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 and Social Policies. PRAN Group has adopted a corporate environment, health, safety and quality (EHSQ) policy for all its companies. This policy covers all E&S risks and impacts of PRAN’s operations and is communicated to all employees and workers, and other relevant stakeholders through displays. The company has established E&S management system certified as per ISO9001(Quality management), ISO14001(Environmental management) and ISO45001 (Occupational Health and Safety) across all its operations, including at MAL and PDL production sites. The ESMS is aligned with IFC PS1 requirements. Both units have obtained hazard analysis and critical control point (HACCP) certification for food safety for products manufactured at their facilities, along with British Retail Consortium Global Standards (BRCGS) Certification. In addition, MAL is certified for Good Manufacturing Practices (GMP) while PDL has obtained ISO 22000 (Food Safety Management Systems) certification and is registered with US Food and Drug Administration (USFDA).
Identification of E&S risks and impacts. PRAN Group identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. The company also conducts annual identification of E&S risks in accordance with ISO14001, ISO45001, and ISO22000 standards as well as its ESMS requirements. The company has established and maintain processes for identifying the E&S risks and impacts of its operations consistent with good international industry practice (GIIP, such as the WBG EHS Guidelines) and utilizing standards tools such as HIRA (Hazard Identification and Risk Assessment) for workplace risk assessment. Comprehensive HIRAs have been developed for all production-related activities, with revisions being conducted at defined intervals. The Company has also prepared HIRAs for the expansion activities planned under the current project. Project Development Limited (the internal construction wing of the PRAN-RFL group) will be responsible for construction of new facilities planned under the project. The work will be carried out in accordance with the provisions of their existing EHS Manual, which clearly outlines - EHS and working condition requirements for construction activities, roles and responsibilities of relevant personnel for implementation and on-site monitoring, labor law compliance, alignment with IFC Performance Standards and WBG EHS Guidelines, and overall safety requirements.
The company also maintains separate legal registers for each facility, capturing key permits, approvals, their validity, and the renewal schedule. Both MAL and PDL currently operate with all required and valid E&S licenses and permits. The company maintains compliance with permit conditions and ensures regular reporting to regulatory authorities. There are no E&S related regulatory actions, show cause notices, legal cases against company operations.
E&S Management Programs. PRAN Group maintains ISO certified management systems, aligned with IFC Performance Standards, at MAL and PDL along with food safety and product quality certifications. As part of its management system, MAL/PDL has developed Standard Operating Procedures (SOPs) for waste management, chemical safety, contractor management, EHS monitoring, emergency response, etc. in accordance with WBG EHS Guidelines. Furthermore, a set of EHS KPIs, such as lost time injuries (LTI), fatalities, energy and water consumption, waste generation and EHS training hours, have also been adopted. These KPIs have been implemented at MAL and PDL and are regularly monitored.
To guide any future procurement of privately owned land for the facility expansions planned under the Project and as per ESAP#1, the Company will develop and adopt a Land Purchase Procedure (LPP). The LPP will ensure that all land transactions carried out through a willing buyer-willing seller process, and conducted in a fair, transparent, and well-documented manner consistent with nation regulation and IFC Performance Standard 5 requirements on willing buyer and willing seller. The procedure will include due diligence of the land parcels to identify and assess all landowners as well as any informal land user claims and will outline appropriate engagement, consultation, and negotiation processes with both landowners and land users. The settlement of any legitimate claims for the users should become a part of the overall land agreement and may include measures to address any economic or access-related impacts. A detailed documentation of this agreement process should be available for each transaction. The LPP shall be finalized and disclosed prior to undertaking any new land procurement under the Project.
Organizational Capacity and Competency. PRAN Group has an EHS organizational structure in place with defined roles, responsibilities, and authority to implement the ESMS at Group and plant-level. The personnel with direct implementation role and responsibility for E&S performance have the knowledge, skills, and experience necessary to perform the work. The corporate EHS team comprises of a General Manager (Manufacturing and EHS), who holds overall responsibility for overseeing EHS at the Group level and duly supported by an Assistant General Manager responsible for E&S management system implementation and compliance. The corporate EHS team is supported by dedicated EHS Managers and Fire Safety Officers at MAL/PDL and EHS coordinators at individual shop floor/department levels. At the PRAN Dairy Complex (PDC) at Shahjadpur (part of PDL), the EHS responsibilities are currently undertaken by the Quality team. As part of ESAP#2, the Company will appoint a dedicated EHS Officer for PDC, Shahjadpur to manage and oversee overall EHS function and ensure effective implementation of the ESMS.
E&S Training. The company has developed a detailed training calendar and trainings on different topics (e.g. EHS, Prevention of Sexual Harassment, Worker’s grievances, Life and Fire Safety) are being organized on a regular basis. PRAN will sustain its collaboration with dairy farmers at PDL and continue to organize capacity-building sessions with an emphasis on its Supplier Code, sustainable farming and animal welfare practices.
Emergency Preparedness and Response. The company has documented Emergency Response and Preparedness Plans (EPRPs) for MAL and PDL facilities, to deal with emergency scenarios, such as fires, hazardous chemical spills, and toxic gas release. PDL has installed gas detectors and alarm systems to promptly signal ammonia (toxic gas) release and has implemented response protocols with clearly displayed instructions across the facility. The EPRPs also outline specific procedures to be followed in case of climate-related incidents such as heavy rains, flooding, cyclones. Specific emergency response organization within the company has been defined with list of certified fire fighters, first aiders, etc.; external responders to be contacted during emergencies have also been identified. The facilities have designated fire safety officer and is supported by a team comprising of supervisors, fire pump operator and firemen...
MAL and PDL sites have valid fire license from Bangladesh Fire Service and Civil Defense Department (BFSCD). During the site visits, the facilities were noted to have fire detection, alarm and firefighting passive and active systems, fire hydrant, sprinklers and fire extinguishers, manual call points, fire exit signages, emergency lights and public address systems. The emergency evacuation plan was displayed appropriately at strategic locations within the units. The firefighting equipment is subjected to periodic inspection and regular life and fire safety (LFS) training is provided for workers. Mock drills are organized at unit levels by associating with BFSCD.
Monitoring & Reporting. The company regularly monitors E&S indicators including resource use (energy and water), emissions and ambient air quality, wastewater and effluent quality, noise levels, solid waste management, OHS performance, compliances and grievance redressal. Plant-level EHS Manager and Fire Safety Officer conducts internal audits on monthly/quarterly basis, while the corporate EHS Head organizes periodic meetings of all EHS personnel from PRAN production plants. The E&S performance of each facility, including MAL and PDL, are discussed, and challenges/best practices are shared at Group-level. A management review is conducted annually during which senior members of the PRAN management are present. External audits are organized regularly as per requirements of Group’s policies and management systems. Implementation effectiveness of EHS procedures during surveillance and recertification on E&S management system and food safety systems is also assessed.
PS2- Labor and working conditions
As of October 2025, MAL reported a total workforce of about 2,021 employees, of which 521 were female employees; PDL had an on-roll workforce of 4,594 employees with 1,633 female employees; no contractual or third-party workers are reported to be engaged at MAL and PDL sites. Warehouse and security operations are outsourced to other company within the PRAN group and are covered by same corporate policies and rules.
Human Resource (HR) Policies and Procedures, Working Conditions and Terms of Employment. PRAN Group has documented HR policies and procedures aligning mostly with the applicable national laws and IFC PS2 requirements, covering aspects such as recruitment, wages, working hours and overtime, prohibition of child labor and forced labor, sexual harassment and abuse, non-discrimination, freedom of association, etc. Appointment letters are issued to all workers at the time of employment and describe the working conditions and terms of employment. New employees receive induction training on HR policies and procedures. The company has also developed an employee handbook which is distributed to all staffs. The company has in place a functional Human Resource (HR) Information System (HRIS) to address and manage HR and labor related aspects of the Company’s operations. Company ensures workers’ salaries, overtime payments, festival bonus, leave benefits are aligned with the applicable statutory requirements. A detailed process has been established for regular monitoring of HR compliances through internal audits at regular frequency. Group HR team is accountable for these internal audits covering all PRAN factories, head office, sales & distribution offices.
PRAN arranges for employee accommodation at MAL and PDL, both within and outside the factory premises. At MAL, separate facilities are arranged for men and women, currently 60 women workers and 320 male workers are residing in the provided accommodation facilities. These facilities are shared with RFL Group employees. A An officers’ mess is operated within the MAL premises. All accommodations are equipped with beds, storage spaces, clean drinking water, sanitation facilities, fire safety arrangements, and food supplied from factory-operated kitchens. At PDL, separate women’s (550 residents) and men’s (650 residents) dormitories are maintained for PDL and RFL employees at Bangalpara. Both dormitories are located in properly designed high rise buildings and provided with requisite amenities for clean drinking water, sanitation, dining rooms, laundry services, fire safety, security, etc. Fire mock drills and fire safety audits are conducted, and the facilities broadly align with IFC EBRD Worker Accommodation Guidelines.
In addition to the bus transport for workers’ movement, PRAN operates shuttle boat services (only to safely cross the river) at MAL and PDL to support employee movement, as both facilities are located along the river. Dedicated ferry ghats have been constructed to ensure orderly and safe boarding and disembarkation. All boats are equipped with life jackets and buoys. PRAN has also developed dedicated HIRA and SOP for boat transportation, outlining hazards, control measures, and operational protocols to ensure safe transit for all passengers and has conducted boat safety trainings for the workers using this facility.
Workers Organization. There are no staff unions at MAL or PDL. However, the company has developed a Freedom of Association Policy and does not restrict formation of employee unions. Worker participation committees (WPCs) have been formed that have representation of workers (through an election process) and management and are tasked to discuss and resolve workplace issues. The WPC meets on a regular basis to discuss issues related to workplace and improvement of facilities.
Non-discrimination and Equal Opportunity. The company has a policy on Equal Opportunity which mentions about equal employment opportunities; no discrimination at MAL and PDL production plants was observed during the appraisal.
Worker’s Grievance Mechanism. The company has an internal grievance redress mechanism (GRM) which include multiple grievance intake points, such as in-person, grievance box to raise and address allegations including anonymously, if complainants so prefer, with provision of a Group and plant-level grievance committee. The grievances boxes have been placed in the worker changing rooms to allow workers to anonymously raise grievance without any risk of reprisal. The grievance redress committee has 12 members including 4 staffs and 8 workers. The committee meets on a regular basis and discusses with the management on redress of grievances.
Sexual Exploitation Abuse and Harassment (SEAH). The Company has established a Policy on Prevention of Sexual Harassment and constituted a specific anti-harassment committee, with trainings conducted on prevention of sexual harassment at the workplace. As part of IFC investment conditions and as per ESAP#3, the Company will formulate SEAH risk mitigation and management systems at MAL and PDL level and implement and monitor those systems and procedures. Company will procure the services of a local SEAH consultant to formulate, institute and train the relevant project stakeholders including security personnel on GBVH/SEAH Risk Mitigation and Management Systems based on a terms of reference agreed with IFC.
Protecting the Workforce. The company clearly indicates its commitment in respect of child labor and forced labor through its policies and employee manual. Employees are screened physically along with their respective documents to determine their age. No instances of child labor or forced or bonded labor were noted during the site visits.
Occupational Health & Safety (OHS) Management. The company has established an Occupational Health & Safety (OHS) Management System certified as per ISO 45001 Standards at MAL and PDL plants. To evaluate the implementation effectiveness and performance of the OHS management system, the company conducts regular internal audits. The company maintains health clinics within its premises. In the past 3 years, the company reports no fatal workplace accidents or incidents at MAL/PDL plants. The company conducts regular OHS training, including fire and emergency preparedness training, and first aid training for its operational personnel.
Supply Chain. PRAN sources agro-commodities like fruits and aloe vera from the farm supply chain and raw milk from dairy farmers. PRAN also procures processed products for MAL and PDL from local and international vendors, comprising of food (sugar, flour, milk powder, etc.) as well as non-food (packaging) items. PRAN's Supply Chain Management System (SCMS) and Supplier Code provide specific guidance on labor practices, OHS, and ethical standards for suppliers. The company utilizes a risk screening platform and conducts regular audits, including site visits, to assess Supplier Code implementation. The company builds awareness among third-party suppliers regarding the Supplier Code.
MAL is not involved in any contract farming arrangements for procuring agro commodities; it sources processed fruit pulp from PAL (a PRAN Group company that has contract farming agreements with farmers). IFC has been involved with PRAN Group (and specifically with PAL) in running an advisory program on ‘development and implementation of good agricultural practices (GAPs) for PRAN- RFL produce suppliers in Bangladesh’ to build capacity within PRAN to adopt sustainable contract farming practices and align with IFC PS requirements in relation to raw material sourcing. As per ESAP#4, the company will strengthen its due diligence of its agro commodity suppliers by augmenting the traceability of contract farmers and sourcing arrangements for fruits, aloe vera, and other agricultural commodities, through development of spatial mapping platform and improving monitoring/verification oversight against IFC PS supply chain requirements. The Company will arrange for an independent verification to be conducted on an annual basis to verify implementation effectiveness of the Supply Chain Management System and Supplier Code.
PDL has a well-established village-level milk collection system that provides farmers with additional income opportunities. Its dairy supply chain is structured around dairy hubs, which include village milk collection and chilling centers (VMCCs) and transport of chilled milk to the plant. PDL supports farmers through training on animal health, hygiene, and improved milk yields, delivered by a dedicated dairy academy team of supervisors and veterinarians. Regular training sessions are conducted using a defined curriculum, with attendance records maintained. SOPs for VMCCs are in place, and block supervisors ensure compliance and animal health monitoring, supported by health cards for each animal. PDL also uses an information system to track milk production and payments to milk farmers, enabling full traceability, and maintains a detailed database of all participating farmers.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency. MAL and PDL operations consume resources, such as electricity, gas, diesel, and water. Between Jul 2024 to Jun 2025, resource consumption for MAL included 4.4 million (kWH) of electricity purchased from the national grid; 1.3 million cubic meters of gas/month; 6.6 kilo liters (KL) of diesel/month and 5060 cubic meters of water/day. The resource consumption for PDL during the same reporting period included: 4.03 million kWH of electricity purchased from the national grid and 111.9 million kWH of electricity generated from gas generator based captive power plant; 30.2 million cubic meters of gas and approx. 1.9 million cubic meter of water. The company sources its energy requirements at MAL/PDL from national power grid power and from installed captive power plants with gas being used as the primary fuel. There is limited use of renewable energy at MAL/PDL, in form of solar lights being installed along internal roads. The company sources its water at MAL/PDL from its licensed groundwater wells and the extraction is monitored on a daily basis. The water is treated in-house through filtration and softening for various industrial and domestic uses. The company is actively engaging in initiatives to enhance resource efficiency and energy conservation and reduce its waste generation and has adopted specific targets in this regard.
Greenhouse Gases (GHG) Emissions. The project is expected to generate a total of 387,785 tCO2e per year. This consolidated estimate reflects direct emissions from PRAN’s operations (Scopes 1 and 2) as well as upstream agricultural emissions from raw milk production (Scope 3), which represent dominant share of the project’s carbon footprint. As part of its GHG emission reduction strategy, PRAN is planning for increased use of solar power at its manufacturing facilities.
Air Emissions. Air emissions from the Company’s operations are primarily from the captive power plants, diesel generator stacks and the boiler exhausts. MAL and PDL operate gas generator based captive power plants for generating power and also procures electricity from the national grid. Diesel generator sets provide backup power where required. The facilities also operates boilers, using gas as fuel together with exhaust heat boilers. Ambient air quality and stack emission monitoring are conducted, and the available results reviewed during appraisal indicate overall compliance with national standards and WBG EHS Guidelines. As part of the ESMS, PRAN has established monitoring program for air emission in line with permit conditions wherein boiler and DG set stack emissions as well as ambient air quality are monitored regularly using independent, accredited, 3rd party laboratories at fixed periodic intervals. The Company also conducts regular noise monitoring and the reported ambient noise levels from the industrial area and surrounding residential area is compliant with Bangladesh Standards and IFC EHS Guidelines.
Wastewater Treatment. Effluent treatment plants (ETPs) are available at MAL and PDL sites with secondary treatment for treatment of industrial effluent. Effluent quality is tested regularly, and results showed overall compliance with national standards and WBG EHS Guidelines. At MAL, total coliform concentration in the treated effluent was found to be exceeding the guideline value and PRAN informed of installing additional tertiary treatment units (multi grade filter and activated carbon filter) to address the issue. The installation of the additional treatment units at MAL is expected to be completed by early next year. In the milk supply chain of PDL, the existing mother hubs are also equipped with ETPs to treat the wash water generated from cleaning of farm cooling tanks and milk tankers. The new mother hubs, planned under the project, will each be equipped with ETPs.
Waste Management. PRAN operations generate electronic wastes, hazardous and non-hazardous wastes. The non-hazardous domestic waste is disposed through arrangement with the local service providers while the recyclable plastic waste and the electronic waste is transported to RFL Plastic Limited and RFL Electronics limited (PRAN-RFL Group companies). PRAN’s companies handle limited quantities of hazardous waste (e.g. cartridges, filters, used oil, chemical drums). During the site visits, it was noted that MAL has a dedicated hazardous waste store. PDL under another IFC investment (Project#47376) and as part of agreed ESAP, is building a dedicated hazardous waste storage facility..
Hazardous Chemicals. PRAN handles hazardous materials (mostly food processing chemicals) which are transported, stored, and handled as per national regulations. The company has in place a Standard Operating Procedure (SOP) for hazardous chemicals; the SOP offer essential guidance for storage and handling of hazardous chemicals and for addressing accidental spills, aiming to minimize the potential harm to both human health and the environment. The company operates hazardous chemical storage facilities equipped with built-in safeguards in accordance with SOP requirements.
PS4-Community Health, Safety and Security
PRAN’s MAL/PDL production plants are located within established industrial zones and have been designed, constructed, and are operating in compliance with the national building and fire safety codes. The company has obtained factory licenses from the competent authorities for all its operations. The company has established regular infrastructure and an equipment safety related inspection regime in compliance with local factory regulations. All high-pressure vessels, lifting equipment, and other critical equipment are tested on a regular basis by competent authority as per national standards and norms. The nature of the MAL and PDL operations does not present significant safety and security risks to nearby communities. However, there can be impacts due to the movement of vehicles on the access road to the facilities. Transport is used for receipt of raw materials and delivery of finished products. PDL also maintains a fleet of insulated tankers for transport of the milk from the mother hubs and collection centers to the factory; company vehicles are also used for delivery of the packaged milk to the distribution centers. The Company has developed and implemented transport management plans and also arranges regular training of drivers on road safety.
Security Personnel. Security guards are employed indirectly through another company withing the PRAN group. MAL and PDL do not employ armed security guards at facilities. Security guards are appropriately trained to interact with the neighboring communities and workers. The company reports no security incident in the past involving security personnel and local community members at these two locations. The security personnel are also provided with training on basic safety, first-aid, fire safety and emergency response.
