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
Environmental and Social Assessment and Management System. Eni manages the corporate E&S risks of its value chain operations through the implementation of an Internal Regulatory Framework (IRF) which includes Health, Safety and Environmental (HSE) policies and Standard Operational Procedures (SOPs) that define the approach to HSE risk management and performance monitoring, and all Eni subsidiaries are expected to adopt and implement the IRF. These policies and SOPs are aligned with IFC PS and Good International Industry Practice (GIIP), such as the WBG EHS Guidelines. All the three country-level Ene subsidiaries will adopt and implement Eni’s IRF to their respective agri-feedstock production and Agri Hub operations as appropriate, including to manage E&S risks and impacts of the existing and planned Agri Hubs and agri-feedstock supply chains and associated occupational and community health and safety risks, proportionate to the nature of the operations and Ene’s operational control and leverage (ESAP#1).
Identification of Risks and Impacts. Eni’s IRF requires each Ene subsidiary to carry out, in relation to their activities, a process of identification and assessment of potential E&S risks and impacts. For new business projects, Eni has developed an Environmental and Social Impact Assessment (ESIA) best practice technical guideline document on environment, social, and OHS impact assessment to be implemented by all its subsidiaries. Further, Eni has also developed an agri-feedstock environmental, human rights/social and health impact assessment (Agri-ESHIA) guideline (2025) with the aim of evaluating potential impacts of their agricultural initiatives on environmental, health and social (including human rights) perspectives. The three Ene subsidiaries will integrate these two guidelines into their HSE management systems (ref. ESAP#1) and implement them as part of the design of their operations.
For the Agri Hubs, prior to the construction of the Loudima Agri Hub (Congo) and the future Agri Hub in Mozambique, ESIA Studies were conducted, in compliance with the above-mentioned Eni ESIA technical guideline and the respective local laws and regulations. Ene has successfully obtained the requisite environmental permits for both sites. Construction-phase E&S risk identification and management at Loudima Agri Hub was guided by the approved ESMPs, while the operation-phase ESMPs are discussed under “Management Programs” sub-section below. As the construction of the Agri Hub in Mozambique is yet to start, Ene has not started the implementation of the ESMPs for this operation. For the planned outsourcing of the agri-feedstock crushing services in Angola and Mozambique, Ene Angola and Ene Mozambique will each develop and implement an E&S due diligence template aligned with Eni’s IRF, its 2025 ESHIA Guidelines, IFC PS requirements, and WBG EHS Guidelines, and use the template to assess E&S risks prior to the formalization and signing of crushing contracts (ESAP#2).
For the agri-feedstock supply chain, Ene conducts an initial certification (ISCC or Italian National Scheme)-aligned risk identification and assessment process for each commercial farm and identified gaps are closed within agreed timeframes before the first formal independent ISCC audit. All the potential agricultural counterparties (aggregators and commercial farmers) also undergo a dedicated counterparty human rights screening and are requested to sign the Agri-feedstock Code of Conduct. Once a commercial farm is qualified as a supplier and the relevant contract is signed, Ene conducts periodic internal monitoring through their sustainability officers and field agronomists. Specific contractual clauses on respect for human rights are included in the agreement. The independent ISCC certifier conducts recurrent farm audits at the commercial farms (including a representative sample of their respective smallholder farms, if also acting as an aggregator) to maintain their ISCC certification status. The primary responsibility for E&S risk assessment and compliance assurance for all smallholder farms lies with the commercial farms, as per their aggregator role, and carried out through their field officers. The scope of the IFC PS risk assessment requirements is more stringent than the current scope of ISCC-aligned assessments (including Principles and Criteria), especially on complementary farm activities (e.g. farm equipment repair and maintenance activities, security, general labor and working conditions and stakeholder engagement/grievance management).
Going forward, Ene Angola, Ene Congo and Ene Mozambique will each (i) develop an aggregator/commercial farm and smallholder farm E&S risk assessment template that merges appropriate schemes certification requirements, Eni’s ESHIA and IFC PS requirements; (ii) conduct E&S risk assessment for all current aggregators/commercial farms as per the template in (i) above and develop a time-based action plan to address identified gaps; and (iii) develop a schedule for periodic smallholder E&S risk assessments by the aggregators/commercial farms (ESAP#3). The risk assessment template will be integrated into the Farm Handbooks for continuous E&S risk monitoring.
For regular operational aspects for Ene staff like road transport, health and safety, operational security, waste etc. in each country, risk identification and assessment process is done at the country level in line with the existing Eni procedures already developed for the country.
Management Programs. The three Ene subsidiaries are at different phases of development and implementation of their respective E&S risk management system and programs. They currently partly rely on existing Eni corporate procedures implemented by the in-country oil and gas subsidiaries. As already required in ESAP#1, Ene subsidiaries will further develop their respective company-level ESMSs and programs for their Agri Hubs and agri-feedstock sourcing operations. The Loudima Agri Hub in Congo is in the process of drafting its operation-phase E&S management plans and procedures. In the agri-feedstock supply chain, each selected commercial farm has developed and implemented a Farm Handbook that guides key agronomic and E&S requirements for farm management and crop production. In addition, some commercial farms have E&S management plans that cover specific E&S topics e.g. waste management, water management, pesticide use, soil management, biodiversity management and dust management. Going forward, (i) Ene Congo will put in place the best endeavors to ensure the Loudima Agri Hub draft E&S management plans and procedures meet Eni IRF and IFC PS requirements, including the WBG General EHS Guidelines (ref. Vegetable Oil Production and Processing); and (ii) following the E&S risk assessments to be conducted as per ESAP#3, every commercial farm/aggregator will develop or update their respective E&S management plans and ensure that these cover material E&S risks in their respective portfolio of smallholder farms (ESAP#4).
Organizational Capacity and Competency. The respective Ene country project managers or general managers bear the overall responsibility and accountability for the implementation of the E&S risk assessment and management plans at the Agri Hubs (if applicable) and for the agri-feedstock production. Technically, the in-country Ene HSE and sustainability teams lead the effective implementation of the IRF, ESIA technical guidelines and certification (ISCC or other applicable according to EU-RED) requirements. Ene Congo and Mozambique have designated EHS and sustainability leads for the Agri Hubs and sourcing operations, respectively. Ene has developed E&S training material applied by all three subsidiaries to Ene field staff and core staff at the aggregators/commercial farms, to strengthen their skills and empower them as trainers. The training package covers key relevant E&S topics as required by IFC PS. E&S trainings with field staff and aggregators/commercial farmers are conducted annually and designed to strengthen their knowledge regarding environmental management, OHS and human rights in the agri-feedstock sector, reflecting the contractual expectations signed between Ene and the aggregators/commercial farmers. Ene Congo also conducts training induction to all Agri Hub workers, delivered through group toolbox and leadership talks, pre-task safety briefings and post-incident briefings. The EHS officers in Ene Congo and Ene Mozambique are conversant with the Eni IRF and related requirements. The sustainability officers and agronomists in each of the three countries demonstrated good understanding of the key E&S issues and have the role of monitoring these issues in the field. The commercial farms visited by IFC during this appraisal have designated sustainability and EHS leads whose competence can be improved through the above annual Ene-coordinated training courses. The smallholder farmers receive E&S technical guidance from the trained aggregators/commercial farms.
Going forward, (i) Ene Angola will recruit a competent resource-person to oversee the EHS risk assessment and management function for the business; and (ii) all three Ene subsidiaries will require the aggregator/commercial farmers to keep appropriate records of annual E&S trainings to their general workforce and to smallholder farmers in their respective supply chains (ESAP#5).
Emergency Preparedness and Response. All three Ene subsidiaries shared country-level Emergency Preparedness and Response Plans (EPRPs) for their general operations. Similarly, for the Loudima Agri Hub, Ene Congo has an EPRP that covers all key risks including fire, medical emergency, explosions, building collapse, equipment integrity failure, oil spills and security. The Agri Hub has an evacuation plan testing schedule (drill schedule) that covers all identified emergency scenarios and maintains a clinic and a nurse at each plant. Ene Congo also has working arrangements with government fire department and hospital facilities for cases of emergency. Some aggregator/commercial farms have also developed their own farm emergency protocols. Going forward, all three Ene subsidiaries will ensure that (i) Ene Mozambique will develop and implement an EPRP for its Agri Hub in Mozambique prior to its commissioning; (ii) Ene Congo will update the Loudima Agri Hub EPRP to cover climate emergencies (floods and heat stress), transportation-related incidents and hazardous material exposure scenarios relevant to agri-feedstock operations (ESAP#6). The adequacy of aggregator/commercial farm emergency protocols will be determined during the farm E&S risk assessments to be conducted per ESAP#3 above.
Monitoring and Review. Eni corporate IRF is reviewed as needed, and all updates are adopted by the subsidiary companies, as appropriate. The three Ene subsidiaries will consider any periodic IRF changes and adopt these to their respective HSE management systems, where appropriate for the nature and scope of E&S risks in their operations. Key operational E&S KPIs are set at the global level and tracked at the country level, and include health and safety, employee welfare, grievances, gender and diversity, training, industrial relations (employees in workers; organizations), waste, greenhouse gas emission, biodiversity impacts, pollution cases, occupational incidents and transport-related safety incidents. The reports by Ene subsidiaries are collected monthly in each country, reviewed and discussed at the country level for performance tracking, definition of priorities, and assignment of E&S related capital/operational expenditures. For the Loudima Agri Hub in Congo, the E&S management plans and procedures (ref. ESAP#4) will include a specific procedure for E&S monitoring and performance review at the plant level. For the agri-feedstock supply chain Ene relies mainly on certification-aligned monitoring and audit schedule. Going forward, all Ene subsidiaries will develop detailed agri-feedstock E&S risk monitoring and audit procedures aligned with Eni IRF and IFC PS (ESAP#7).
Agri-Feedstock Supply Chain. Ene Angola, Congo, and Mozambique source agri-feedstock primarily through commercial farming enterprises, some of which also act as aggregators of smallholder farmers. These commercial farms operate as formal business entities, typically with their own permanent workforce, mechanized operations, internal management systems, and ISCC certification responsibilities. Prior to onboarding commercial farms/aggregators, Ene subsidiaries implement ISCC-aligned procedures for risk assessment, and the key E&S requirements are incorporated into commercial agreements. The main criteria set for these farms include legal rights to land, soil quality, no land conversion after 2008, no ongoing or recent physical or economic displacement, no impacting key biodiversity areas (KBAs) or protected areas, or indigenous peoples’ lands. Within this Project, the feedstock will be sourced in agreement with aggregators/commercial farms on severely degraded land and from intermediate crops, including on underutilized, unused and abandoned lands.
Once onboarded, each aggregator commits to developing a Farm Handbook detailing operational and training needs to comply with Eni’s E&S risk management standards and align with ISCC certification requirements; and signs the Agri-feedstock Code of Conduct. For EU-RED III sustainability and traceability requirements, both commercial and smallholder farms are geo-referenced, and data shared with certification bodies. The ISCC certification of the commercial farms acting as aggregators cover their respective portfolio of smallholder farms. The aggregators/commercial farms also sign self-declaration forms committing to ILO’s fundamental labor rights and related core conventions. During the contract period, commercial farms/aggregators are expected to abide by ISCC Principles and ensure that smallholder farmers within their respective portfolio also comply with these Principles. Ene retains monitoring and audit rights under ISCC certification. The scope of Ene and ISCC audit reports include review of E&S risk management systems, including OHS, labor, biodiversity, resource (land, water) management, stakeholder engagement and on farm/community grievance mechanism. The audit process includes worker interviews.
In addition, Eni has developed an Agri-Feedstock Human Rights Framework to safeguard human rights within agricultural supply chains to complement the above supply chain E&S risk management measures. The Framework will be applied progressively in all the three countries. In this Framework, prior to onboarding an aggregator and/or a commercial farmer and before awarding a contract to them, Ene requires the potential counterparty to sign the declaration of acceptance of the Agri-Feedstock Code of Conduct - which sets out the key environmental, social and governance (ESG) minimum requirements that suppliers of agricultural feedstock must comply with across the value chain; and carries out risk-based human rights checks. In line with the provisions contained in Eni’s regulatory instruments on business integrity and human rights clauses, all agri-feedstock contracts must contain specific commitments on human rights. According to this approach, aggregator and commercial farmers are required to comply with international human rights standards and ensure that the same obligations are respected across their supply chain, including by their sub-contractors. They must adopt monitoring, grievance and reporting mechanisms and may be subject to audits conducted by Ene or third parties engaged by the latter. Non-compliance may lead to corrective actions, contract suspension or termination, and liability for damages.
To meet PS requirements for management of E&S risks in the agri-feedstock supply chain, Ene will implement the requirements in ESAP #3, ESAP#4, ESAP #5, ESAP#6 and ESAP #7. OHS requirements in ESAP #9 and labor requirements in ESAP #10 and #11 below will also be implemented to improve management of these topics among contractors and in the supply chain based on a reasonable, risk based approach and commensurate with Ene’s level of influence.
PS 2: Labor and Working Conditions
At the time of this appraisal, the three Ene subsidiaries had a total direct workforce of about 32 employees, 13 in Ene Angola, 11 in Ene Congo , and 8 in Ene Mozambique. Minimal increase in direct workforce is expected as the project implementation will rely mostly on contractor workers at the Agri Hub in Congo and Mozambique and field agronomists. Workers at the aggregator/commercial farms are typically expected to vary with seasons and production targets.
Human Resources (HR) Policies and Procedures and Terms of Engagement. Eni HR internal regulations are part of its IRF and provide principles and operating modalities according to which the activities of the HR process shall be managed. In addition, in line with Eni’s Code of Ethics, Eni’s Policy “Respect for Human Rights in Eni” outlines the approach on human and labor rights, and priority areas of commitment, coherently with the requirements of IFC PS2. These documents, together with the Eni’s Policy “Zero Tolerance against violence and harassment in the workplace”, are applied also to Ene and its subsidiaries according to the provisions established in Eni’s Policy “Regulatory System” and cover, among others, human and labor rights, such as commitments on freedom of association, provisions on non-discrimination and equal opportunity, prohibition of child labor, forced labor and zero tolerance to harassment at the workplace; and are aligned with PS 2 requirements. In accordance with this framework, all the three Ene subsidiaries have adopted the aforementioned regulatory instruments and developed dedicated procedures matching the Eni requirements to respective country labor laws.
The country level Internal Regulations have established working hours, attendance requirements, overtime approval procedures, overtime remuneration, annual leave, maternity leave, paternity leave, sick leave, salary arrangements and employee benefits. The Regulations specify maximum overtime limits, overtime compensation rates as well as annual and maternity leave entitlements broadly aligned with PS 2 requirements.
Workers Organizations. Eni’s Policy “Respect for Human Rights” and corporate HR policies make specific commitments on fundamental principles and rights at work, including freedom of association and collective bargaining. At the time of this appraisal, none of the Ene subsidiaries’ workforces at the Agri Hubs were unionized. The three Ene subsidiaries also reported that no past labor actions (e.g. strikes) have occurred in its processing operations.
Worker’s Grievance Mechanism. Eni’s corporate policies provide guidance for workers at subsidiary level on Grievance Remediation Mechanism (GRM) that are aligned with PS2 requirements. Eni also operates a corporate level whistleblowing management framework that is accessible to all stakeholders, including employees, and is aligned with PS2 requirements.
Child and Forced Labor. The three Ene subsidiaries comply with Eni corporate HR requirements and do not employ children at their operations. Additional requirements are provided under the third-party workers and supply chain sections below.
Occupational Health and Safety. The main OHS risks in the Agri Hub operations are chemical and hazardous material handling, physical activity/movements, working in confined spaces, hot works, heat stress, electrical installations, fire and explosion, noise, air quality, other occupational health and safety risks, and road transport and logistics. In the agri-feedstock supply chain, the key OHS risks are related to road transport, farming activities, and activities at the equipment workshops within the farms. Although it is still early to have a good trend on incidents and accidents at the Loudima Agri Hub, it is expected that incident/accident management will be as effective as in the operating Kenyan Agri Hubs where the incident rates are below the industry benchmark for grain and oilseed milling. PPE provided for the workers on work sites was adequate. Castor seed cultivation is currently at a pilot scale in Angola and Mozambique, and limited quantities of seed will be processed. Specific measures to mitigate health risks related to human exposure to dust released during castor processing and press cake handling at the Agri Hubs are already in place in the Loudima and Kenyan Agri Hubs where most of the processing will occur. To address potential release of process dust at the Agri Hubs, the designs of all Agri Hubs (and evidenced by the Loudima Agri Hub) will have air collection systems that filter the process air and collect resulting dust for re-feeding into the oil-cake formation systems. The field staff of the Ene subsidiaries/branches implement the established Eni’s IRF, including OHS provisions for road travel, personal protective equipment (PPE) use, communication and reporting – the key risk areas. At the commercial farms, OHS risks are partly identified and addressed within the Farm Handbooks and through the ISCC compliance requirements. The periodic ISCC-aligned training to the aggregators and commercial farms covers OHS aspects, including occupational health awareness and prevention measures. While there are efforts by aggregators and commercial farmers to cascade key OHS knowledge to their respective portfolio of smallholder farmers, the scope and consistency of implementation may vary across supply chains and operational contexts. Going forward, (i) Ene Congo will ensure that the E&S management procedures being developed for the Loudima Agri Hub includes adequate OHS risk assessment, management and monitoring procedures; and (ii) respective E&S management plans to be developed by each aggregator/commercial farm will address material occupational health and safety risks proportionate to the risks in their activities (ESAP#8).
Third Party Workers. Ene subsidiaries do engage Operations & Maintenance (O&M) contractors for some activities at the Agri Hubs and related activities (e.g. transport and security). The O&M contractors, according to Eni’s procurement process, are required to formally accept the Eni Supplier Code of Conduct which explicitly establishes, among other provisions, the obligation to respect human rights. To provide adequate instruction and enforcement of effective implementation of labor and OHS provisions, each Ene subsidiary will develop and implement a formal contractor’s E&S risk management procedure, including labor and OHS requirements for contracted security personnel and workers of the seasonal transport service providers (ESAP#9).
Supply Chain. As already indicated in PS1 section above, Ene Angola, Congo, and Mozambique source feedstock primarily through the commercial farms (for crops) and commercial aggregators, typically with their own ISCC certification responsibilities. Contextual risk findings for Angola, Congo and Mozambique indicate that the risk of child labor is high in smallholder agricultural settings as well as informal labor sector. The contextual risk findings also indicate that limited employment opportunities in Angola, Congo and Mozambique can drive certain indicators of forced labor. For this project, the seasonality in labor requirements and low transition of minors to higher education at household level can expose commercial farms and aggregators to laborers in the 14-17 years age bracket. The current scope of Ene farm audit reports includes review of incidences of forced labor, child labor, discrimination, abusive labor practices as well as some level of OHS risks identification and management.
As part of the Agri-Feedstock Human Rights Framework, it is expected that child and forced labor risks will be monitored and managed through periodic awareness activities on respect for human rights to aggregators and field visits undertaken by the field supervisors and reported to Ene management in case of critical issues identified. To further strengthen the oversight and prevention of child labor, decent working conditions and OHS risks in its supply chain and meet IFC PS2 requirements, the three Ene subsidiaries will, based on farm E&S risk assessments in ESAP #3 above, update the Farm Handbooks to capture procedures for verification of age of workers, incorporation of age-cohort based OHS risk assessments and subsequent requirements for minors working in the farms, expansion of limitations on minors to include all dangerous tasks beyond chemical exposure; include awareness measures related to occupational health and safety risks for young workers engaged in permitted agricultural activities; have mechanisms for review and sensitization on restriction of movement, coercion and indebtedness as additional indicators of forced labor; and institute mechanisms to monitor and report on human rights issues in their respective portfolios of aggregators/commercial farms and smallholder farms, per Eni Agri-Feedstock Human Rights Framework, (ESAP#10).
PS 3: Resources Efficiency and Pollution Prevention
Resource Efficiency. Ene follows GIIP in selection of technical equipment and operation of its Agri Hubs, and resource efficiency KPIs at the existing Kenya’s Agri Hubs comply with WBG EHS Guidelines for Vegetable Oil Production and Processing. To ensure consistent monitoring and efficient use of energy and water resources, the E&S management procedures for the Loudima Agri Hub will include resource (energy and water) efficiency management and monitoring procedures. For the outsourced crushing operations, Ene Angola and Mozambique will ensure that resource (energy and water) efficiency management and monitoring are developed and implemented by the respective facilities following E&S assessments (ref. ESAP#2). For the contracted commercial farms, Ene subsidiaries will ensure that the E&S management plans cover risks and mitigation associated with water and energy use at the farms (ref. ESAP#2). There is no current plan for irrigation at the commercial and smallholders’ farms for the production of agri-feedstock.
Greenhouse Gas (GHG) Emissions. Gross GHG emissions specifically pertaining to the Project (Scope 1 and Scope 2 emissions from Agri Hub operations) are estimated at well under 25,000 tCO2eq/year during the life of the Project. At the same time, the Project is expected to result in significant reduction in GHG emissions throughout the fuel value chain, including Agri Hubs, agricultural inputs, land use change, transportation, refining and processing and product transport to retail outlets. The total expected emission reduction from the Project is around 116,000 tCO2eq/year. This project is part of Eni’s GHG emissions reduction program, and the company will report annual certified GHG emissions from the Project to the public and shareholders.
Air Emissions. The main sources of air emissions are from ploughing and pesticide and fertilizer application at the farms, agro-processing at the Agri Hubs and road transport. Pesticide and fertilizer applications are periodic, and the emissions are minimal and localized. The Ene Congo’s Loudima Agri Hub is designed for mechanical oil extraction, hence Particulate Matter (PM10 and PM2.5) is the principal source of ambient air emissions from the operations – mainly from cleaning, screening, and crushing of oilseeds. The Agri Hub is equipped with dedusting system designed and installed to GIIP. This will be the case for Ene Mozambique’s Agri Hub. On stack emissions, the main sources at Loudima Agri Hub are the HFO-powered steam-generation boiler and the back-up generators. The Loudima Agri Hub is equipped with a dust collection system (per equipment manufacturer’s specifications) to manage dust from the closed processes. The Agri Hub had just been recently put in operation at the time of IFC visit hence no historical air emission record was available. Given the similarity in design with the Makueni Agri Hub in Kenya, whose latest PM emissions are at 19µg/m3 for PM 2.5 and 31µg/m3 for PM 10, it is expected that the same performance will be maintained at the Loudima Agri Hub. Project vehicles are only used as needed and adequately serviced to reduce excessive emissions; and the access road to the Loudima Agri Hub is tarmacked to minimize dust from trucks. To standardize and have consistency in monitoring and managing air emissions, the E&S management plans and procedures to be developed and implemented for the Loudima Agri Hub will include air quality management and monitoring procedures with appropriate sampling locations, monitoring schedules and monitoring scope, aligned with IFC PS. Ene will ensure that the planned Namialo Agri Hub and/or outsourced crusher have adequate air emission mitigation similar to the above. Management of emissions from road transport and pesticide application are discussed under PS4 below.
Noise. Similar to air emissions above, there are no historical noise monitoring data due to the recent operations at Loudima Agri Hub at the time of this appraisal. It is expected that noise values will be maintained within WBG General EHS Guidelines as the case in Kenyan Agri Hubs. Ene Congo will, as part of the E&S management plans and procedures to be developed for the Loudima Agri Hub, include noise management and monitoring procedures with appropriate sampling locations, monitoring schedules and monitoring scope (aligned to Table 1.7.1 of the WBG General EHS Guidelines).
Waste and Wastewater Management. The main sources of waste in the project are the Agri Hubs, commercial farms and their sub-contracted smallholder farms. The main types of waste generated at Ene Congo’s Loudima Agri Hub include general (paper, wood, plastics) and hazardous wastes (medical from the on-site clinic, and lubricant-contaminated wastes); while those from the farms in all three countries are fertilizer and pesticide packaging materials, waste paper, cloths and plastic cans, oil contaminated-materials and soil at the equipment repairs workshops and waste equipment parts. Wastes at the Loudima Agri Hub are segregated, collected on site and periodically transferred to municipal disposal facilities by a contracted waste transporter. At the commercial farms, some waste is consolidated and transferred to municipal waste bins away from the farms, while in other cases the waste is disposed of on farm grounds. Waste related to auxiliary activities (e.g. vehicle/farm equipment repair and maintenance) are not adequately covered in the waste management plans at some commercial farms. Waste fertilizer and pesticide packaging from the smallholder farms are periodically collected by the field officers and retained within respective commercial farms. Minimal wastewater is produced at the Agri Hubs as per the dry process, and is mostly characterized by sewage effluent and de-vaporized water and occasional wastewater from process equipment cleaning. The de-vaporized water from Loudima Agri Hub process is collected and treated through wastewater treatment tanks within the facility and circulated back into the process; while the effluent from sanitation is currently collected on site and will be disposed of through a licensed company periodically. To adequately manage the waste and wastewater in the project, the E&S procedures to be developed for the Loudima Agri Hub will include waste and wastewater management procedures (that include provisions to track waste handling and transportation and disposal by the contracted waste companies). The E&S procedures for the contracted commercial farms will include appropriate waste management plans whose scope is adequate to cover waste related to non-farming activities (e.g. on-farm equipment repair and maintenance workshops), include environmentally safe and legally compliant ways of disposing of the waste fertilizer and pesticide packages and cover waste related to their sub-contracted smallholder farms (ref. ESAP#4).
Hazardous Materials Management. Across the three countries, the main hazardous materials are stored and used in Agri Hub operations and at the commercial farms. These include HFO, diesel, lubricant oils and greases, pesticides, fertilizers, and vegetable oil. Ene subsidiaries keep inventories of all hazardous materials bought and retained in their operations and requires the commercial farms to do the same at their farms. Hazardous materials are adequately handled at the Loudima Agri Hub, with 110% secondary containment at the diesel and HFO locations; while at the commercial farms, some materials are placed in unsuitable areas and not adequately contained (e.g. diesel, lubricants and oils at the equipment repair areas at some farms). Agri-chemicals at the commercial farms are stored in designated areas within the farms, but the storage areas lack on-site material safety data sheets and have inadequate warning signages, spill protection and access controls. There is no formal process of handling hazardous product packaging (e.g. pesticide containers). Going forward, the E&S procedures for the contracted commercial farms will include appropriate hazardous materials management plans whose scope is adequate to cover non-farming activities (e.g. on-farm equipment repair and maintenance workshops), agri-chemicals, and hazardous materials handled by their sub-contracted smallholder farms (ref. ESAP#4).
Pesticide Use and Management. All three Ene subsidiaries have standard requirements on pesticide and fertilizer storage and use at the farms. Each contracted farm is expected to procure pesticides and fertilizers from their own sources but provide the list for Ene’s verification and approval, including strict prohibition of WHO Class Ia and Ib products. Each Ene’s subsidiary has summarized the Integrated Pest Management (IPM) requirements (aligned with Food and Agriculture Organization’s International Code of Conduct on the Distribution and Use of Pesticides and IFC PS3 requirements) in the Farm Handbooks issued to each farmer. Further, field agronomists support farmers through sensitizations and training on pesticide storage and use. This approach ensures appropriate control on procurement and use of fertilizers and pesticides within their supply chain.
PS 4: Community Health, Safety and Security
Fire and Dust Explosion. The Loudima Agri Hub has feedstock silos, processed oil and HFO storage tanks. The plant is located over 5km from the closest settlements, but some seasonal farming, hunting and grazing occur in the vicinity. A hazard identification (HAZID) study was undertaken in 2022 at the early stages of the project design, and fire and dust explosion risks related to temperature control and flammables were identified. The recommendations were integrated into the design of the facility. The temperature and pressure at the feedstock silos are digitally controlled by automated pressure release systems. There are fire suppression systems at the HFO and diesel storage areas and across the process areas. The Agri Hub EPRP includes mechanisms for collaboration with host community and government authorities and facilities in case of fire or explosions. Going forward, the Agri Hub E&S management plans and procedures (ref. ESAP#4) will include a procedure for assessment, management and monitoring program for fire and dust explosion risks at the plant, including potential community exposure scenarios proportionate to the nature and scale of operational risks.
Road transport. Generally, all three Ene subsidiaries currently apply the corporate Eni land transportation and road safety (driving) policies, including on types of vehicles to be used, route surveys, driver competence assessments and speed limits. All vehicles are adequately pre-screened and approved prior to deployment, including trucks to be used by the aggregators for agri-feedstock transportation. Agri-feedstock is transported to the Agri Hub or other Ene storage areas under the custody of the aggregators via contracted trucks. Ene verifies the suitability of these trucks for the project. Processed vegetable oils from Agri Hubs will be transported by licensed trucks to designated in-country storage facilities prior to overseas shipment to Eni’s bio-refineries. Going forward, because of the uniqueness of the agri-feedstock project scope, Ene subsidiaries will develop separate project road transport management procedures that include measures for driver competency, vehicle safety assurance, agri-feedstock and processed oil transportation route risk assessment and monitoring, assessment and management of risks associated with GBV/SEAH and community exposure to transport-related hazards, and grievance mechanisms related to the communities along such routes, as appropriate. Ene subsidiaries will also include road transport safety material in the E&S training toolkit (ref. ESAP#4) and undertake these sessions with the commercial farms and smallholder farmers per annual training calendar - covering both agri-feedstock transportation and general road transport by farm workers and emphasizing road safety awareness measures relevant to communities located along transport routes (ESAP#11).
Food Security. Some of the agri-feedstock utilized in the Ene subsidiaries/branches are non-edible (e.g. castor) while others (sunflower or rapeseed) are used as food sources among communities in Africa. Ene subsidiaries/branches currently mainly rely on large-scale commercial farmers with existing and secure farmlands, and some commercial farmers are expected to retain pools of smallholder farmers in their respective supply chains for agri-feedstock production. The agri-feedstock is grown in crop rotation systems, on severely degraded lands or on parts of these lands that are abandoned or unused and do not directly compete with food production from these farms. Eni is developing its agri-feedstock initiative to be coherent with Annex IX of RED III, which includes intermediate crops and crops grown on severely degraded land. To further strengthen food security risk monitoring and achieve timely identification and management of any emerging risks in the Project, Ene will develop and implement a food security risk monitoring guideline, including a monitoring schedule, aligned with IFC PS (ESAP#12).
Security Personnel. Eni's corporate level security policies and guidelines are broadly aligned with PS4 requirements, addressing both contextual risks and company activities. The Security Management System requirements are cascaded to all subsidiaries and require security personnel to operate according to principles of proportionality and international best practices in hiring, codes of conduct, and oversight on adherence to human rights commitments. Prior to onboarding, Ene subsidiaries conduct due diligence on past human rights violations by shortlisted security service providers. To meet PS requirements, Ene Angola, Mozambique and Congo will develop and implement, for all their security service providers, security contract clauses covering (i) identification of risks and impacts on communities due to the project’s use of security forces, (ii) guidelines on use of firearms, (iii) collaboration on awareness raising and training on Eni human rights commitments, including GBVH, and (iv) mechanisms for reporting and escalation of security-related community grievances and incidents. Ene subsidiaries will also have community GRM mechanisms to address community complaints regarding security personnel for Ene subsidiaries’ operations. (ESAP#13).
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Biodiversity Conservation. The existing Ene Congo Agri Hub is situated within the Western Congolian forest-savanna ecoregion, and the proposed Ene Mozambique Agri Hub will be situated in the Southern Swahili coastal forests and woodlands ecoregion. The two Agri Hub locations have been modified by anthropic activities prior to Agri Hub construction (e.g. livestock grazing, charcoal collection, fires, conversion to cropland). ESIAs, including specialist studies of the project area (e.g. vegetation studies), have been completed for both Agri Hub locations. Though some gaps exist (e.g. brief vertebrate surveys), these are considered commensurate to project risks within the areas. Both the Ene Congo and Ene Mozambique Agri Hub locations are situated in Modified Habitat. As per ESAP#1, both Ene group subsidiaries will adapt and implement the Eni Group ESMS, which will also integrate specific measures to prevent the accidental introduction and spread of seed crops beyond farm areas.
Sustainable Management of Living Natural Resources. Ene Congo and Ene Mozambique will purchase oilseeds cultivated on severely degraded land or in rotation with food crops, from geographically dispersed commercial farms and smallholders across Angola, Republic of Congo, and Mozambique. The regions of production of all three countries are of concern for Natural Habitat conversion, although some producers in the current supply chain (e.g. Mozambique) are situated in historically consolidated agricultural landscapes. In Angola, the commercial farm concessions are a mix of Natural/Modified Habitat mosaic, whilst in Republic of Congo several of the commercial farm concessions overlap extensive areas of Natural Habitat. As required in ESAP#1 above, Ene Congo and Mozambique will adapt and implement the Ene Group IRF, including the Agri-feedstock Supplier Code of Conduct, to mitigate adverse project impacts on biodiversity. All supplying commercial farms are either already ISCC-certified or are working towards this certification. The ISCC certification focuses on prevention of deforestation and conversion of wetlands and high biodiversity value grasslands, does not allow any production in legally protected areas, and has a 2008 cut-off date for land use conversion. Commercial farmers also act as aggregators for smallholders, which are not certified. To onboard new commercial farm suppliers, Ene field teams perform an ISCC-aligned farm screening to determine whether commercial farms will be eligible to meet certification criteria, and also utilize a PS6-aligned screening checklist for identification and management of potential biodiversity risks. To minimize the risk of Natural Habitat conversion in the smallholder supply chain and in commercial farms that are not yet certified, Ene Angola, Congo and Mozambique will develop and implement a procedure for the assessment of habitat conversion risk which will include ground-truthing to validate desk-based screening data, and confirm the risk level and significance (ESAP#14). High risk areas where significant natural habitat conversion risk is confirmed will be excluded from sourcing. As required in ESAP#3 above, the E&S risk assessments to be conducted by Ene Angola, Congo and Mozambique will include the commercial farmers’ capacity to implement the above procedures at the smallholder farm level, and develop and implement corrective action plans to close identified gaps. Ene commits to achieve 100% ISCC compliance in its supply chain by 2028.
