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
E&S Management Systems (ESMS) and Policy. Allied has established several ESMS building blocks, including policy statements (environmental, OHS, ESG and compliance), hazard identification tools, E&S audits, resource use and emissions monitoring, and emergency preparedness arrangements. These are supported by ISO-certified management systems (ISO 14001, ISO 45001, ISO 9001) and a Code of Business Ethics and Principles covering compliance and integrity commitments (e.g., anti-bribery, conflicts of interest, whistleblowing, and accountability).
IFC’s review indicates that these elements operate as a combination of management systems and standalone procedures rather than a single, integrated, risk-based ESMS. Documentation does not yet demonstrate consistent ESMS “line of sight” from policy to standardized risk screening and assessment across operations, to risk-based management programmes, to monitoring indicators, corrective action closure, and formal management review. The company’s recent expansion into fertilizer blending—alongside existing co-located chemical operations—introduces an elevated and more complex EHS risk profile, increasing the need for consistent governance, oversight and traceability across sites and activities. As the project transitions from installation completion into testing, commissioning and trial production, effective E&S management becomes increasingly dependent on a structured ESMS to manage operational risks across the company’s co-located, multi-site chemical and fertilizer activities.
The company will develop and implement an integrated ESMS aligned with IFC PS1, consolidating environmental, social, labour and governance (including ethics and compliance) requirements into a unified framework. The ESMS will standardize risk identification, management programmes, monitoring and management review across all operations, with clear roles, competencies and training to demonstrate consistent risk-to-action traceability and performance-based implementation (ESAP #1)
Identification of E&S Risks and Impacts. Allied applies operational risk identification processes, including structured hazard assessments, site inspections, and E&S audits, which capture routine risks associated with chemical handling and fertilizer blending (e.g. dust generation, occupational exposure, material handling, and equipment and utility interfaces). These processes are complemented by an ESIA prepared in line with national requirements, which identifies key environmental, occupational health and safety (OHS), and community risks associated with fertilizer blending operations, including emissions, waste management, utilities, and traffic-related interactions. Reflecting the relative immaturity of the ESMS described above, these arrangements remain primarily compliance- and task-oriented, with limited integration of process-based hazard analysis and structured evaluation of non-routine and emergency scenarios. Existing documentation does not yet provide a comprehensive assessment of low-probability, high-consequence events, nor an integrated analysis of cumulative and interface risks across co-located operations, including fertilizer blending, sulphonation, and sodium silicate facilities that share infrastructure, utilities, workforce, and emergency response systems. This limits the company’s ability to fully identify and manage compound-level and escalation risks associated with site-wide operations. During commissioning and early operations, effective risk identification is necessary to manage operational and process-related risks across the company’s co located facilities.
To strengthen alignment with PS1 and GIIP, and as part of ESMS implementation, the company will undertake a process-informed, site-wide risk identification and cumulative/interface assessment, proportionate to the project’s risk profile. This will include process safety–relevant hazards and potential major accident scenarios associated with co located chemical operations, as well as climate-related physical risks and their interaction with operational hazards; and transport and traffic risk assessment covering interaction with public road users. The results will be consolidated into a risk register and integrated into operating procedures, emergency preparedness arrangements, and ESMS implementation (ESAP #2).
E&S Management Programs. In line with the ESMS components described above, Allied has established operational procedures and controls to manage routine E&S risks, including hazard controls, emergency preparedness arrangements, inspection and audit programmes, and corrective action tracking. These arrangements support the management of day-to-day risks associated with fertilizer blending and chemical handling operations. Reflecting the relative immaturity of the ESMS, these measures are not yet structured as formal, risk-based management programmes linked to the full risk identification process. Existing controls are largely compliance-driven, with limited evidence of risk-based prioritization, defined responsibilities and timelines, measurable performance indicators, and traceability between identified risks—including process safety and cumulative/interface risks—and corresponding mitigation and monitoring systems. This constrains the company’s ability to demonstrate systematic and performance-driven management of operational and site-wide risks.
To strengthen alignment with PS1, the company will establish formal E&S management programmes under the ESMS, aligned with the outcomes of the process-informed risk identification work. These programmes will define risk-based mitigation measures, responsibilities, timelines, and performance indicators, and will be implemented across co-located operations to support consistent execution, monitoring, and continuous improvement (as per ESAP #1, informed by ESAP #2). Specific E&S management programs will cover as a minimum resource efficiency and pollution prevention, hazardous materials management, community health and safety integration and security management. (ESAP #3)
Organizational Capacity and Competency. The company maintains corporate and site-level E&S capacity, including an EHS management function and site-based personnel supported by training on operational safety and emergency awareness. These arrangements provide a baseline capability to manage routine risks associated with chemical manufacturing and fertilizer blending.
In line with the ESMS maturity described above, organizational arrangements remain largely operational in focus, with limited formalization of ESMS governance and unclear accountabilities across corporate and site levels, particularly for process safety, cumulative risks, and coordination across co-located facilities. Training is also not yet structured within a formal, risk-based competency framework and does not consistently cover key risk areas.
This constrains the company’s ability to demonstrate sustained capacity to implement an integrated ESMS across its multi-site operations. Strengthening will be undertaken under ESAP #1, including clarification of roles and development of a structured competency and training framework aligned with identified risks.
Emergency Preparedness and Response. Aligned with its operational activities, the company has established site-level emergency preparedness arrangements, including an Emergency Response Plan (ERP), defined response roles, evacuation procedures, and periodic drills. The ERP covers core response functions such as communication, evacuation, first aid, firefighting, and coordination with external emergency services, providing a baseline framework for managing routine incidents.
However currently, emergency preparedness remains largely procedural and inward-focused. The ERP is not yet systematically informed by process-based risk identification and does not fully address credible process safety and cumulative risk scenarios, including dust fires, utility failures, or escalation across co-located fertilizer, sulphonation, and sodium silicate operations. In addition, the current framework does not yet explicitly incorporate climate-related physical hazards (e.g., extreme rainfall/flooding and extreme heat) and their implications for emergency response capacity, site-wide coordination, and potential community exposure.
Based on the outcomes of ESAP #2, the company will update and implement a risk-based, scenario-driven ERP that: (i) reflects credible process safety, cumulative/interface, and climate-related physical hazard scenarios; (ii) establishes coordinated response arrangements across co-located facilities; and (iii) includes periodic scenario-based drills and testing aligned with identified risks. (ESAP #4)
E&S Monitoring and Reporting. In line with its ISO-certified systems and regulatory requirements, the company undertakes E&S monitoring through inspections, audits, and tracking of resource use and emissions, supported by follow-up of corrective actions. These processes provide a baseline level of oversight for routine operational performance across its chemical and fertilizer operations.
At present, monitoring arrangements are not yet fully structured as a risk-based, integrated system. In particular, documentation provides limited evidence of defined performance indicators linked to key risks, systematic tracking of corrective actions against specific risk drivers (including process safety and cumulative risks), and formalized management review processes to support adaptive management.
This limits the company’s ability to demonstrate systematic, performance-based monitoring and continuous improvement aligned with PS1 requirements. To address this, monitoring and review arrangements will be strengthened under the ESMS per ESAP #1, through the establishment of an integrated, risk-based monitoring framework, incorporating indicators aligned with priority risks, structured tracking of corrective actions, and periodic management review to support informed decision-making and continuous improvement.
PS2- Labor and working conditions
At appraisal, the project operates with a moderate, operations-focused workforce, comprising a core team of 61 direct employees (including 15 female staff) structured across management, technical, and operational roles. Operations are primarily supported by direct employees, with contractors engaged for specialized and non-routine activities (e.g. maintenance, logistics, material handling), particularly during commissioning, maintenance, and peak periods. This provides a flexible workforce model aligned with the project’s operational needs, combining stable in-house capacity with targeted contractor support.
Human Resources (HR) Policies. Allied Chemicals has established an HR framework supported by formal policies, including an HR Policy Manual and Code of Business Ethics. These set out commitments to fair treatment, non-discrimination, prohibition of child and forced labour, worker welfare, and business integrity, providing a baseline alignment with PS2 principles. In line with the relative immaturity of the ESMS described above, the framework remains largely policy-based, with limited procedural detail, enforceability, and integration into a structured management system. Coverage of contractor and supply chain labour management is also incomplete, and implementation, monitoring, and reporting are not yet systematically evidenced.
The company will strengthen and operationalize its HR framework, including formal procedures applicable to all worker categories and integration into the ESMS, with strengthened contractor requirements and accessible grievance arrangements. (ESAP #5)
Working conditions and Terms of Employment. The HR framework establishes general provisions on working hours, remuneration, worker conduct, and disciplinary procedures, consistent with national labour legislation, providing a baseline structure for employment management. At the implementation level, gaps remain in the definition and standardization of employment terms, including wage structures and payroll transparency, leave administration, overtime calculation, and termination processes. In addition, consistent application across direct and contracted workers is not yet systematically demonstrated.
These gaps will be addressed under ESAP #5, through the formalization and operationalization of labour management procedures covering all worker categories, including clear and enforceable terms of employment, structured grievance mechanisms, strengthened OHS management, and consistent implementation and monitoring across sites and contractor activities.
Workers’ Organizations. Allied recognizes workers’ rights under national law to form and join workers’ organizations; however, arrangements are not yet supported by formalized procedures or mechanisms to ensure consistent application across all worker categories. Evidence of structured worker representation, engagement, or consultation processes remains limited. In addition, there is limited evidence of a documented and accessible grievance mechanism that is consistently implemented and monitored across direct and contracted workers. These gaps will be addressed under ESAP #5, including explicit commitments on freedom of association, establishment of structured worker engagement mechanisms, and implementation of a formal grievance process accessible to all workers, integrated into the ESMS for consistent application and oversight.
Child Labour, Forced Labour, Non Discrimination and Equal Opportunity. The company has established policies prohibiting child and forced labour and promoting non-discrimination and equal opportunity, aligned with national legislation and ILO standards. These provide a baseline framework consistent with PS2, supported by measures such as age verification and prohibition of coercive practices. Current documentation however indicates that these commitments are not yet fully operationalized, with limited evidence of systematic monitoring, compliance verification, and defined remediation procedures, including consistent application across all operations and worker categories. These gaps will be addressed under ESAP #5, through the establishment of formal monitoring and compliance mechanisms and integration into the ESMS to ensure consistent implementation and oversight in line with PS2.
Protecting the workforce. The company has established measures to address harassment and misconduct, including a zero-tolerance Sexual Harassment Policy supported by investigation procedures and existing grievance channels, providing a baseline framework aligned with PS2. Consistent with the relative immaturity of the ESMS, these measures are not yet fully integrated within a comprehensive labour management framework. In particular, risks related to GBVH/SEA and protection of vulnerable groups are not systematically addressed, and survivor-centered response procedures are not consistently defined or applied across all worker categories.
These gaps will be addressed under ESAP #5, through the integration of GBVH/SEA risk management measures, survivor-centered protocols, and alignment within the ESMS to ensure consistent implementation and oversight across operations and contractors.
Workers Grievance Mechanism. Allied Chemicals has established a formal Employee Grievance Mechanism, supported by multiple reporting channels, investigation and appeal procedures, and safeguards on confidentiality and non-retaliation. These arrangements provide a baseline framework for worker grievance management. However, the mechanism is not yet fully operationalized in line with PS2, with limited evidence of systematic case tracking, defined resolution timelines, and consistent accessibility across all worker categories, including contractors, as well as limited coverage of sensitive grievances.
Building on the strengthening of the labour management framework under ESAP #5, the company will establish and operationalize a Worker Grievance Mechanism aligned with IFC PS2, applicable to all worker categories, with multiple confidential reporting channels (including anonymous options), clear procedures for submission, tracking, and resolution with defined timelines, and specific provisions for handling sensitive complaints (including GBVH/SEA) in a survivor-centered manner. The mechanism will be integrated into the ESMS, with systematic case logging and periodic management review to ensure effective implementation and continuous improvement. (ESAP #6)
Workers Engaged by Third Parties and contracted workforce. As indicated previously, at appraisal, the facility was transitioning into commissioning, with operations primarily supported by direct employees. There is a Contractor Management Policy covering selection, induction, and OHS, providing a baseline framework for contractor engagement. However, consistent with the ESMS maturity described above, arrangements are not yet fully aligned with PS2, particularly regarding labour conditions, access to grievance mechanisms, non-discrimination, and GBVH/SEA risk management for contractor personnel, with limited evidence of consistent oversight across activities. These gaps will be addressed under ESAP #5, through strengthening labour management procedures to ensure full coverage of contractors and integration into the ESMS for consistent implementation and monitoring.
Occupational Health and Safety (OHS). Allied has established an ISO 45001-aligned OHS framework, including hazard identification, incident reporting, workforce training, and compliance processes, providing a baseline platform for managing routine risks in line with PS2 intent. Currently however, OHS arrangements remain partially developed and not fully aligned with GIIP. Key risks include dust/fire hazards, worker exposure, boiler/steam failures, mechanical and electrical hazards, and interface risks from co-located facilities, which are not yet supported by process-informed hazard assessments, structured exposure monitoring, or task-specific controls, nor systematically assessed for cumulative impacts. Recorded incidents (including electrocution, burns, and injuries) indicate residual risks and gaps in control effectiveness.
From a PS2 perspective, while foundational systems exist, the company does not yet demonstrate systematic, risk-based management of worker health and safety across all operations and worker categories, limiting alignment with requirements on safe and healthy working conditions.
Building on ESMS strengthening under ESAP #1 and labour management improvements under ESAP #5, the company will develop and implement a risk-based OHS management program aligned with IFC PS2 and the WBG EHS Guidelines, including: (i) undertaking process-informed hazard identification and risk assessment covering operational and co-located facility risks; (ii) establishing structured monitoring of key occupational exposures (e.g. dust, noise, and heat); (iii) defining and implementing task-specific control measures and procedures commensurate with identified risks; and (iv) strengthening incident investigation and root cause analysis, with corrective actions systematically tracked through the ESMS and trend analysis of incidents and verification of control effectiveness to support consistent implementation and continuous improvement across all worker categories. (ESAP #7)
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency. Allied tracks fuel, electricity, and water use through internal monitoring systems, with resource consumption typical of dry-process fertilizer operations and limited wastewater generation. Consistent with the relative immaturity of the PS1 ESMS, resource management remains compliance-focused, with limited evidence of baselines, performance indicators, benchmarking, or efficiency targets, and incomplete tracking of waste streams and disposal practices. This limits demonstration of systematic resource efficiency and pollution prevention in line with PS3 requirements. These gaps will be addressed under ESAP #1, through integration of performance-based resource management, waste tracking, and monitoring/review processes within the ESMS to support continuous improvement
Greenhouse Gas (GHG) Emissions. Allied tracks fuel and electricity use and associated emissions, with GHG emissions limited and consistent with dry-process operations, primarily from diesel combustion and purchased electricity, and screening-level estimates indicate emissions are expected to remain below the 25,000 tCO2e reporting threshold.
Air Emissions, Dust, Noise and waste. Fertilizer blending is based on a dry process, with dust emissions as the primary pollution pathway, particularly at feeding, transfer, and processing points. Baseline controls include dust capture and recycling systems, housekeeping, and spill prevention, supported by ISO 14001 and periodic monitoring. At present, pollution management remains largely compliance-focused, with limited evidence of a fully developed pollution prevention framework, including quantified baselines, structured monitoring, and defined performance indicators across environmental aspects.
To align with PS3 requirements, the company will strengthen pollution prevention within the ESMS, prioritizing dust control performance monitoring, combustion emissions management, and spill prevention, supported by defined monitoring parameters and corrective actions for continuous improvement.
Noise from mechanical equipment is expected to be localized within an industrial setting, with limited sensitive receptors; impacts are low to moderate and acceptable within the industrial boundary
Waste generation is limited and managed through outsourced collection arrangements, supported by basic housekeeping and spill prevention controls. Consistent with the relative immaturity of the ESMS, arrangements remain procedural, with limited evidence of structured waste classification, tracking, and contractor oversight aligned with PS3. These gaps will be addressed under ESAP #1, through integration of basic waste characterization, tracking, and monitoring processes within the ESMS to support consistent implementation and continuous improvement.
Hazardous Materials. Fertilizer blending uses a dry process, with hazardous materials largely limited to fuels and utilities (e.g. diesel), supported by baseline controls such as dedicated storage, secondary containment, and recognition of spill risks in operational assessments. Current arrangements, however, are not yet consolidated within a fully integrated, site-wide framework, with limited evidence of systematic coverage of loss-of-containment scenarios, escalation risks across co-located facilities, and coordination with emergency preparedness. These gaps will be addressed through ESAP #3, with implementation and ongoing management integrated into the ESMS under ESAP #1
PS4-Community Health, Safety and Security
Community Health and Safety, Transport and Emergency Preparedness. The project is located within an established industrial area with limited sensitive receptors, and community risks are typical of fertilizer blending and co-located industrial activities, including on-site operations, material handling, transport movements, and shared infrastructure. The controlled industrial setting limits direct community exposure to routine risks, with impacts generally site-specific and manageable.
However, as indicated above, current arrangements remain largely compliance-based, with limited evidence of a systematic assessment of low-probability, high-consequence and cumulative risks, including accident scenarios, hazardous material releases, traffic risks (including caused by contractor-operated transport and logistics activities), and interactions with public road users. In particular, integration of transport-related risks and cross-facility escalation scenarios into community health and safety (CHS) and emergency preparedness planning is not yet fully demonstrated. While internal safety and emergency measures exist, the framework does not yet reflect a comprehensive, risk-based approach aligned with PS4, including coordination with local authorities and structured community communication protocols.
Overall, given the nature and scale of operations and absence of sensitive receptors, residual community health and safety risks are expected to be low to moderate, subject to the implementation of ESAP #2, #3 and #4, which will define and validate credible scenarios and corresponding control measures.
Security Personnel. Security arrangements are limited to access control and asset protection within the industrial compound., under ESAP #1, the company will formalize security management procedures (including conduct expectations and escalation protocols) and ensure linkage with the project level grievance mechanism through ESMS implementation to align with PS4 and applicable human rights principles.
