel oil and natural gases, water pumping and from WWTP); (ii) 46,404 tCO2eq from Scope 2 emission (i.e., purchased heat from coal combustion and electricity from national grid); and (iii) 228,174 tCO2eq from Scope 3 emission (third-party solid waste treatment and water supply pumping). BHC will include annual GHG emission and reduction measures and disclose through the annual corporate Sustainable Development report.

Air Emissions. The main sources of point source air emissions are from coal-fired co-generation boilers/power plants. BHC has two coal-fired boilers with total capacities of 25- and 30-tons steam per hour, which provide steam mainly for sugar manufacturing plant and surplus steam for turbine power generation (2MW). BHC installed cloth bag dust filter system as emission treatment. The stack air emission monitoring is being conducted on quarterly basis and real-time continuous monitoring system for point source air emission, while ambient air quality is being monitored in semi-annual basis. The latest results were in general in line with Vietnam national standards and WBG EHS Guidelines for Thermal Powerplant (for small combustion facilities). The ambient air quality was also in line with the WHO Ambient Air Quality Guidelines referenced in WBG General EHS Guidelines. The coal-fired boilers will cease from operation and be replaced by biomass-fired boilers at Tay Ninh facility expected in 2027.

Noise. BHC carries out noise monitoring at the same frequency and locations for ambient noise at sensitive receptors close to refinery except at night-time. Monitoring results met WBG General EHS Guidelines’ noise level values. However, ambient noise monitoring method is not in accordance with the WBG General EHS Guidelines of the minimum 48 hours continuous monitoring. BHC will conduct at the minimum 48 hours continuous ambient noise monitoring, to ensure the compliance with national regulations and WBG General EHS Guidelines’ noise level values for both Dong Nai and Tay Ninh sites (ESAP#3.2).

Effluent Treatment Plant. BHC’s wastewater treatment plant (WWTP) is being monitored on monthly basis and real-time continuous monitoring system. Treated effluent is discharged directly to the Dong Nai River system. The latest results were in compliance with Vietnam national standards and WBG EHS Guidelines. The effluent from the Tay Ninh facility will be discharged to a local natural spring. BHC will assess and maintain the compliance of the WWTP with national effluent standards and WBG EHS Guidelines for Sugar Manufacturing as part of the ESIA development for Tay Ninh facility (ESAP#3.3).

Waste Management. BHC manages wastes in compliance with national regulations and WBG EHS Guidelines by signing contracts with licensed waste handling contractors.

Pest Control. BHC relies on a licensed third-party service provider for pest control at the refinery with appropriate due diligence and control process. BHC will request commitments from pest control service providers to not using/distributing WHO Class Ia/Ib and Class II products, or those are subject to international bans or phase-out, and conduct due diligence to ensure the compliance (ESAP#3.4).

Potential site contamination. The relocation of the sugar refinery plant to Tay Ninh may leave some potential site contamination legacy issues at the Dong Nai site from its past operations. These may come from long term use of hazardous materials, including fuel or coal storage. BHC will commission a third-party consultant to conduct (i) a Phase I environmental site assessment (ESA) to determine whether there were contamination issues at Dong Nai site; and (ii) a Phase II ESA and cleaning up the site, if required (ESAP#3.5). The ESA should be conducted in conformance with international standards such as ASTM International Standard Practice for ESA/Standard Guide for ESA. 

PS4: Community Health, Safety & Security

Road Traffic Safety. BHC is currently contracting third-party transportation services with approximately 80-100 15-ton trucks travelling 30-50km distance to and from BHC facilities to transport imported raw or produced sugar from local ports or to refinery. BHC will assess and manage the traffic safety risks from sugar transportation toward the community as part of the PS-compliant ESIA study for the new refinery site (ESAP#4.1). The ESIA will also assess temporary traffic risks of transporting equipment from Dong Nai to Tay Ninh site and identify feasible plan to minimize the impacts to communities along the roads. 

Security Personnel: The security force at BHC includes 14 guards in Dong Nai and 4 in Tay Ninh. All security personnel are direct employees with over 10 years employment at BHC. BHC’s security guards are unarmed and are mainly responsible for access and perimeter control and general surveillance at sites. They received general training, such as firefighting training, first aid and food safety training and how they interact with the security guards and with the nearby communities. 

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

BHC purchase sugar in regions where there is a risk of significant conversion of natural and/or critical habitats, including Vietnam, Australia, Thailand, Laos and potentially Brazil (see PS1 Supply Chain for more details). To manage risks of habitat conversion, BHC has recently adopted a Supplier Code of Conduct (COC) that includes commitments to not convert natural/critical habitats.  Regarding BHC’s supply chain, a supply chain mapping exercise is to occur to understand risks of natural/critical habitat conversion (ref. to ESAP#1.7). Where it is identified that suppliers are not currently certified and do not have measures in place to meet BHC’s commitments, including commitments not to convert natural and/or critical habitat values, those suppliers will be phased out and alternative suppliers will be identified and contracted by the end of 2025 (refer to ESAP# 1.8).                                                   

TTCS has a community engagement policy and required each of its subsidiaries to develop a tailor-made Community Engagement Plan (CEP). TTCS also provided a step-by-step structural guidance for the development of such plan, which includes mapping and listing all stakeholders in the areas of influence of its subsidiaries’ operations; strategy to maintain regular engagement and information disclosure; staff community relations personnel and requirement on their language skills; mapping and register E&S issues, and development of mitigation measures; and a grievance mechanism logging and resolution system.

Following the same requirement, BHC will develop a SEP for its engagement with stakeholders during the relocation process and resume of operation in the Tay Ninh site, as a part of ESIA and ESMP development. stakeholder mapping must include communities, households located close to the Tay Ninh plant who will be impacted by the plant operation or any groups or communities who will be impacted by the Dong Nai plant relocation (ESAP#8.1). which will include a grievance mechanism (GM) for BHC to receive and address grievances.