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
Johnvents has an Environmental and Social Management System (ESMS) aligned with the requirements of IFC Performance Standards and commensurate to the level of risks associated with the company’s existing processing activities. This includes a Group ESMS framework that sets minimum standards for all subsidiaries and affiliates. The Group’s E&S policies include: (i) a health and safety policy; (ii) environmental sustainability policy; (iii) quality and food safety policy; (iv) health hazard policy; and (v) a Hazard Analysis and Critical Control Point (HACCP) policy. Each facility adapts these policies into its site-specific plans and procedures while remaining aligned with the Group standards. Johnvents maintains the required national regulatory permits and internationally recognized food safety and sustainability certifications and embeds environmental and social (E&S) management across sourcing, processing, logistics, and community engagement.
In Nigeria Johnvents is compliant with certifications from the National Environmental Standards and Regulation Enforcement Agency (NESREA) and the Standard Organization of Nigeria (SON). At an international level the company has Rainforest Alliance certification valid to September 2026. Johnvents also upgraded to the Food Safety System Certification (FSSC) 22000 Version 6 which applies to the entire supply chain. In support of the expansion activities associated with this investment, the Group ESMS framework will apply to the Project and the corporate Environmental and Social Management Plan (ESMP) will be adapted to cover the development and processing activities related to sesame in Nigeria and cashew in Cote d’Ivoire and acquire the relevant national certifications for these operations (ESAP #1).
Identification of Risks and Impacts
The company’s Environmental and Social Management Plan (ESMP) outlines a risk assessment, management, and monitoring matrix detailing key risks associated with the existing cocoa processing facility, including occupational, health and safety (OHS), environmental, and community related risks. In addition, Johnvents’ health safety and environment (HSE) and quality team conduct periodic Hazard Analysis Critical Control Point (HACCP) and OHS inspections for routine work. More recently, Johnvents also applies a risk-based approach at Group and facility level using the IRIS Carbon platform for initial screening by identifying key E&S risks per facility, and a group-level double materiality assessment to prioritize high-risk issues across facilities and has a group level risk register.
For the development of the new processing facilities in Nigeria and Cote d’Ivoire the company will undertake an Environmental and Social Impact Assessments and update the ESMP’s to incorporate the new activities, both in accordance with the respective national regulations and the requirements of IFC Performance Standards. The latter will also include public involvement to ensure stakeholder input is incorporated into project planning and management (ESAP #2a). In addition, the Hazard Identification and Risk Assessment (HIRA) / Hazard and Operability Procedure (HAZOP) will be completed for the new activities to systematically identify, assess, manage, track, and communicate associated risks; this will then feed into an update of the Group level risk register. The register should be elaborated to include risks related to life and fire safety (LFS), gender-based violence and sexual harassment (GBVH), adverse weather (heatwave & flood) management, community health and safety and security management (ESAP #2b).
Management Program
The ESMS incorporates elements including E&S policies, an ESMP, standard operating procedures, quality, food safety, and occupational health and safety risk identification, emergency preparedness and response, and stakeholder engagement. In doing so, the ESMS integrates risk identification, mitigation, monitoring, and continuous improvement across farming, sourcing, processing, logistics, and community engagement, including farm mapping and traceability, supplier and farmer onboarding, health and safety (H&S) risk management, waste and water management, child labor monitoring and remediation if identified, gender inclusion, and grievance mechanisms. Performance is tracked through defined environmental, social, governance (ESG) and H&S KPIs, internal audits, regulatory inspections, and digital data systems (including IRIS Carbon), with periodic reporting and escalation to management and the Board. As a component of the ESMS, the company develops and implements an annual training plan on E&S topics for employees. Training topics include HSE management; fire, safety, and accident prevention; food safety, internal audit training, among others. HSE induction is provided to all new hires. All the above programs will be adopted and implemented across all expansion facilities as per ESAP #1.
Organizational Capacity and Competency
Johnvents has established a dedicated sustainability and ESG structure, with defined associated roles spanning group-level leadership, country sustainability leads, E&S officers, H&S officers, data analysts, and more than 25 field agents supporting on the ground E&S implementation. To strengthen implementation of HSE programs at the cocoa processing plant, the company has established an OHS committee which operates in accordance with defined Terms of Reference. Going forward, Johnvents will hire additional HSE and sustainability staff to manage the expanded operations in Nigeria and Cote d’Ivoire. HSE committees will also be established at newly acquired processing facilities (ESAP #3).
Emergency Preparedness and Response
The Group has an emergency preparedness and response procedure (ERP) which defines emergency situations including preparedness and response measures; the procedure also defines the plant layout and evacuation routes. Emergency response equipment at processing plants includes fire alarms, fire extinguishers, and fire hydrants. Firefighting equipment is inspected monthly by the company, and annual firefighting and emergency response training and inspection is undertaken by the State Fire Service in Nigeria. The ERP defines roles and responsibilities, information on regular safety inspections (including by the State Fire Service), safety inductions and personal protective equipment (PPE), toolbox talk and monitoring requirements through internal dashboards. Serious incidents are escalated to corporate management, regulatory agencies and there is also Board level sustainability oversight, with follow up actions tracked through internal systems. A similar approach will be applied to the new operations in Nigeria and Cote d’Ivoire per ESAP #1.
Supply Chain Risks
Building on its 100% cocoa traceability, Johnvents will apply similar measures as it expands to other commodities i.e., sesame in Nigeria and cashew nuts in Cote d’Ivoire. Thus, at these operations the company will; (i) establish a supplier code of conduct defining social and biodiversity standards to be signed by all suppliers that ensures the conversion of natural/critical habitats is avoided; (ii) establish a platform to verify sourcing origins; and (iii) establish sustainable supply chain procedures with clear management, monitoring, and auditing for both commodities (ESAP #4).
Monitoring and Review
The company monitors E&S performance as part of the current overall E&S and food safety management activities. This includes periodic HSE and food safety inspections, food safety internal audits, and environmental measurements of air quality and noise. The company also receives unscheduled audits from NESREA and the Federal Ministry of Labor and Productivity. In support of monitoring, the company has GPS/GIS-based farm mapping, deforestation risk screening, traceability systems, farmer capacity-building programs, child labor monitoring and remediation, gender inclusion initiatives, and structured grievance mechanisms. The Group also has competence in ESG data management, GHG accounting, and reporting through the IRIS Carbon platform, supported by defined KPIs, internal audits, and board-level oversight. A similar approach to reporting will be applied to activities associated with the expanded operations in Nigeria and Cote d’Ivoire (ref. ESAP #1).
PS 2 – Labor and Working Conditions
Johnvents currently employs a total of 1,497 workers, comprising 692 (36%) direct workers and 1223 (64%) contracted workers; of these 409 (21%) are female workers. The company has adopted a local recruitment approach whereby the hiring of workers within the local catchment area is prioritized.
Human Resources (HR) policies, management procedures: Human resources (HR) at Johnvents is managed through the HR and Administration department, headed by an HR Manager, who is responsible for the formulation and implementation of policies and procedures. In addition, the company has an HR board sub-committee with oversight of HR matters. Johnvents has implemented an HR policy that defines the company/employee relations and management approach. Johnvents has also adopted a Staff Handbook, Disciplinary Procedure, Asset and Information Management Policy, Performance Management Policy, and Whistleblowing Policy.
The Staff Handbook defines the various worker related policies and procedures, including a code of conduct, driving policy, anti-harassment, compensation and benefits, allowances, bonuses, leave, performance management, disciplinary action, and learning and development. As per the Staff Handbook, should an employment contract be terminated due to redundancy, this process is managed per statutory requirements.
As defined in this section, the company’s approach to HR is compliant with national requirements and generally aligned with this PS and currently adopted at the Group level and implemented across all subsidiaries in Nigeria. Going forward, the company will apply a similar approach to HR in Cote d’Ivoire by developing an employee handbook that aligns with the national regulation (ESAP #5).
Working Conditions and Terms of Employment: All employees are provided with a written contract defining their role, effective date, compensation and benefits, and core duties. The processing plants operate 24-hours a day, with the implementation of three 8-hour shifts. Any hours beyond defined contractual hours are considered as overtime and remunerated accordingly. All workers are provided with a medical and welfare service covering the costs of medical expenses, pension fund administration, national housing fund contributions, and group life insurance.
Workers’ Organization and Freedom of Association: All labor and working conditions at Johnvents operations, for both direct and contract workers, are governed by local labor law, including the Labor Act and Trade Unions Act, which promotes freedom of association and collective bargaining. While Johnvents do not restrict unionization at their operations, currently no workers are unionized, nor is there an existing collective bargaining agreement in place.
Non-Discrimination and Equal Opportunity: As per the company’s HR policy, Johnvents is committed to being an equal opportunity employer without any form of discrimination.
Grievance Mechanism: Johnvents has adopted a worker grievance mechanism, as defined in the Staff Handbook, that provides various channels for the submission and resolution of grievances and issues. While management encourages informal management of grievances, the Handbook makes provision for a four-stage formal management process. The process defines feedback timelines and allows for anonymous submissions. Should resolution not be achieved through the defined process, an Appeals and Grievance committee can be established at the discretion of the Managing Director. In addition to the grievance mechanism, Johnvents has also adopted a process for the reporting and management of all forms of harassment in the workplace including GBVH. All workers also have access to the Whistleblowing Policy. This policy allows for the submission of anonymous allegations and complaints.
Protecting the Workforce: As per the Nigerian constitution, Labor Act, and Child Rights Act, Johnvents prohibits the use of forced and/or child labor within their workforce. Worker’s age is verified and recorded at the time of recruitment, while third-party contractors are prohibited from employing anyone under the age of 21. As part of their recently launched sustainability program, Johnvents is actively working with farmers, cooperatives, and licensed buying agents to improve awareness and promote good practice in relation to labor and working conditions within the cocoa supply chain, including the potential use of child labor. The company have recently adopted the RA approach of “Assess and Address” which is comparable to the International Cocoa Initiative’s CL Monitoring and Remediation System. As detailed under PS1, compliance and progress is monitored through periodic RA audits and the company’s sustainability program. This will similarly apply for the new subsidiaries in Nigeria and Cote d’Ivoire whereby workforce protection at the company operations and in the supply chain will be audited internally via the Group’s sustainability program.
Occupational, Health and Safety (OHS): Johnvents have identified high risk areas pertaining to OHS, which primarily relates to dust, heat, and noise exposure, as well as the risks associated with the operations of plant machinery. The company has various standard operating procedures in relation to these risk areas, to support the implementation of the Health and Safety Policy defining the key principles and objectives relating to OHS, and there is a Health Hazard Policy defining the process for the elimination of potential hazards. In 2025, the total number of occupational injury cases was three (one direct employee and two contractor employees), with no fatality recorded. As indicated under PS1, training is provided to workers including fire prevention, control and emergency management, safety and accident prevention, road safety, and general HSE. Daily toolbox talks are also undertaken. All staff are provided with the relevant PPE including safety boots, overalls, ear plugs and dust masks.
As per national regulatory requirements, Johnvents monitors and reports on workplace noise levels on a quarterly basis. Measurements were taken at over 20 different locations, including CNG generator station, boiler house, roasting section, workshop and pre-processing section. Where noise levels are noted to be high i.e., above 85 dB(A) in some workstations, the company requires the use of mandatory PPE.
First aid boxes and safety signage are positioned at strategic locations around the operation. In addition, where the company is promoting the distribution of agrochemicals in the supply chain, the correct application, handling, and storage of these inputs is covered under the ongoing training provided through the sustainability program.
Ambient temperature was above 32oC when visiting and both Nigeria and Cote d’Ivoire and are projected to experience an increase in temperature due to climate change. Factory operations will need proper ventilation systems as workers may be exposed to heat-related illnesses such as heat stress/stroke and dehydration. Air conditioners and fans have been installed at specific areas. However, improved ventilation appears necessary at all locations. These ventilation / cooling systems need to be implemented as a priority and other adaptive measures need to be considered, such as implementation of heat stress management protocols, and ensuring access to drinking water (ESAP #6).
Contractor Management: Johnvents currently utilizes third-party contractors to support functions such as cleaning and security. Contractors will also be engaged for the construction of the new processing facilities. Prior to procurement, all contractors are vetted and approved at a Group level. As per existing contracts, all contractors are required to abide by Johnvents’ policies and procedures. Johnvents has a well-developed contractor management plan with procedures to monitor and report on contractor performance against company policies and procedures for compliance with the corporate contractor management plan, applicable legal requirements including wage regulations and IFC PS2 requirements. Contracted workers have access to Johnvents’ grievance mechanism should they need to submit a grievance or complaint.
Supply Chain: Through their ongoing sustainability program, Johnvents are actively working with farmers, cooperatives, and LBAs to improve awareness and promote best practice in relation to labor and working conditions within the supply chain, including the potential use of child labor and risks associated with health and safety. All supply chain corrective actions for IFC’s initial investment have been closed with 100 % traceability achieved for cocoa sourcing. Risks associated with the current supply chain for cashew and sesame cannot be excluded and will be managed in accordance with ESAP #4.
PS 3 Resource Efficiency and Pollution Prevention
Resource Efficiency: To improve resource and operational efficiency, Johnvents transitioned from grid/diesel to Compressed Natural Gas (CNG) for all energy requirements including the boiler at the cocoa processing plant in Akure, Nigeria (this was part of IFC’s initial investment). Water for construction and operations (steam generation, hygiene, sanitation, and potable consumption) is sourced from groundwater abstracted through on-site boreholes in accordance with government approvals and permits, and consumption is measured using flow meters. For the new facilities, water will equally be sourced from boreholes, with conservation measures in place such as optimization of boiler and thermal systems, water recycling and reuse initiatives, rainwater harvesting, and monitoring of resource consumption through metering systems; there are also employee awareness programs to support resource efficiency.
Greenhouse Gas Emissions: Johnvents' direct greenhouse gas emissions, including scope 1 and scope 2, mainly come from electricity and fuel used in processing plants and transportation fleet management. Total annual GHG emissions are estimated at under 25,000 tons of CO2 equivalent. These emissions are monitored as part of the company's sustainability initiatives and reported annually.
Air Emissions and Noise: At Johnvents processing facilities, air emissions are primarily related to particulate matter (PM) generated from its steam boilers and mechanical food processing. Johnvents has recently transitioned to a cleaner and more efficient compressed natural gas (CNG) energy source. As per national regulatory requirements, Johnvents implements a quarterly air quality and noise level monitoring including carbon monoxide, volatile organic compounds, nitrogen dioxides, sulphur dioxides and suspended particulate matter. The Group has a procedure for the environmental measurements in its corporate ESMS that will be applied to the new subsidiaries in Nigeria and Cote d’Ivoire.
Waste and Wastewater Management: The company has a waste management plan, which addresses management of the hazardous and non-hazardous waste generated including storage, collection, and disposal requirements in accordance with the WGB General EHS Guidelines. The plan defines chain of custody requirements for final disposal and there is an established waste register for monitoring and reporting waste disposal. The main solid waste generated from processing activities is cocoa shells, cashew nut shells, along with other forms of solid wastepaper, polyethylene bags, and scrap metals. A portion of the shells are used as fuel for the boilers and the rest is sold as animal feed. Hazardous waste generation is limited to waste generated from the laboratory such as spent reagents, medical waste from site clinic, and plant maintenance activities such as spent oil and oil filters. Johnvents uses licensed waste collection and disposal service providers for the collection of the waste generated from the processing plants and will do the same Cote d’Ivoire.
The existing process activities generate no industrial wastewater. Domestic and process-related wastewater generated from the processing plants is collected in septic tanks for regular disposal. Wastewater generated from the proposed cashew processing facility in Cote d’Ivoire will be treated on-site through a dedicated effluent treatment system, in line with applicable environmental regulations and good industry practice.
Pesticide Use and Hazardous Material Management: The company is involved in the distribution of agrochemicals (pesticides and fertilizers) within their supply chain. As a component of Johnvents sustainability program, it undertakes ongoing training to promote the responsible application and storage of agrochemical inputs. This includes the use of chemicals approved by the Cocoa Research Institute of Nigeria (CRIN), responsible and appropriate application, safe storage, record keeping, and disposal. Johnvents has develop a hazardous material management plan to include a dedicated emergency response section with mitigation measures for spills including secondary containments, specific contact details, escalation flowcharts, and coordination protocols with external agencies such as national fire services and hospitals. Activities associated with the expansion will adopt similar hazardous material management plans and incorporate requirements for regular risk assessments, scenario-based drills, include a stakeholder engagement protocol for major incidents, outlining notification, consultation, and feedback mechanisms as per the Group’s corporate ESMS (ESAP #1).
PS4 Community Health, Safety, and Security
Community Health and Safety: Johnvents’ cocoa processing plant is located within an industrial area of Akure, Nigeria, thus there are limited potential impact on local communities. Potential community health and safety risks emanating from the company’s operations could relate to exposure to contaminated food products, road and traffic incidents, dust and noise associated with the movement and transport of goods, and risks associated with security personnel. The new facilities in Ibadan, Nigeria and Cote d’Ivoire are in industrial zones. Given the nature of the operations significant adverse impacts are not expected on nearby communities, except in case of emergencies (e.g. fire) or through traffic and security. The plan for handling such emergencies is included in the emergency response plan.
Food Safety and Hygiene: The management and oversight of food safety is the responsibility of the quality assurance department. Johnvents have adopted several policies and procedures relating to food safety and hygiene including the HACCP policy, Quality and Food Safety Policy, Food Safety Operations Manual, and product hold-release procedure. All final products, including cocoa powder, butter, and cake, are submitted to the Institute of Public Analysis for compliance and certification purposes. The company conducts internal audits under the Food Safety System Certification (FSSC) 22000 frameworks. The same standards will be applied to the new subsidiaries in Nigeria and Cote d’Ivoire.
Road and Traffic Safety: Johnvents presently owns and operates a fleet of 83 trucks and intends to increase this by 30 as part of a logistics and distribution expansion initiative through its subsidiary, Haven Hauling. Drivers are employed directly by Johnvents and are provided with ongoing training (including driver behaviour, vehicle maintenance and inspection, safety and security, and fleet management) as a component of the company’s annual training schedule. All trucks are fitted with an in-vehicle monitoring system (IVMS) that provides continuous monitoring on speed, location, and driver behaviour. All trucks are also fitted with internal and external cameras. As a component of the existing OHS procedure, Johnvents has a Road Traffic and Driver Safety (RTS) procedure, consistent with GIIP, to mitigate and manage risks associated with company’s trucking operations and road traffic accidents.
Security Management: Johnvents currently employs a Security Manager who is responsible for oversight and management of security at Johnvents operations. Onsite security is provided by third-party contractors who provide security guards to the processing plants. In addition, the Nigerian national police force provides armed police officers to the operation for additional security requirements. For the new subsidiaries in Nigeria and Cote d’Ivoire, limited armed security will be used in coordination with licenced private security agencies. All security providers will be vetted, trained on human rights, use-of-force principles, and Johnvents Code of conduct, and their performance reviewed regularly. Johnvents will commissioned a security risk assessment to define the risk profile of the operations and inform their security requirements in accordance with its Security Management Plan (SMP) which has provisions for guard selection, rules of engagement (including minimum force), included in memorandum of understanding with public security forces on roles and responsibilities, training, equipment, facilities, working conditions, and community access to the grievance mechanism.
PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources
The company sources commodities which are produced in regions where there is a risk of significant conversion to natural and /or critical habitats. The supply chain mitigation and proposed corrective actions associated with these risks are described under PS1. The risk of ongoing conversion of natural/critical habitats cannot be excluded in the period prior to achievement of 100% traceability for all commodities as described in ESAP #4.
