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:
Dorado Ivory has a health, safety, and environmental (HSE) policy, developed in 2021, for the Dorado plant in Toumodi. The policy seeks to ensure safe and healthy working conditions and to prevent injuries and ill health among employees and stakeholders. Dorado has also established a Corporate Social Responsibility (CSR) strategy based on four key pillars: environmental sustainability initiatives, direct philanthropic contributions, ethical business practices, and economic responsibility. The company has yet to develop corporate policies covering environment, occupational health and safety, and supply chain management for the RCN processing plants and sourcing operations. Dorado will develop and implement corporate policies consolidated in an ESMS that meets IFC Performance Standards requirements, comprising: (i) policy; (ii) identification of E&S risks and impacts; (iii) E&S management programs, including relevant SOPs; (iv) E&S management organization; (v) an Emergency Preparedness and Response Plan; (vi) E&S monitoring and reporting; (vii) stakeholder engagement; and (viii) a community grievance mechanism. In addition, the company will develop and implement climate adaptation measures within its ESMS to address physical climate risks associated with increased temperatures, heatwaves, heavy rainfall, flooding, drought, and water stress. These measures will include: (i) a Heat Stress Management Plan for workers, incorporating appropriate prevention and response measures; (ii) climate-related emergency preparedness and response procedures addressing flooding, worker safety, site access, and electrical hazards; and (iii) water management measures to improve water efficiency and confirm that project water use does not adversely affect water availability for surrounding communities during periods of water scarcity (ESAP #1).
Identification of E&S Risks and Impacts:
E&S risks and impacts of the Bluejay RCN processing plant have been assessed against Ivorian E&S legal and regulatory requirements. An ESIA for the proposed RCN processing plant was completed in 2025, and, as part of the ESIA process, an E&S Management Plan (ESMP) and E&S Monitoring Plan were developed. Key mitigation measures required in the ESMP include: (i) establishment of an environmental and emergency preparedness team; (ii) implementation of an Emergency Preparedness Plan (“Plan d’Operation Interne” POI); (iii) compliance of air emissions and noise levels with Ivorian regulatory limits; (iv) collection and disposal of process and runoff waters and solid and hazardous wastes; and (v) safe traffic management within and around the plant. Dorado will update the ESIA to broaden its scope to cover climate change risks and the 2.5 MW rooftop solar system and to further align the assessment with the IFC PS (ESAP #2).
E&S Management Plans and Programs:
As part of the development of its ESMS, Dorado will develop and implement E&S programs for its RCN processing plants, consistent with IFC PSs. These will include a supply chain management program, road safety management plan, and labor influx management plan, ensuring that E&S risks associated with sourcing operations, transport activities, and the construction workforce are proactively managed (Ref. ESAP #1).
Organizational Capacity/Competency: At the existing plant, E&S responsibilities are managed by the CSR department, working in coordination with HSE and HR sub-departments to verify alignment with the corporate vision and strategy. The CSR department reports to the Plant Director, under the overall supervision of the Managing Director, and oversees worker safety, hygiene, environmental monitoring, and contractor compliance. At the corporate level, the company has recently appointed a Head of Sustainability to strengthen overall coordination, reporting, and policy alignment. As part of IFC’s investment, Dorado will further reinforce its E&S capacity by full-time, suitably qualified and experienced E&S Manager to lead the implementation of the ESAP and the ESMS (ESAP #3).
E&S Training:
Dorado has developed a training program for the existing operation covering security, safety, environment, food hygiene, and HR procedures. As part of ESAP #4, the company will enhance its training plan to include: (i) OHS induction training for all workers; (ii) modules on its corporate E&S policies, the grievance mechanism, and gender-based violence and harassment (GBVH); (iii) E&S management plans and role-specific EHS SOPs, informed by workplace risk assessment and controls; (iv) fire prevention and first aid training; and (v) awareness on infectious diseases.
Emergency Preparedness and Response:
As per its ESMS (Ref. ESAP #1), the company will develop and implement a site-specific Emergency Preparedness and Response Plan (EPRP). The EPRP will address: (i) risk identification and response procedures; (ii) emergency communication protocols with local fire authorities and, as needed, neighboring communities; (iii) provision of emergency response equipment, including firefighting equipment; (iv) training and drills; (v) inspection and maintenance of emergency equipment; and (vi) definition of key performance indicators (KPIs) and performance reporting.
E&S Monitoring and Review:
As per its ESMS (Ref. ESAP #1), the company will develop and implement an E&S monitoring and reporting procedure specifying KPIs covering: (i) compliance with E&S legal and regulatory requirements; (ii) leading and lagging OHS indicators, including Lost-Time Injury Frequency Rate (LTIFR); (iii) resource efficiency, including energy and water consumption and efficiency per ton of products; (iv) pollution control, including ambient and point-source air emissions, noise levels, and the quality and volume of liquid effluents against applicable guideline values; (v) the storage, management, and disposal of solid and hazardous waste through licensed service providers; and (vi) food safety.
Supply Chain Risk Assessment and Management System:
In 2025, Dorado purchased 92,000 MT of RCN, sourced directly from cooperatives across CDI. With the proposed IFC financing, Dorado aims to increase its RCN sourcing volume to 150,000 MT by 2027. Dorado currently purchases its RCN directly from approximately 100 suppliers, of which 80% are cooperatives and 20% are aggregators. For the existing processing plant, the cooperatives are responsible for supplying the RCN, bagged, to the warehouse, using their own transportation. Besides the warehouse at the processing facility, Dorado has leased additional warehouses in Bondoukou, Bouake, and Toumodi, with a capacity of 104,000 tons managed by Dorado’s own team and CMI, where farmers can deliver their crops. Dorado contracts service providers to transport RCN from these leased warehouses to the processing facility. Supplier data for cooperatives and aggregators are recorded in the cooperatives’ database, including supplier name, region where cooperative headquarters are located, and legal and administrative information; traceability is currently limited to this level, a situation common across sectors where farm-to-facility traceability has yet to be an established practice. Dorado will launch a Rainforest Alliance preparation program in June 2026 with an initial pilot of 10 suppliers, supporting them in achieving certification on a phased basis over 2028–2030 and representing approximately 4,000 tons of certified RCN. Dorado also intends to launch a digital traceability program with a specialized service provider, through which all suppliers will progressively digitize their data, including product information and warehouse GPS coordinates. These initiatives will be complemented by the implementation of the Supplier Code of Conduct and supply chain management program under the ESMS (Ref. ESAP #5).
The field visit to cooperatives confirmed that the majority of RCN farmers within the supply chain own and operate their plantations. These established plantations typically feature trees aged between 10 and 20 years. To further strengthen this assurance, Dorado will conduct on-the-ground assessments of cashew-producing areas to confirm natural habitat (e.g., woodland, savanna), as described in the PS6 section with respect to cashew sourcing (Ref. ESAP #5).
Dorado will develop and implement a corporate Supply Chain Management System (SCMS) for its RCN sourcing operations. The SCMS will include: (i) the adoption of a Supplier Code, to be incorporated into all purchase agreements and signed by all suppliers, which will define E&S and OHS responsibilities; explicitly prohibit child labor, forced labor, and conversion of natural habitats; and promote fair and equal treatment, freedom of association, collective bargaining, appropriate working hours and wages, and a safe and clean working environment; prohibit the use of pesticides under World Health Organization (WHO) Class Ia and Ib products; require the protection of biodiversity values, including no conversion of natural habitats and the avoidance of RCN sourced from protected areas; (ii) the development and implementation of a 2027–2032 sustainable RCN procurement strategy, including the lifetime of IFC’s investment, assurance that all RCN sourcing is risk-screened by Dorado or a designated service provider, and a time-bound plan for the expansion of the Rainforest Alliance (RA) preparation program suppliers; (iii) the formalization of Dorado’s sourcing procedures, including a supplier risk screening a procedure for verification of habitat conversion risk in sourcing areas, contractual enforcement of the Supplier Code of Conduct’s provisions, establishment of a dedicated RCN sourcing team or partnership with a service provider, training requirements covering the Supplier Code of Conduct and monitoring; and (iv) an annual audit of the effective implementation of its Supplier Code (ESAP #5).
PS2: Labor and Working Conditions
As of March 2026, the company employed 96 permanent staff (24 women and 72 men), alongside 88 international workers on fixed-term contracts (3 women and 85 men) supporting current operations. In addition to its directly employed workforce, Dorado engages outsourced personnel to meet seasonal workforce needs. For the 2024–2025 RCN purchasing season, about 1,210 casual workers were engaged, of whom 687 were women, primarily performing manual tasks such as RCN de-shelling, kernel peeling, and classification. An additional 100 workers were employed under local term contracts. Seasonal peaks also involve loaders, forklift drivers, and cleaning staff.
Casual and seasonal workers are engaged through a third-party service provider, while permanent and fixed-term staff are directly employed by Dorado. To strengthen and manage its seasonal workforce, Dorado intends to engage two additional labor agents to manage the recruitment and employment of the casual workforce for the CDI plants.
Human Resources (HR) Policies and Procedures:
Dorado’s HR framework is set out in its Internal Regulation (April 2021), Code of Business, Code of Conduct, and Human Rights Policy, which together address non-discrimination, gender equity, prevention of harassment and violence, and prohibition of forced and child labor. The policies and procedures are aligned with the Ivorian Labor Code and the objectives of IFC PS2.
All HR policies apply to permanent workers and to all direct and indirect employees who receive onboarding on the HR Manual, payroll systems, and EHS policy and procedure requirements upon hiring. Dorado commits to fair and equitable wages and other conditions of employment; recognizes employees’ right to freedom of association; provides safe and healthy working conditions; and prohibits child and forced labor. Employee training on OHS will be further enhanced as part of the expanded scope and continued development of the E&S/OHS training program under its ESMS (Ref. ESAP #4).
Working Conditions and Terms of Employment:
The company engages third-party service providers to support the recruitment of permanent, fixed-term, and casual staff. For permanent positions, a designated firm manages the recruitment process: departments submit job descriptions for posting and pre-select three candidates, who are then reviewed by HR and approved by the Executive Manager. Dorado sets employment terms in accordance with the Ivorian Labor Code and PS2, and consistent with SMETA (Sedex Members Ethical Trade Audit) requirements. All employees have signed contracts detailing the employment type, dates, working hours, salary, leave, benefits, and rights, and have access to pay slips showing wages, statutory social security deductions, and other HR information. Administrative staff work from 8:00 a.m. to 5:00 p.m., while processing operations run on three eight-hour shifts. Annual leave entitlements are consistent with the Ivorian Labor Code. Casual workers benefit from a mandatory rest day after every five working days. Overtime is compensated in line with the applicable provisions of the Labor Code. For the upcoming cashew season, the company will engage two new service providers to manage casual and fixed-term contracts, further strengthening the management of its seasonal workforce.
Non-discrimination and Equal Opportunity:
Dorado’s Code of Business Ethics and Human Rights Policy promote non-discrimination and equal opportunity and prohibit forced labor, child labor, harassment, and violence. Dorado will also confirm that its contracted labor agents adopt an anti-discrimination commitment and apply non-discriminatory recruitment practices.
Workers’ Organizations:
In accordance with the provisions of the Ivorian Labor Code, Dorado recognizes employees’ right to freedom of association. Workers’ representation is established through a workers' committee, composed of two delegates representing permanent employees and two delegates representing casual workers, who engage with Dorado’s management team, including the Managing Director, the Operations Director, and the HR Manager, providing a forum for dialogue on labor and OHS issues.
Grievance Mechanism:
Dorado has a formal worker grievance mechanism that allows employees and casual workers to raise concerns directly with management in writing — bypassing immediate supervisors. The company will update the mechanism and strengthen its implementation to further align it with PS2 requirements, including: identifying appropriate support services for complaints related to gender-based violence and harassment (GBVH); establishing a referral pathway to these services; and providing external training to its Gender Committee to enable it to perform its duties effectively and sensitively. The grievance mechanism and referral pathway will be accessible to all workers, including casual staff (ESAP #6).
In addition, Dorado will require its contracted labor agents to develop their own grievance mechanisms in line with PS2 requirements and to make Dorado’s mechanism available to their workers. All workers will be trained on reporting incidents of harassment, discrimination, non-compliance with legal requirements, and misconduct through the grievance process, which is managed by the HR Department and includes monitoring of corrective and disciplinary actions through to case resolution (Ref. ESAP #7).
Protecting the Workforce:
Dorado prohibits child labor and forced labor across its operations, in accordance with the provisions of the Ivorian Labor Code and its own HR requirements and employs only workers who meet the applicable legal minimum age. The same requirements will apply to the Bluejay Plant.
Workers Engaged through Third Parties:
In addition to the casual workers recruited and employed through labor agents, Dorado engages contractors for transport and security functions at its RCN processing plant. To strengthen the management of its contracted workforce, Dorado will develop and implement labor- and OHS-related requirements for the qualification and selection of contractors, embed E&S provisions in bidding documents and contractual agreements with all contractors, and implement a contractor management plan that includes the monitoring of contractors’ labor management practices and a contractor training plan to support the effective implementation of these provisions (ESAP #7).
Occupational Health and Safety:
The inherent hazards of an RCN processing plant include working at height, in hot and noisy environments, and in confined spaces; working with energized equipment and hazardous products; and ergonomic hazards. During the roasting of cashew kernels, the shells release cashew nut shell liquid (CNSL), a caustic oil that can cause skin burns, infections, and eye damage. Dorado’s RCN processing is highly automated, which minimizes workers’ exposure to these risks, and the company provides Personal Protective Equipment (PPE), such as gowns, gloves, masks, and earplugs, to the entire workforce, including casual workers, according to the hazard profile of each workstation. Dorado also operates an on-site clinic staffed with a nurse providing first aid to all staff, and workers undergo annual health check-ups.
As part of its ESMS (ESAP #1), Dorado will develop a site-specific OHS management system for its RCN processing plants and the rooftop solar system, including an OHS policy, an OHS management plan, SOPs, and the definition and monitoring of leading and lagging OHS indicators, including temperature and noise levels in the plant, with corrective actions taken as needed. Dorado will also establish an OHS Committee at the processing facility and develop and implement a comprehensive training plan, tailored to workstation hazards, for all worker categories.
Supply Chain:
The cashew sector in CDI is not considered significantly affected by child labor. Where children are present, their involvement is primarily limited to the collection of nuts on family-operated plantations — an activity typically carried out by female members of producer households, with cashew revenues shared at the household level. Based on available information and consultations with key stakeholders in the cashew sector, children's presence on plantations is generally limited to family support activities and is reported to occur mainly outside school hours, including during holiday periods.
The key PS2 risks relate to the still-developing traceability of the supply chain and potential OHS risks affecting workers involved in sourcing operations. As described under PS1, Dorado will develop and implement a Supply Chain Management System (Ref. ESAP #5) to manage these residual risks in line with IFC Performance Standards requirements.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency:
The processing of RCN is an energy-intensive process. Dorado’s RCN processing plant is connected to the national electricity grid through a transformer. Dorado monitors its energy use. The company has implemented several resource efficiency measures, including a solar system of 2.5 MW that generates approximately 288,000 kWh per month and boilers that are fully fueled by cashew shells. A CNSL processing facility with a capacity of 250 MT per day is already operational at the existing factory, producing approximately 60 MT of oil per day. A biomass plant will be constructed on site by 2028.
Two biomass boilers use cashew shells as feedstock produce steam for the roasting process. In case of power outage, Dorado has installed two diesel generators of 500 KVA and 600 KVA capacity.
Dorado uses water for steaming and cooling processes, as well as potable water for its workforce. Water is obtained from an on-site borehole. Water testing is currently conducted at the facility to verify that the drinking water meets WHO drinking water standards. Dorado monitors air emission sources and pollutants, including boilers, fugitive dust, CO, NOx, and particulate matter. Going forward, Dorado will develop and implement a resource efficiency management plan for energy and water and establish KPIs for assessing its energy and water usage and efficiency per ton of product (Ref. ESAP #1).
Greenhouse Gas (GHG) Emissions:
Project GHG emissions are expected to remain below 25,000 tCO2e per year, including Scope 1 emissions of 245 tCO2e/year and Scope 2 emissions of 2,585 tCO2e/year. The facility’s solar PV system is expected to reduce GHG emissions by approximately 1,086 tCO2e per year.
Pollution Prevention:
The main environmental risks associated with the RCN processing unit relate to air emissions from the on-site biomass boilers, wastewater discharge from the steaming process, sewage from the workforce on site, noise, boiler ash, and storage of diesel and cashew nut shell liquid (CNSL). For food safety, air inflow within the cashew processing plant may be a source of contamination.
Air Emissions and Noise:
Dorado’s maintenance team performs routine monthly maintenance on both biomass boilers that are located on site in CDI. Emissions measurements comply with the requirements set by the Ivorian Air Quality Decree, as well as the General EHS Guidelines and the Food and Beverage Processing Guidelines.
Dorado will monitor ambient air quality, undertake ambient noise mapping across all its workstations, and provide earmuffs for its workers where noise levels are above 70 dBA. The company will measure noise levels during daytime and nighttime (Ref. ESAP #1).
Wastewater:
Wastewater from the steaming process and CNSL processing, as well as sewage from the workforce on site, is handled through an in-situ wastewater treatment plant with a capacity of 350 m3 per day. As part of its monitoring plan under the ESMS, Dorado will monitor and report on the volume of wastewater generated and the effluent quality (Ref. ESAP #1).
Management of Solid and Hazardous Waste:
Solid waste at the RCN processing plant is mostly characterized by organic waste from cashew shells (used as feedstock for the biomass boilers), testa (from peeling the kernel skin), general waste from the cafeteria and other facilities, jute bags, and metal scraps. Waste segregation practices are implemented. Dorado has developed and implemented a waste management plan in line with PS1. Licensed service providers are used for evacuation of hazardous waste.
Pesticide Use and Management:
Dorado has signed a contract with a licensed provider for fumigation. As per its ESMS, Dorado will develop and implement a pest management plan (Ref. ESAP #1).
PS4: Community Health, Safety, and Security
Food Safety Management System:
Dorado currently holds an up-to-date British Retail Consortium (BRC) food certification license, which is recognized by the Global Food Safety Initiative. Annual audits are performed prior to renewal. The company will obtain the same license for Bluejay.
Traffic Safety:
Suppliers are responsible for transporting and delivering RCN to the factory. Dorado does not own, operate, or contract any transport fleet. During the site visit, hazards associated with truck movements were observed at the entrance and within the factory premises, including vehicle-pedestrian interactions and traffic congestion during deliveries. In accordance with the ESMS (Ref. ESAP #1), Dorado will develop and implement a traffic management plan for the factory premises and access areas under its control. The plan will establish procedures for managing vehicle and pedestrian movements, designated parking and unloading areas, traffic flow and signage, speed limits within the site, driver induction and site safety rules, emergency response procedures, and monitoring of compliance by suppliers and drivers while on site. The objective is to minimize traffic-related risks to workers, visitors, contractors, suppliers, and surrounding communities.
Security:
The Dorado Plant will be situated in a fenced industrial park. Dorado will hire security guards from a security agency and implement a security management plan as required by ESAP #1 (Ref. ESMS).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Dorado sources its RCN directly from cooperatives and aggregators, mostly situated in central, northern, and northeastern CDI in the West Sudanian Savanna and Guinean Forest Savanna ecoregions. These regions of production are of concern for natural habitat conversion, with a tripling in cashew production in the last two decades. Remote sensing imagery and available landcover datasets show this conversion came from both fallow lands and savanna, with some sourcing areas situated in historically consolidated agricultural landscapes. Areas of high and medium risk for natural habitat conversion have been identified around purchasing centers throughout the northern and central regions of CDI.
According to the supply chain review detailed above in PS1 and ESAP #5, Dorado will develop and gradually implement a SCMS, which includes a Supplier Code of Conduct prohibiting the sourcing of RCN from recently converted natural habitats, and the establishment of risk screening procedures through contractual agreement with a service provider. areas will be further analyzed by Dorado and/or a service provider via on-the-ground assessments of habitat conversion risk in RCN-producing areas significant natural habitat conversion confirmed.
An annual independent verification audit of the effective implementation of the Supplier Code will be conducted.
