IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
**Environmental & Social Policies and management systems**
GCB has established a corporate Environmental and Social Management System (ESMS) that outlines the Group’s commitments to compliance with national regulatory requirements and alignment with relevant voluntarily good practices and certifications, such as Rainforest Alliance and Fairtrade. The ESMS is supported by policies and procedures covering (i) Occupational Health and Safety, (ii) Human Rights and Labor, (iii) Business Ethics and Code of Conduct, (iv) Sustainable Procurement, (v) Food Safety and Quality, (vi) Due Diligence, and (vii) Forest Protection and Traceability, and is applied across all Group subsidiaries. The Group maintains a legal register, a property location register, and undertakes periodic compliance audits to monitor adherence to internal requirements and applicable regulations. The Côte d’Ivoire operation has been ISO 22000 certified since 2022.
GCB will update its ESMS to include commitments to address biodiversity conservation in the supply chain, procedures for preventing and managing Gender-Based Violence and Harassment (GBVH),and strengthening monitoring arrangements. To support consistent implementation across all subsidiaries, GCB will prepare an ESMS Manual. Subsidiaries will conduct the necessary sensitization and training to ensure consistent application across operations (ESAP #1).
**Identification of Risks and Impacts**
For the San Pedro processing plant, GCBCCI completed an ESIA in 2019, and the facility received its environmental license in 2020. The key risks and impacts associated with processing plant include: air quality, noise, water management, management of construction workers, stakeholder engagement and aspects related to the cocoa supply chain. GCCCI also applies a Hazard Identification, Risk Assessment, and Risk Control (HIRARC) process across all work areas, consistent with the mitigation hierarchy required under the IFC Performance Standards.
The proposed expansion will occur entirely within the existing facility footprint, located in a gazetted industrial zone, and therefore does not require a new ESIA under national law. As required under ESAP #2, prior to expansion works the Company will undertake an EHS risk assessment and will update baseline data on air emissions, water, GHG scoping and ambient noise modelling and supply chain. Based on the outcomes of these assessments, GCB will develop and implement Environmental and Social Management Plans (ESMPs) proportionate to the risks and impacts identified.
**Organizational Capacity and Competency**
GCB’s organizational structure includes a Supply Chain evaluation team based in Malaysia and a Corporate Sustainability team in the Malaysia responsible for maintaining the Group E&S policies, overseeing their implementation, and coordinating E&S data collection across subsidiaries. The cocoa sustainability team based in United Kingdom oversees sustainability programs. A Sustainability Governance Structure, including a Sustainability Steering Committee, provides oversight of sustainability-related risks and opportunities (SROs) at both corporate and subsidiary levels.
In Côte d’Ivoire, GCBCCI maintains a team responsible for E&S compliance and performance monitoring, reporting to the General Manager. An EHS Officer oversees the implementation of safety standards in line with corporate policies and procedures. Cocoa Bean supplier assessments are managed by the Compliance Department, while engagement with cooperatives is led by an EUDR Unit, composed of two GIS specialists and four field officers. This unit conducts traceability assessments, due diligence of cocoa cooperatives, and ensuring compliance with EUDR requirements. In anticipation of the expansion, GCBCCI will expand the EHS Officer responsibilities to include oversight the ESMPs implementation during construction and operations. The company will also assess the need for additional field officers to support its growing engagement with new cocoa bean suppliers (ESAP #3).
**Emergency Preparedness and Response**
GCBCCI has an Emergency Preparedness and Response Standard Operating Procedure (EPR SO) covering scenarios such as spills, leaks, power outages, gas explosions, water shortages, and flooding. The facility is equipped with fire hydrants, extinguishers, sprinklers, smoke detectors, and alarms; however, emergency signage was noted to be insufficient in the warehouse and production areas. Workers receive regular emergency training and fire drills, and joint exercise with the Industrial Area fire department and the Office National de la Protection Civile are planned for December 2025. In line with ESAP #1, GCBCCI will update its EPR SO by conducting a Fire Safety Audit for the expanded facility and implementing any required corrective actions arising from the assessment.
**Monitoring and Reporting**
Key operational parameters are routinely monitored and reviewed with senior management at site level. Core E&S indicators—including water and energy consumption, GHG emissions, waste generation, responsible sourcing, and local employment—are defined by the Corporate Sustainability team and consolidated in a dashboard for senior management oversight. Environmental and social reporting follows Bursa Malaysia’s Sustainability Reporting Guide, using GRI and TCFD as references.
Within the Sustainability Department, a Committee Working Group manages the implementation of controls in relevant department which monitors direct-sourcing cocoa bean suppliers to ensure compliance with deforestation-free requirements. Supplier and contractor performance is assessed in accordance with the company’s Code of Conduct and Sustainable Procurement Policy and Procedure. As a member of the International Cocoa Initiative (ICI), GCBCCI also evaluates child labor risks and implements a Child Labor Monitoring and Remediation System (CLMRS) for selected large cocoa bean suppliers in our sustainability program. GCBCCI reporting and monitoring efforts will be consolidated into a framework that will be updated regularly in line with the operational needs (ESAP #1).
**Supply Chain**
GCB sources cocoa from several countries, including Côte d’Ivoire, Ecuador, Indonesia, Nigeria, Guinea, Liberia, Uganda, and the Dominican Republic. This diverse footprint exposes the Group to significant risks related to child labor, forced labor, and habitat conversion. To manage these risks, GCB has established a comprehensive system comprising a country-level risk assessment covering human rights and forced labor, a sustainable procurement policy and procedure and supplier onboarding and monitoring protocols. The company also implements farmer-support programs on good agricultural practices and pesticide reduction in collaboration with specialized NGOs through sustainability programs.
Significant efforts have been made to de-risk the cocoa supply processed in the San Pedro facility. These measures include the use of third-party satellite imagery and GIS mapping specialists, complemented by in-house experts, to identify sourcing areas that are free from habitat conversion. GCBCCI has developed a Supplier Code of Conduct (CoC) that sets mandatory requirements for all cocoa suppliers, including cooperatives and SITAPA. The CoC requires compliance with national legislation, respect for human rights and decent labor standards, including the prohibition of child and forced labor; promotion of workplace health and safety, maintenance of product traceability, and adoption of sustainable practices to conserve natural habitats and prevent habitat conversion. The CoC also includes a grievance mechanism for suppliers. Supplier audits are conducted by GCBCCI’s Compliance Team, and serious violations may lead to contract termination.
PS2: Labor and working conditions
Globally, GCB employs 1,876 direct workers. At the time of appraisal, GCBCCI employed 301 staff under open-ended contracts (contrat à durée indéterminée – CDI) and 49 under fixed-term contracts (contrat à durée déterminée – CDD), with women representing 10 percent of the workforce. Upon completion of the plant expansion, total employment is expected to increase to approximately 500 workers. Cleaning and security services are provided by third-party contractors. The Human Resources function is overseen by an on-site HR Manager, with periodic support from the Corporate HR team to ensure that local labor practices are aligned with Group policies and standards.
**Human Resource Policies and Working Conditions**
GCB has a Group-wide HR frameworks that applies to all direct and contracted workers and covers (i) hiring procedure; (ii) human rights and labor practices; (iii) business ethics and code of conduct; (iv) remediation for discrimination at the workplace; (v) remediation of child policy in the supply chain; (vi) disciplinary procedure; (vi) whistleblower procedure; (vii) internal grievance procedures; (vii) zero recruitment fee provisions and (viii) measures to address discrimination, sexual harassment and child labor risks.
In Côte d’Ivoire, working conditions are defined in an HR Manual aligned with national labor regulations. All GCBCCI employees have written contracts, receive payslips, and are covered by medical insurance. Plant employees work in three rotating eight-hour shifts, totaling 40 hours per week. Although there is no trade union, 14 worker representatives have been elected for a two-year term in line with Ivorian labor law. These representatives hold regular meetings with HR management and operate under the applicable national Collective Bargaining Agreement.
All direct workers undergo induction, HR orientation, and medical fitness-for-work checks at hire, as well as biannual medical examinations. A fully equipped medical facility is available on site. No workers are accommodated on the premises, and the company provides free transportation for staff working night shifts.
**Labor Grievance Mechanism**
GCB has a corporate Internal Grievance Procedure applicable to all subsidiaries, allowing direct employees and contracted workers to raise concerns. At the San Pedro facility, grievance boxes are available, but their visible placement may discourage use due to concerns about confidentiality. The current policy lacks provisions for anonymous submission and does not include a structured, time-bound process. In 2025, GCBCCI recorded five grievances, mainly related to salary issues.
As part of ESAP #4, GCBCCI will revise its Internal Grievance Procedure to align with IFC PS2 requirements by (i) clarifying available channels; (ii) ensuring confidentiality and non-retaliation; (iii) establishing a dedicated and confidential pathway for GBVH-cases; (iv) extending coverage for contracted workers, and (v) introducing a time-bound resolution process. Grievance boxes will be relocated to more discreet areas and sensitization sessions will be conducted for all workers to strengthen awareness and trust in the mechanism.
**Occupational Health and Safety**
At the corporate level, GCB records and reports OHS performance, conducts root-cause analyses of serious incidents, and implements corrective and preventive actions. No fatalities have occurred over the past three years. In 2024, the corporate Lost Time Injury Frequency Rate (LTIFR) was 24, with most incidents recorded at processing facilities in Indonesia and Malaysia. GCBCCI applies an Occupational Health and Safety Procedure consistent with corporate requirements and national regulations. All contractors and visitors receive safety induction training on hazards associated with processing operations.
OHS risks at the San Pedro plant are relatively limited, as production is highly automated and monitored from a centralized control room and maintenance work is performed only equipment is fully shut down. While the ESIA included a basic OHS risk assessment, GCBCCI has implemented a robust HIRAC process to systematically identify, assess, and mitigate workplace hazards.
Ahead of the planned facility extension, GCCCI will update its HIRAC process to address construction-related risks. The results will be integrated in plant’s OHS procedures. A dedicated officer will be appointed to oversee OHS management during construction, ensure contractor compliance with OHS requirements, and collect and report OHS performance data for contracted workers, (ESAP #5).
**Workers Engaged by Third Parties**
GCBCCI engages third-party workers primarily for logistics activities, including transport of goods and staff. Contractor selection and oversight are led by the Logistics Department, with support from the HR and the EHS Officer, who jointly conduct the due diligence prior contracting. This process verifies compliance with national labor and OHS requirements, timely payment of wages, provision of PPEs, delivery of safety and induction training, and confirmation of minimum 18 years of age requirements.
**Supply Chain**
At corporate level, GCB participates in multi-stakeholder initiatives aimed at preventing child and forced labor in global cocoa supply chains and is a member of the International Cocoa Initiative (ICI). In Cote d’Ivoire, where child labor and OHS, risks remain significant, GBCCI currently sources from 88 cooperatives, a number expected to increase with the planned expansion. Key risks include hazardous tasks such as carrying heavy loads, use of machetes, and exposure to crop protection chemicals. As the sourcing footprint grows, strengthened due diligence and enhanced monitoring will be required.
Since 2023, GCBCCI has implemented a supplier management system that includes a CLMRS aligned with the ICI methodology. Prospective cooperatives complete a Sustainable Procurement Questionnaire, and results inform targeted remediation measures, including training on good agricultural practices, financial literacy training, and community development initiatives.
To support the expansion, GCBCCI will commission a third-party review of its supply chain management system—including the CLMRS— to ensure alignment with internal policies and Good International Industry Practice (GIIP). The system will be extended to all new suppliers, and any identified gaps will be addressed through time-bound corrective action plans, (ESAP #6).
PS3: Resource Efficiency and Pollution Prevention
**Resource (Energy/Water) Efficiency**
The processing plant is connected to the national electricity grid and through two transformers with capacities of 3,500 kVA and 2,500 kVA. A biomass boiler of over 3 MW, using cocoa shell residues as feedstock, provides steam for the cooking process and contributes to resource efficiency and waste valorization. To ensure operational continuity during grid interruptions, GCBCCI maintains eight diesel-fueled generators, each with a capacity of 1,500 kVA.
Water for steaming, cooling, and potable use is supplied by SODECI and tested in accordance with WHO standards. GCBCCI monitors water use across its facility, including withdrawal, disposal, consumption, and water intensity. The plant operates a closed-loop cooling system that reduces freshwater demand, increase recycling, and minimize environmental impacts.
**Greenhouse gas (GHG) emissions**
Since 2024, GCB has begun calculating and reporting emissions from its cocoa processing operations. Scope 1 and Scope 2 emissions primarily result from electricity consumption and fuel use associated with processing, logistics, transport, and administrative operations.
In line with ESAP #2, GCBCCI will update its emissions modelling and prepare a comprehensive GHG inventory for the expanded San Pedro facility aligned with the international GHG Protocols and IFC Performance Standard 3 requirements. This enhanced baseline will support the development of a carbon reduction roadmap, including an assessment of feasible measures, associated costs, expected GHG reduction potential, and proposed implementation timelines.
**Noise prevention**
Noise generated from plant equipment, processing activities, and associated traffic and logistics activities has resulted in exceedances of permissible levels in some areas, as identified through ambient noise monitoring conducted by a licensed operator. In line with ESAP#2, GCBCCI will update the ambient noise mapping across all work areas and conduct daytime and nighttime measurements at the nearest sensitive receptors to verify compliance with national regulations and the World Bank Group General EHS Guidelines.
**Wastewater management**
GCBCCI operates an on-site wastewater treatment plant with a capacity of 29 m³/day, originally designed to accommodate future production expansion; therefore, no upgrade is currently required. Recent improvements include installation of online COD analyzers and dissolved oxygen (DO) monitors, to strengthen process control and performance. The WWTP is operated by trained personnel. Treated effluent is discharged into the municipal network in accordance with regulatory requirements, while sludge is stored in a designated area collected by a licensed operator. Effluent quality is regularly monitored against applicable discharge standards, with results recorded and submitted to the relevant authorities. Monitoring data indicates compliance with national requirements issued by the Department of Environment and alignment with the World Bank Group General EHS Guidelines.
**Waste Management**
GCB implements a 3R (Remove, Reduce, Recycle) program. In Cote d’Ivoire, GCBCCI follows a site-specific waste management procedure. Solid waste consists mainly of organic residues such as cocoa shells, which are used as feedstock for the biomass boiler, alongside typical non-organic waste such as metal scraps, plastics, paper, wood, jute bags, and general waste. Emissions from the boiler are monitored and in compliance with national requirements. Waste is segregated into hazardous and non-hazardous categories using clearly labeled bins. Non-recycle waste is transferred to licensed third-party licensed providers, and medical waste from the on-site first-aid clinic is stored in designated containers before collection by authorized handlers.
**Hazardous Materials management**
Hazardous materials used at the San Pedro facility include fuel for generators, oils and lubricants, fatty acids, smudges, and small quantities of pesticides. The site has designated hazardous storage area and relies licensed third-party contractors for handling and disposal. However, gaps in storage practices were observed during the visit, requiring upgrades to meet regulatory requirements and Good International Industry Practice. As part of the ESMP updates for the expansion, GCBCCI will implement a Hazardous Materials Management Plan and upgrade all storage areas to ensure they are proper coverage and containment (ESAP #2).
Pesticide use is limited to warehouse pest control and is carried out only by licensed operators using approved products. The company does not handle fertilizers directly but sets clear requirements for their safe and responsible use by suppliers through its Supplier Code of Conduct.
PS4: Community Health, Safety and Security
The plant is located within a designated industrial zone that is not accessible to the public and is physically separated from nearby communities. While the nature of processing activities does not present high external risks, the company’s emergency preparedness and response procedures cover non-routine scenarios and are considered adequate to address potential interactions with external parties.
**Road Traffic Safety**
Transportation of cocoa beans to the plant is managed by cooperatives or the bean-washing facility. Beans are delivered to collection points or warehouses, from which 30-ton trucks transport them to the San Pedro plant via the national road network. During the four-month peak harvest season, approximately 16–20 trucks access the facility daily. While traffic volumes are expected to increase with the expansion, transport routes will continue to rely on the upgraded national road network, limiting movements through local villages. As part of ESAP#2, GCBCCI will assess road safety risks associated with the increased truck movements and, where relevant, provide defensive-driving training to transport operators.
**Security Personnel**
Security at the San Pedro plant is provided by unarmed personnel from a vetted third-party contractor. The site relies primarily on passive security measures, including perimeter fencing, access-controlled entry points, and CCTV surveillance. Security staff are equipped with appropriate PPE and required to comply with the company’s Code of Conduct.
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
GCBCCI sources cocoa beans from areas of Côte d’Ivoire where risk of natural and critical habitat conversion remain. To manage these risks, the company applies its corporate Forest and Traceability Policy in its direct sourcing network, which includes screening of deforestation and protected areas using Satelligence; (ii) 100 percent polygon-level mapping of all supplier plots with GPS coordinates capturing historical land-use, and (iii) a Supplier Questionnaire. Data are stored in an internal database that uses radar-based remote sensing to detect deforestation occurring after the EUDR cut-off date of December 30, 2020. Plot flagged as potentially non-compliant are placed on hold pending field verification by GCBCCI’s team.
In Côte d’Ivoire, a dedicated team applies this traceability system all cooperatives. Upon arrival at the warehouse, cocoa beans are segregated and labeled according to certification or compliance category (Rainforest Alliance, Fairtrade, or EUDR). Each lot is assigned a unique identification number and associated client and market destination information. As of 2025, approximately 85 percent of cocoa beans sourced is EUDR-compliant or certified, with compliance target by early 2026. As part of the IFC investment, GCBCCI will assess the effectiveness of its Sustainable Traceability System and disclose results through its annual reporting obligations. Any gaps identified will be addressed through time-bound action in line with ESAP #7.
