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 Impact
Policy, Environmental and Social Management System. SDN has recently developed two standalones’ policies on Health, Safety and Environment (HSE) detailing the company’s approach to managing its operation in accordance with national legislation and aligned with IFC PS1. These policies address aspects relating to the identification and mitigation of project specific risks and impacts, including aspects related to labor and working conditions, environmental impacts, occupational health, and safety (OHS) and management of third-party service providers. At the time of IFC appraisal, these policies were yet to be implemented. As part of the IFC financing, SDN will develop and implement an ESMS (Environmental and Social Management System) aligned with PS1 standards. The ESMS will be applicable to the flour mill and the solar farm and the transmission line (T-Line) and will include the following elements: (i) identification and assessment of E&S risks and impacts; (ii) E&S organizational capacity and competence; (iii) community health, safety and security management; (iv) occupational health and safety (OHS) management programs; (v) contractor management procedures; (vi) Supplier Code of Conduct; and, (vii) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs)(ESAP#1). The client will provide adequate resources as necessary to develop and implement the ESMS.
Identification of Risks and Impacts. E&S risks and impacts of SDN processing plants have been assessed against Mali E&S legal and regulatory requirement. SDN’s current processing plant underwent an E&S Impact Assessment (ESIA) study in 2022. As part of the ESIA process, an E&S Management Plan (ESMP) and E&S monitoring plan were developed. The E&S impact assessment for the existing operation is compliant with national law and broadly aligned with PS1 guidelines but lacks details on the screening and scoping phase, delineation of extended area of influence as well as a robust stakeholder engagement exercise. The low voltage distribution lines will be designed to run along existing roads, hence will pose low E&S risk that could be addressed in the ESIA and its ESMP. In line with ESAP #2, SDN will develop an ESIA aligned with IFC Performance Standards for the new flour mill and the solar farm including the transmission line.
Management Programs: The ESIAs for the existing operations (feed mill and oil processing) include framework environmental and social management plans. These framework plans feature detailed E&S aspects and impact tables for various activity phases. Besides the HSE policy developed, the company is yet to develop an HSE plan including procedures related to hazard and risk identification, design and development, hazardous materials, safety training and on air, noise, waste and E&S monitoring and reporting and KPIs. As part of its ESMS and the flour mill ESIA (ESAP#1 and #2), SDN will develop and implement a comprehensive ESMP that will describe the mitigation measures and E&S requirements to be addressed during construction and operations phases of the flour mill and the solar farm including the transmission line consistently with IFC PSs including labor and working conditions, resources efficiency and pollution prevention as well as community health, safety and security management.
Organizational Capacity and Competency. SDN has a quality department responsible for conducting quality control testing on both raw materials and finished products prior to offloading the container and sale at its existing facilities. As part of the IFC investment, SDN will recruit a full-time and competent E&S manager to lead the completion of the ESAP and implementation of the ESMS. The E&S management function will be provided with annual budgetary allocations to implement E&S actions and maintain the ESMS. The E&S manager will report directly to SDN’s General Manager. In addition, considering the level of effort required to complete the ESAP, SDN will contract an OHS and HR officer (as discussed in more details under PS2) to support the E&S manager to complete the ESAP per agreed timeline. (ESAP#3).
E&S training. SDN will develop and implement an E&S training applicable to all their operations including the greenfield plan that will incorporate OHS and food safety modules, E&S policies, E&S management plan, EHS SOPs based on employee roles/responsibilities and workplace risk assessment and control, including use of PPE, good housekeeping practices, work permit system (working at height, hot environment, confined space, heavy lift), electrical safety (Lock-Out/Tag-Out system), fire prevention, first aid and training on infectious and sexually transmitted diseases, defensive driving course (ESAP#1). The on-site emergency and OHS committee will be established and receive advanced training from specialized agencies, consultants and/or local fire authorities.
Emergency Preparedness and Response. SDN plant is equipped with 8 fire extinguishers, inspected regularly. No evidence was found about firefighting drills. There were no documented Emergency Preparedness and Response Plan (EPRP) validated by local authorities. As part of its ESMS (. ESAP#3), SDN will develop and implement an Emergency Preparedness Plan (“Plan d ’Operation Interne” - POI) as per the provisions of Mali’s building codes and life and fire safety (LFS) standards applicable to all its assets including the flour mill and solar farm .Upon completion of the EPRP consistent with IFC PS1 and applicable/relevant section of the WBG EHS Guidelines, including physical climate risks associated to heatwaves and flooding, SDN will certify the plan with the competent authorities and will socialize it with the communities neighboring its plant and establish a collaboration agreement with local fire authorities in case of emergency situations.
Monitoring and Review. As part of the ESMS (. ESAP#1), SDN will develop and implement an E&S monitoring and reporting procedures, specifying Key Performance Indicators (KPIs) such as compliance with E&S legal and regulatory requirements, leading and lagging OHS indicators (including Loss-Time Frequency Injury Rate - LTIFR), resource efficiency (energy and water consumption/efficiency per ton of products), pollution control (ambient and point source air emissions, noise monitoring, water quality guideline values, proper storage of solid/hazardous waste management and disposal with licensed service providers) and Food Safety KPIs.
PS2: Labor and Working Conditions
SDN currently employs 358 employees in its existing feed mill and oil processing operations, out of which 51 are women. This proposed IFC investment is expected to create some 196 additional jobs, out of which 45 will be temporary positions (during construction and early operation phases). The human resources department consists of a director and one officer; both are based at the Bamako headquarters.
Human Resources Policies. SDN has an Internal Regulation and Code of Conduct in place as well as newly developed policies and procedures addressing forced labour, non-discrimination and equal opportunity, retrenchment, as part of its HR management system. Those policies and procedures are yet to be implemented.
As part of this IFC investment, SDN will develop and implement a HR manual that is compliant with PS2 standards for all employees (permanent and fixed-term contracts) and contractors. This manual will serve as a management tool and will include clear HR policies and procedures on: (i) freedom of association, (ii) working hours, paid leave and other regulatory rights (iii) grievance mechanism allowing for anonymous complaints; (iv) procedure for overtime management and (iv) provisions on contractors and casual labor. These policies will be communicated to all workers, including temporary, casual, and subcontracted staff (ESAP #4). Given the anticipated expansion of the permanent and casual workforce with the proposed IFC financing, the HR function will be strengthened with an HR officer (ESAP# 3).
Working Conditions and Terms of Employment. SDN operates six-days a week, with workers required to work 8-hours per day, with a one-hour lunch break. The feed mill operates on 3 shifts of 8 hours each while the oil plants operate 6 months per year, running on a full day basis during production periods. Overtime is paid on a higher rate as stipulated by the Malian labor law. At present, sample contracts and payslips have not been provided to verify the workforce profile or to confirm the terms and conditions of employment for SDN employees. In order to ensure compliance with its Human Resources (HR) manual, (ESAP#4), SDN will establish formal employment contracts for all members of its workforce. This will include the development of contracts not only for existing employees but also for those who will be engaged at the new greenfield site. In addition to formalizing employment terms and ensuring that all workers have clear documentation outlining their rights and responsibilities, SDN will also ensure that all statutory social contributions are duly paid. This commitment covers all categories of employees, including those engaged at the new greenfield site.
Workers’ Organizations. SDN respects the rights of workers to join or form unions or worker’s associations of their choosing. Currently, there is no union in place. As per their HR manual (ESAP#4), SDN will develop freedom of association policy to allow and uphold workers’ freedom of association and the collective rights of bargaining, consistent with PS2.
Grievance Mechanism. SDN has developed a new grievance mechanism (GM) for employees and subcontractors, providing a way for them to raise concerns and complaints. However, this procedure has not yet been implemented and currently does not include procedures for addressing gender-based violence (GBV), anonymous complaints and sexual harassment. As part of the IFC investment, SDN will update and implement the grievance mechanism for all workers, including third-party workers. The updated GM will (i) allow anonymous grievances and provide dedicated channels for reporting GBV and sexual harassment (GBVSH); (ii) increase employee awareness of the GM through induction sessions, notice boards, and online platforms; (iii) include specialized training for staff responsible for handling GBVSH complaints, in line with IFC Performance Standard 2 requirements (ESAP #5).
Protecting the Workforce. Neither child labour or forced labour will be or is utilized by SDN operation as per the provisions of the Mali Labor Code and SDN’s HR requirements. SDN only employs people according to legal age employment regulation which is set to 18 years or over. Policies related to child labour and forced labour have been developed and will be integrated in the HR manual referenced in ESAP#4.
Occupational Health and Safety. Inherent hazards and risks of a flour processing plant include working at height, in hot and noisy environments, in confined spaces, with energized equipment and ergonomic hazards. As part of the ESMS (ESAP#1) mentioned above, SDN will develop an OHS Management System for its processing plants aligned with IFC PS2 and WBG EHS General Guidelines requirements as well as requirements for Electric Power Transmission and Distribution. SDN will train all relevant workers in the implementation of these procedures. The plan will also include an OHS policy, Standard Operating Procedures (SOPs), and definition and monitoring of OHS leading and lagging indicators. SDN will also ensure monitoring of safety protocols, maintaining incident records and adherence to a structured approach of incident investigation and resolution, adopting a Personal Protective Equipment (PPE) policy defining the company’s minimum PPE requirements and enforcing it at site level. Personnel safety inductions will be mandatory for all workers. SDN will include audiometry test as part of the annual health check-up of its milling staff and will include noise monitoring at its facilities and sensitive receptors in its E&S monitoring and reporting requirements (ESAP #1). Job specific training, followed by general weekly safety meetings and specific daily toolbox talks will also be implemented. SDN will also recruit a full-time and competent OHS officer (. ESAP# 3), establish an OHS Committee at the different processing facilities including the flour mill, and develop and implement a comprehensive training plan based on workstations hazards for all worker categories. SDN will also establish an on-site first aid clinic and recruit a full-time nurse (ESAP#6).
Workers Engaged by Third Parties. SDN utilizes a limited number of third-party service providers including security agencies and construction workers via the construction company. SDN will formalize the E&S requirement for its service providers in its ESMS manual as per. (ESAP #1) and as per. (ESAP #5) will extend its grievance mechanism to cover third party workers. Also, SDN will implement a contractor management procedure that requires the selection, evaluation, management, and monitoring of third-party service providers and requires each contractor to have a QHSE supervisor as well as monitor and report on its HSE practices and performance (ESAP#7).
Supply Chain. SDN has recently developed a Suppliers' Code of Conduct outlining the company’s expectations regarding business integrity, adherence to fair labor practices, including the prohibition of child and forced labor—and responsible sourcing. For the flour mill, SDN plans to source wheat from Europe through established international bulk traders.
At the time of appraisal, a supplier for the photovoltaic (PV) modules had not yet been identified. As part of its ESMS (. ESAP #1), SDN will strengthen its Suppliers Code of Conduct by introducing ethical pre-contractual requirements in supplier selection and incorporating a procedure for supply chain mapping and risk assessment. The enhanced policy will also extend to contractors involved in sourcing PV modules, who will be required to demonstrate that these standards are applied consistently throughout their own supply chains. SDN will maintain the right to disengage from any supplier that fails to meet the company’s ethical, environmental, or social performance requirements.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. SDN currently utilizes electricity sourced from the national grid for all its operational assets. The company makes use of back up diesel generators where portable power is needed or during power outage. In 2024, SDN consumed an estimated 6000 liters of diesel and 600,461 kilowatt hours of energy from the national grid. It is estimated that SDN greenhouse gas (GHG) emissions from the use of grid electricity and diesel for backup generators will remain below 25,000 tons of CO2 equivalent per annum after the IFC investment.
Noise and Air Emission: As part of this investment, SDN will develop and implement noise and air management plans within its facilities, at the perimeter of its facilities and at the closest sensitive receptors to determine noise and dust impact on its workforce and neighboring communities. In addition, SDN will develop a maintenance program of all combustion equipment to ensure they have proper functioning and limiting emissions.
Water Consumption. Flour milling is mostly a dry process. SDN sources its water from the national water corporation and uses water predominantly for daily domestic use and in temporary construction activities. Also, due to the small size of the solar plants, the volume of water requirement for cleaning is expected to be small and will not affect water supplies. However, as per ref. (ESAP #1), SDN will include water monitoring in the E&S performance monitoring and reporting procedure.
Waste Management. SDN waste includes pellets, stones expiration, spoilage and production waste. SDN current wastes are collected by small collectors. As part of this investment, SDN will develop and implement a waste management procedure that details the production, handling, storage, transport, and disposal of all waste streams generated in its operations including batteries (Ref. ESAP #1). The company will ensure the use of authorized waste management service providers in managing some of its waste streams.
Hazardous Materials Management. SDN’s current operations include limited hazardous materials such as hydraulic oil, mechanical oil and diesel. Most of the hydraulic and mechanical oil are collected by private companies and are reused in the brick fabrication process. For the solar farm, hazardous materials include batteries (e.g., lithium-ion), electronic parts (e-waste). SDN will develop and implement a hazardous management plan by ensuring a waste tracking and recording system from cradle to grave is implemented for all its operational assets. Proper hazardous material storage protocols including storage of hazardous materials including fire prevention and adequate spill kits and firefighting equipment will be deployed and readily available at appropriate locations (. ESAP #1).
Pest Control. As part of this IFC investment and under its ESMS, SDN will ensure a pest management plan is developed and implemented at the flour mill including silos storage. A certified service provider will be used to implement the plan. SDN will ensure that material safety datasheets (MSDs) are obtained, verified and mitigation measures implemented during pest control operations. Waste generated from the fumigation activity is retained and managed by the service providers (ESAP#1).
PS4: Community Health, Safety and Security
Food Safety. There are no formal food safety protocols in place for the current operations. As part of this investment, the company will develop and implement a food safety program. Also, food safety protocols will be implemented at the flour mill and ensure laboratory technicians are regularly sensitized on use of new equipment. SDN will certify its processing operation according to internationally recognized food safety standard consistent with the principle of Hazard Analysis and Critical Control Point (HACCP) system. In addition, the HACCP program should be specifically issued for milling processing such as the biological risks (such as mold and bacteria); pesticide residues; and metal fragments from processing machinery (ESAP#8).
Community Health and Safety. SDNs operations in Banankoro are located on three parcels with a total surface area of 6 ha. There are communities living near the site in the direct area of effluence. As the flour mill will be operating 24 hours each day, impacts of noise could be considerable. SDN will develop and implement a noise management plan that will ensure that low noise rating equipment is procured for the milling process and to ensure that noise limit values are below the permitted regulatory and WBG EHS limits as part of its ESMS (ESAP#1).
Traffic Safety. SDN relies on its own fleet for its transport operations. As per ESMS (ESAP #1), SDN will develop and implement a traffic management plan applicable to its transport fleet, its suppliers and distributors. The plan will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards as well as alcohol and drug testing requirements. Also, SDN will provide a detailed induction session on the E&S provisions of its Code of Conduct, including zero tolerance to gender-based violence and sexual exploitation, abuse and harassment for its own truck drivers and transport service providers.
Life and Fire Safety. As per the IFC investment, SDN will incorporate life and fire safety (L&FS) requirements in the design of the silo’s storage facility and new flour mill. The silos design will follow international standards to prevent dust explosions and make provision for life and fire safety measures like hoses, water hydrants and water reservoirs. As per (ESAP #1), SDN will include L&FS measures in its EPRP and communicate emergency response protocols with other operators within the area where it operates mills including the municipal fire department as well as community within the area of influence focusing on protection and safe evacuation of personnel and stakeholders.
Security Personnel. SDN utilizes a third-party service provider for security guards. The Company employs a total of 2 unarmed guards covering two shifts. A security risk assessment will be prepared as part of the company’s ESMS covering all aspects related to, hiring, training, appropriate conduct of security workers toward workers and community members, equipping, and monitoring of security guards and their activities.
