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
Identification of E&S Risks & Impacts: OCP has undertaken an EIA for the project in accordance with statutory requirements and is in line with IFC PSs requirements. The key E&S risks identified in the EIA have been discussed in the relevant sections below. The main impacts are potential dust and traffic impacts associated with the construction phase and potential community impacts during the operation phase. Environmental management and monitoring plans (EMPs) are included in the EIA. As per the ESAP (#1), OCP will ensure implementation of the EMPs during both construction and operation and ensure their inclusion in the contracts signed with the contractors.
E&S policy and management systems: OCP has a sustainability strategy, supported by several group-level policies including sustainability, environmental management, human rights, labor and occupational, health and safety (OHS). These policies apply to all OCP sites and facilities including this project and are publicly disclosed on OCP website: https://www.ocpgroup.ma/sustainability/policies-and-standards.
OCP’s Jorf Lasfar facility has implemented quality and environmental management systems certified as per ISO 9001 and 14001 requirements, respectively. Also, the plant has been certified by the International Fertilizer Association and Protect & Sustain, which is a product stewardship program of the global fertilizer industry. The proposed PG storage will be part of the Jorf Lasfar facility and therefore, the existing management system will be extended to the proposed storage as well.
As regards the project, the project consultant has an HSE management system certified as per ISO 45001 and its own set of policies and procedures. For the purposes of the project, these (project consultant’s) systems are implemented for all contractors. All contracts include a specific Annex (“Annex S”), which describes HSE requirements to be implemented by the contractor and their sub-contractor. The contractor has also prepared and implemented an HSE plan covering all key requirements as per Annex S.
E&S organization and capacity: OCP’s Chief Sustainability & Innovation Officer, a member of the Strategic Committee, is overall responsible for defining strategic sustainability direction and ensuring its implementation The corporate sustainability and innovation office (CSIO) is focusing on a number of strategic sustainability projects e.g. clean energy, non-conventional water, PG, environment, green Ammonia, climate change and Carbon neutrality. PG storage project is, therefore, led by the CSIO team. Each strategic business unit has its own sustainability team. HSE management at the Jorf Lasfar is led by its HSE team.
OCP has a Board level committee on Audit, Risks, and ESG Issues, which reports progress in ESG areas, along with performance against established ESG targets to the Board of Directors. Since 2023, an ESG Committee has been established with top executives from various departments, which establishes a unified view of ESG aspects, promoting corporate governance and implementing the ethics roadmap. The ESG committee reports progress on these aspects to the board level committee.
For the project, the contractor has a safety manager and five safety supervisors on-site. Each sub-contractor also has a safety team. The project consultant has a dedicated team focusing on construction, quality and HSE management (HSE manager and five HSE supervisors).
Emergency Response Plan: OCP has a corporate standard on emergency response planning. All facilities in Morocco have a Crisis Management Plan in place. In line with the project requirements, both the project consultant and the construction contractor’s HSE plans include an emergency response procedure and require regular training and mock drills to be conducted. During the site visit, it was noted that the site has an infirmary.
and ambulance. An emergency response plan has been developed for the project and a hooter is available on-site to declare emergencies. As per ESAP(#2), OCP will ensure that an emergency response procedure is developed and implemented for the operation phase of the project.
Monitoring and Review: At the group level, OCP publishes a global reporting initiative (GRI)-aligned Sustainability report and the monitoring and review processes are described in detail in the report(https://www.ocpgroup.ma/sites/default/files/2025-12/OCP_Sustainbility_Report-2024.pdf). For the project, the project Consultant has outlined specific processes to monitor and measure the effectiveness of their and contractor’s HSE plans/programs as well as compliance with relevant Moroccan legal requirements. Weekly HSE meetings are conducted to review the status, which is attended by both project consultants and contractor HSE teams. Weekly and monthly reports are prepared by the project consultant which include sets of key E&S performance indicators and submitted to OCP. Weekly walkdowns and regular site inspections are conducted. Any safety observation (SOR) need to be resolved by the contractor within agreed timeline. The project consultant also does deep analysis of SOR to identify preventive actions.
PS2- Labor and working conditions
The project is expected to employ up to 300 workers at the peak of construction and 50 workers during operation and maintenance (O&M). The majority of workers will be hired by the contractors and the general contractor must send all new workers’ applications to be validated by the OCP’s Act4Community program, (described under stakeholder engagement) to verify that the workers come from the local communities. The contractors and OCP have HR teams responsible for management of the workforce during construction and operations. During the site visit, 87 people were working on the site.
HR policies and procedures: OCP has publicly disclosed corporate policies on Responsible HR Management, General Human Capital, Working Conditions, Diversity and Inclusion, HSE; Social Dialogue; Training and Development and a Supplier Code of Conduct. OCP’s corporate policies and Code of Conduct aligned with PS2 requirements and are also applicable to the project.
Working conditions and terms of employment: Based on discussions and document review during the site visit, construction working hours are 8 hours/day during the week and four hours on Saturday. Overtime compensation is provided for extra hours as per applicable legal requirements. There is an on-site canteen, toilets and drinking water points. The on-site canteen does not seem to provide sufficient space for workers to rest after their meal. Improvements are needed in on-site rest area for workers (ESAP #3). There are no workers staying on-site.
The contractors’ project managers and supervisors are in direct contact with the workers from the subcontractors, and they monitor the timesheets every day and verify salary payments regularly. The project consultant is responsible for compliance of contractors (on behalf of OCP), thus the project consultant shall develop and implement contractor management procedures to verify compliance with labor and working conditions – both during construction and operation phases (ESAP#4).
Child or forced labor: OCP has made clear commitments for prevention of child and forced labor in several of its abovementioned policies. No instances of child or forced labor were noted during the visit.
Freedom of association: OCP has made public commitments to freedom of association under its general human rights policy and working conditions policy. There are three unions at OCP’s Jorf Lasfar facility and the OCP HR department works closely with the worker delegates from the unions.
Non-discrimination: OCP has a corporate policy on diversity and inclusion which includes commitments to non-discrimination practices, providing equal opportunities, creating a workplace free of harassment, implementing supportive internal mechanisms for special needs.
OCP has included commitment to prevention of harassment in its code of conduct, general human rights and diversity and inclusion policies. To strengthen its approach to gender based violence (GBV), OCP is working to develop a stand-alone GBV or sexual harassment policy.
Third party workers and OHS management: OCP has a publicly disclosed OHS policy and implements OHS management system aligned with ISO 45001 standards. The company has corporate standards/tools on HSE risks analysis, incident-accident investigation, HSE management for contractors and monitoring of HSE performance. A dedicated corporate team leads this management system across all sites, implementing tailored risk mitigation programs. Each site also has its HSE team to identify, assess, and address safety risks. Also, health and safety at work committees are established with representatives from different departments. All units and sites carry out self-assessments and implement the related recommendations. OHS performance results are disclosed in the Sustainability Report.
For the purposes of the project, project consultant’s systems are being implemented for all contractors and the HSE requirements are described in Annex S of the contract. The contractor has developed an HSE plan, which was reviewed by and agreed with the project consultant before mobilization. A construction readiness review was conducted with the contractor with OCP also involved. Based on the document review, all key systems including tool box talks, HSE induction, job safety analysis, protective personnel equipment, permit to work system, OHS signage, incident recording and investigation, safety inspections etc. were noted to be implemented. Also, digital tools for pre-qualification of vehicles, equipment and drivers and documenting observations and inspections were noted to be implemented. Incentive and award system for good performance as well as a system of managing non-compliances is in place. The project has not had any lost time injuries or fatalities since the start of construction. The same system will be implemented through the project consultant for the operation phase. As per the ESAP (#4), OCP will share the contracts signed with the O&M contractor(s) and their HSE Plan with IFC.
Considering the natural characteristics of PG, an assessment of the dose to workers has been estimated as part of the EIA for the operation phase. Based on results of atmospheric dispersion calculations, estimated annual dose to workers at the storage site even with conservative conditions, is expected to be significantly lower than the annual limit recommended for workers by the IAEA for occupational exposure (i.e. 20 mSv/year). OCP has developed a radiological environmental monitoring program (REMP) as part of the EIA to track any key impacts, especially regarding radiological aspects. As per the ESAP(#5), OCP will implement the REMP and monitoring will be conducted at the frequencies specified in the REMP through competent independent service providers and any corrective actions identified based on the monitoring results will be implemented within reasonable timelines.
Grievance mechanism: Through its corporate policies on social dialogue, diversity and inclusion and human rights, OCP has committed to implement grievance mechanisms across all OCP Group operations which are legitimate, and accessible. OCP has multiple channels including an ombudsman to receive grievances. The number and types of grievances received and their resolution is disclosed in the Sustainability Report. Since the workforce involved in construction and operation of the project will mainly be contract workers, OCP shall ensure that all contractors develop and implement a grievance mechanism accessible to all workers for both the construction and operations phases, in line with PS2 requirements (ESAP#4).
PS3-Resource Efficiency and Pollution Prevention
Energy use: The electricity requirement of the project is about 70,509 MWh per year. This power will be supplied from the existing cogeneration at Jorf Lasfar plant. No new power generation is needed for the project.
OCP has already committed to and disclosed its carbon neutrality roadmap with a voluntary goal of being carbon neutral by 2040. Various initiatives are being taken by OCP to reduce its carbon footprint. Greenhouse Gas emissions (GHG) are monitored and disclosed as part of the sustainability report. As no additional power generation is needed for the project, the estimated GHG emissions due to fuel consumption from operational equipment (trucks and machinery)
is expected to be 733.44 tonnes of Carbon Dioxide (CO2) equivalent per year during construction phase and 3,810 tonnes of Carbon Dioxide (CO2) equivalent per year during the operational phase, mainly due to use of trucks.
Prevention of soil and groundwater contamination: The entire bottom of the Phase 1 storage area and the inner slope of the perimeter will be lined with a composite membrane comprising of a high-density polyethylene (HDPE) textured geomembrane (2 mm thick) followed by 60 cm thick layer of mechanically compacted PG, to protect the membrane during the construction of the drainage system and also provides an additional barrier against seepage. PG will be extracted from the Borrow Area to make this coverage. A drainage system will be installed on top of the composite membrane, which will direct seepage to the seepage collection ditch, and finally to the plant's settling basin for reuse. Similarly, a runoff collection ditch will collect sedimentation from the top of the PG pile and runoff from rainfall from the slopes of the pile, and direct it by gravity flow from the storage area, through the conduits to the settling basin. The water from the settling basin will be pumped back to the plant for reuse in the phosphoric acid production units for recycling, particularly for use in PG transport by slurry mode.
As part of the EMP, the company will establish observation wells around the PG storage area to monitor groundwater level and quality. Also, various equipment will be maintained regularly and compaction of the PG stack or any changes will be monitored regularly.
Water Supply and Wastewater Management: Water for construction is supplied from the existing desalination plant at OCP Jorf Lasfar. Bottled drinking water is provided for drinking. As regards sanitary wastewater, mobile toilets (chemical toilets) have been provided and are regularly maintained, therefore, no wastewater is discharged.
During operation, the water consumption of the PG storage will mainly be for make-up water. The consumption is expected to be about 355 m3/h in year 1,245 m3/h in year 2 and about 45 m3/h in year 3. The water used for this purpose will be supplied from the existing desalination plant and thus no additional water impacts are expected due to the project.
The project has a closed loop for seepage and run-off, and therefore no discharge is expected. The seepage and run-off from the storage area will be collected and reused as described above.
Air and Noise Emissions: As per baseline air quality assessment, the area has dust (PM10) levels higher than national standards at two locations close to the project site. During construction, there can be potential dust related impacts due to excavation, backfilling and movement of materials through trucks. During the site visit, it was noted that periodic water sprinkling is undertaken to minimize the dust. Also, all construction vehicles are pre-approved for their appropriateness. Pollution and speed control measures are also implemented. The construction will end in April 2027 and thus impacts will only be limited for this period.
During operation, the PG will be transported in wet form as a slurry. As part of the EIA, modelling was conducted (using the ADMS – 6 model) for two scenarios – (a) baseline condition, which is currently subject to wind generated dust from the uncovered ground and (b) the site with the disposal area constructed. The results of the modeling showed a significant decrease in the emissions of PM10 and PM2.5 resulting from construction of the disposal area, due to wet storage of the PG. Therefore, the project will have a positive impact on air quality through reduction of overall dust emissions.
As regards noise, given the location of the project, type of operations and distance between the project and residential areas, no significant noise impacts are expected as per the EIA. According to the EIA, if there are any significant noise impacts, these will be raised via the grievance mechanism.
Hazardous materials and waste management: Project consultant’s and contractor’s HSE plans include requirements on hazardous materials and waste management. Waste bins were provided on-site and waste was noted to be managed appropriately.
PS4-Community Health, Safety and Security
Security Personnel: Project site is fenced off and access is restricted to unauthorized persons. Unarmed guards are provided to secure the site and access control by a third-party security company retained by OCP. As part of its responsible local communities’ relations policy, OCP has committed to responsible security practices aligned with the Voluntary Principles on Security and Human Rights.
Assessment of Potential Radiation Exposure : As part of the EIA, a study of radiation exposure was conducted for the project which included the results of the radiological characterization of the PG itself and the modeling of the atmospheric dispersion. Multiple samples of PG from OCP’s production lines were tested in May to July 2025 for its activity concentrations. The results are compared against reference value for naturally occurring radionuclides (other than K-40) set at 1 Bq/g (i.e. 1000 Bq/kg) in accordance with the IAEA Safety Guide RS-G-1.7. This value is used as a screening tool to determine whether a NORM (non-radioactive material) falls under regulatory control. All materials tested by CNESTEN, the Moroccan technical and scientific authority on radiation, were either not detected or had values below the reference values All tested radionuclides were either not detected, or values were below the reference values.
The dispersion modeling was carried out using highly conservative assumptions, including the maximum measured values, continuous public presence, and Stability Class F, representing very stable atmospheric conditions which limit dispersion. According to the dispersion modeling results included in the EIA, the calculated annual dose in areas with human presence remains are below the IAEA limit of 1 mSv/year. The annual dose was also assessed at five points around the stock, in areas with regular public presence. Even under the most conservative assumptions, the calculated annual dose remains below the IAEA limit of 1 mSv/year.
Considering the PG activity and dispersion modelling results, OCP has developed a radiological environmental monitoring program (REMP) as part of the EIA to track any key impacts, especially regarding radiological aspects. As per the ESAP(#5), OCP will implement the REMP and monitoring will be conducted at the frequencies specified in the REMP through competent independent service providers and any corrective actions identified based on the monitoring results will be implemented within reasonable timelines.
Dust and traffic impacts: As per the EIA, there could be low to moderate impacts due to dust and traffic during the construction phase (expected to end in April 2027). The EIA has identified mitigation measures, which will be implemented as part of the EMP. These will include: periodic water sprinkling, use of highways and national roads as much as possible and avoid sensitive areas (e.g. schools, health centers, douars, etc.), enforcement of speed limits on and around the site, road safety training of drivers, etc. Also, as per the ESAP (#6), a project-specific community grievance mechanism will be implemented.
Access to Cemetery: Given the proximity of a cemetery, 55 m northwest of Borrow pit, as per the EMP, OCP will establish a protective perimeter at the cemetery in consultation with the commune and community representatives and ensure continued access to the cemetery by the public.
