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Environmental & Social Review Summary
Project Number
51991
Company Name
MOVIT PRODUCTS LIMITED
Date ESRS Disclosed
May 20, 2026
Country
Uganda
Region
Africa
Last Updated Date
May 20, 2026
Environmental Category
B - Limited
Status
Pending Approval
Sector
Soap and Cleaning Compound (Soap, Detergent, etc.)
Industry
Manufacturing
Department
Regional Industry - MAS Africa
Project Description
Movit Products Limited (“MPL” or “the Company”) is a personal care and hygiene products company manufacturing body care, baby care, and haircare products across 10 Eastern and Southern African countries including Uganda, Kenya, Zambia, Democratic Republic of Congo (“DRC”), Malawi, Burundi, Rwanda, South Sudan and Tanzania. The company's products are manufactured at the MPL facility situated in Kampala, Uganda. To further support its production capacity and extend its regional presence, the company plans to construct an additional plant as part of its operational expansion.
The new plant will be constructed in a 28-acre greenfield property in Soga Village, Kibaha District, Coast Region in Tanzania. The site is classified as modified habitat with no overlaps with protected or Alliance for Zero Extinction (AZE) sites; and is leased from the Tanzania Investment Special Economic Zones Authority (“TISEZA”). MPL intends to engage an EPC Contractor to undertake the civil works for the Tanzania plant but the Company will be responsible for installation of equipment and machinery. The MPL Tanzania plant will contribute to the company’s expansion program into eastern and southern Africa by establishment of a new plant in Tanzania for manufacture of personal care and hygiene products that will include packaging, storage, and dispatch of finished goods. Operations will be supported by utilities and ancillary infrastructure such as power generation, water supply, wastewater treatment, warehousing, offices, and internal transport and logistics, and will be undertaken within the purpose built industrial site.
The new plant will be constructed in a 28-acre greenfield property in Soga Village, Kibaha District, Coast Region in Tanzania. The site is classified as modified habitat with no overlaps with protected or Alliance for Zero Extinction (AZE) sites; and is leased from the Tanzania Investment Special Economic Zones Authority (“TISEZA”). MPL intends to engage an EPC Contractor to undertake the civil works for the Tanzania plant but the Company will be responsible for installation of equipment and machinery. The MPL Tanzania plant will contribute to the company’s expansion program into eastern and southern Africa by establishment of a new plant in Tanzania for manufacture of personal care and hygiene products that will include packaging, storage, and dispatch of finished goods. Operations will be supported by utilities and ancillary infrastructure such as power generation, water supply, wastewater treatment, warehousing, offices, and internal transport and logistics, and will be undertaken within the purpose built industrial site.
Overview of IFC's Scope of Review
IFC E&S review of the proposed investment included (i) visit to MPL Factory in Kampala, Uganda and the proposed site in Kibaha, Tanzania in March and April 2026. (ii) Meetings with the MPL Uganda and corporate management team including the Safety Health Environment and Quality (SHEQ) Manager and the Human Resources (HR) Manager); (iii) meetings with workers and contracted staff at the operational Uganda plant; (iv) Meetings with institutional stakeholders in Tanzania including land, environment and village administration officers; (iv) review of E&S documents and information provided, including company E&S policies and procedures, E&S monitoring records and environment health and safety (EHS) audits for existing facilities/operations in Uganda; and (v) review of E&S Impact Assessment (ESIA) for the proposed MPL Plant in Tanzania.
During the construction phase of the Tanzania Plant and equipment installation phase at the Uganda Plant, IFC will undertake supervision of the construction/equipment installation activities as part of its routine supervision. Any necessary Corrective Action Plans or updates to the ESRS and ESAP will be undertaken at that point.
During the construction phase of the Tanzania Plant and equipment installation phase at the Uganda Plant, IFC will undertake supervision of the construction/equipment installation activities as part of its routine supervision. Any necessary Corrective Action Plans or updates to the ESRS and ESAP will be undertaken at that point.
E & S Project Categorization and Applicable Standard
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
See appraisal report
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
See appraisal report
This is a Category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability due to limited and site-specific E&S risks and impacts associated with the construction of the new plant in Tanzania. These can be avoided or mitigated by adhering to recognized Good International Industry Practices (GIIPs). Key E&S risks and issues for this investment are: (1) adequacy of E&S risks assessment and management of construction impacts in line with PSs; (2) E&S management systems and E&S capacity and governance; (3) assurance of fair, safe and healthy working conditions for construction and operation phases in line with PS2 requirements, (4) grievance mechanisms and safeguards against GBV, sexual exploitation and abuse, and child labor; (5) resource efficiency, pollution prevention and waste management per applicable World Bank Group (WBG) EHS Guidelines and Good Manufacturing Practices (GMP); (6) facility design, emergency response and community health and safety protection measures; (7) stakeholder engagement and community grievance mechanisms.
Environmental and Social Mitigation Measures
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.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
E&S Policy Management Systems, Plans and Programs. MPL’s environmental and social policy commitments are set out in the Occupational Health and Safety and Environment Policy Statement and operationalized through the Health, Safety and Environment (HSE) Management Manual. At the time of appraisal, the HSE Manual was being implemented in Uganda operations, providing the company’s plans and procedures on occupational health and safety, emergency preparedness and response, life and fire safety risk management, resource use, pollution prevention, waste management, hazardous materials management, environmental spills and contractor management. Its commitments to continuous improvement are supported by procedures for incident reporting and investigation, corrective actions, internal training, monitoring and audits. The company will apply and cascade these HSE and ESMS requirements to its Tanzania operations (including construction of the new facility) and further strengthen the system in line with the project ESAP items provided in this ESRS (ESAP #1).
Identification of Risks and Impacts. An ESIA study was prepared for the proposed project in accordance with the local environmental permitting law and an EIA License issued for the project. For routine operational OHS risk identification and management, the HSE manual also provides the MPL hazard identification and risk assessment procedure. To meet PS requirements, MPL shall update the HSE manual and develop site specific risk registers for Tanzania and Uganda Operations, to capture risk related to noise emissions, air emissions, wastewater disposal, security management, environmental spills and road safety risks that would affect the communities in the neighborhoods where it operates. MPL will also develop a legal register for tracking compliance with local E&S permits, licenses and approvals in both countries of operation (ESAP #1).
MPL will acquire equipment to enhance its automated systems in Uganda operations. Prior to the implementation of this initiative, MPL will undertake a PS aligned E&S risk assessment for the installation of equipment in the Uganda operations. MPL will then develop a PS aligned E&S Management Plan specific to the proposed works and incorporate cumulative risks and impacts to the entire operation (ESAP#1b).
Construction Contractor Management. MPL will engage contractors to undertake construction of the new plant in Tanzania and installation of associated equipment. Civil works for the plant will be implemented under an Engineering, Procurement and Construction (EPC) contract, covering all structural and civil components of the facility. MPL will separately engage original equipment manufacturers and specialised contractors to install production equipment and supporting infrastructure.
MPL will review the ESIA for the Tanzania site and the requirements of the project ESAP to develop a PS aligned construction phase environmental, health, safety and social management plan (CEHSSMP) to be implemented by the construction phase contractors. Contractors will be required to prepare and implement CEHSSMP. MPL will also appoint independent qualified E&S personnel as part of the project supervision team to oversee contractor performance and monitor implementation of the CEHSSMP and contract based E&S commitments. The qualified E&S personnel will undertake regular site monitoring, audits, and reporting throughout the construction phase. (ESAP #2).
Prior to contractor mobilization, MPL will develop and execute contracts that integrate applicable EHS clauses in these contracts, as aligned with IFC Performance Standards. These requirements will include compliance obligations derived from the project E&S risk assessments, including the approved ESIA for the Tanzania project and the E&S Risk Assessment for the installation of equipment in Uganda operations (Ref. ESAP#1b), as well as the project ESAP.
As part of ESAP#1, all the updates on contractor management practice developed under the project ESAP, including the requirements discussed in PS 2 and PS 4 sections below, will be integrated into an enhanced Contractor Management Plan aligned with PS requirements and the IFC Good Practice Note on Managing Contractors' E&S Performance. The enhanced contractor management procedures will require MPL to capture due diligence processes to assess potential contractors’ E&S policies, procedures and ESMS commensurate with the contractor operations, prior to engaging them. Any improvements necessary to meet PS requirements on contractor operations on and outside MPL premises, will be captured in legal agreements with each contractor. The enhanced contractor management procedures will also require contractors to undertake site specific OHS baseline assessments, develop project E&S risk registers including coverage of labor risks and task specific EHS risk registers.
Organizational Capacity and Competency. The MPL Chief People & Culture Officer is the designated ESG Champion and manages the MPL ESG team and agenda in the company. He is supported by the Environment Health and Safety (EHS) Officer, a sustainability and compliance officer and HR Officers. The ESG team reports to the MPL CEO and its Board.
The various line managers have designated responsibilities as guided by standard operating procedures (SoPs) applied in EHS management of their particular operational risks. The Plant Head also holds EHS management responsibilities over development of maintenance and expansion projects in the existing Kampala factory, and the development and delivery of the proposed plant in Tanzania.
The procurement Manager is charged with E&S screening of contractors, suppliers and labor outsourcing companies prior to engagement by the company. The HR team then manages labor compliance of labor outsourcing companies while the EHS manager oversees EHS compliance of contractors and suppliers in MPL premises.
For the proposed Tanzania operations, MPL will engage an EHS and a HR Officer prior to commissioning of the Tanzania Plant. This team will report to the Tanzania Plant Manager – who will have delegated E&S management roles cascaded from the corporate ESG team based in Kampala (ESAP #3). For the construction phase, the company will also retain a qualified E&S Consultants as part of the project management team to supervise the Tanzania project EPC Contractor’s implementation of the CEHSSMP (Ref ESAP #2).
EHS Training. The company delivers internal capacity building for staff through in person group trainings and regular tool box talks on priority topics identified by EHS and HR management. In addition, external, certified professionals are engaged to provide occupational health and safety training in line with local legal requirements, including first aid, fire prevention and emergency response, and mandatory qualifications for members of workplace EHS committees. As part of ESAP #1, MPL will provide a training strategy for the planned employment for the Tanzania project.
Emergency Preparedness and Response. MPL has an Emergency Preparedness and Response Plan (EPRP) applicable to its manufacturing and administrative facilities and integrated into the Enterprise Risk Management Framework and Business Continuity Management System. The EPRP identifies emergencies such as fire and explosion, hazardous chemical spills and releases, gas leaks and asphyxiation, product or biological contamination, serious medical emergencies, road accidents, extreme weather events, security incidents such as intrusion, sabotage or civil unrest, and utility failures. The EPRP also provides scenario specific response procedures, activation thresholds, command and control arrangements, evacuation and accountability measures, and coordination with external responders. A formal emergency response organisation is in place with mechanisms for continuous training, emergency drills and periodic audit of emergency response infrastructure and equipment. The EPRP also captures natural disasters and extreme weather events as potential emergency scenarios. As part of ESAP #1, MPL will enhance the current EPRP to (i) include mechanisms for early warning or monitoring to indicate when extreme weather or climate related events are likely to occur; and (ii) assess and address how events such as flooding, prolonged heat, or water shortages could affect critical facilities, including chemical storage areas and essential emergency response infrastructure and equipment.
EHS Monitoring and Review. The HSE Manual provides for monitoring of implementation and evaluation of the performance of the integrated E&S management procedures plans and programs. The company has established a HSE Committee with staff and management representation for joint monitoring and to enhance the HSE performance of all business units. The MPL ESG and Sustainability team also oversees internal and external audits on E&S performance undertaken to facilitate licensing or permitting by local authorities. As part of ESAP #1, MPL will strengthen its HSE monitoring framework by formalizing performance improvement processes and defining clearer performance indicators to demonstrate ongoing alignment with IFC PSs. The company will also cascade these monitoring and review systems, including the improvements under the project ESAP to the Tanzania operations. Reports from the Tanzania operations will be escalated to senior management and the MPL board, through the Uganda based ESG Champion.
PS 2 – Labor and Working Conditions
Workforce at the Uganda Operations. At the time of appraisal, MPL had 569 direct staff of which 23% were women. IFC’s due diligence included review of the existing HR policies and procedures, and a sample of the processes applied in the employment relationship with Movit starting from recruitment to induction, performance review and termination of workers. MPL maintains HR Management Systems and records (pay, deductions, health benefits, OHS monitoring, performance reviews, termination systems, grievance redress), in line with local (Uganda) labor law requirements. IFC due diligence was therefore limited to these available records systems, engagement with Movit Management and engagement with MPL-Uganda staff.
The company also relies on third- party workers in its Uganda operations, to provide semi-skilled and unskilled work in its core operations and for security services. At the time of appraisal, third-party workers were about 1,539 (68% women), majority of whom were engaged through a labor outsourcing company. MPL also engages contractors to undertake operational repair and maintenance services, as well as services such as waste removal from their facility in Uganda. IFC’s due diligence included a review of MPL’s contractor’s oversight systems, as concerns the labor outsourcing company and other contractors. MPL is in the process of enhancing its systems on oversight of third-party workers, hence, available record keeping systems were not comprehensive enough to capture all PS 2 due diligence requirements. As such, IFC due diligence was limited to the site appraisal visit in Uganda operations, available basic record keeping systems already in place, engagement with MPL Management and engagement with Contractor staff in Uganda. Findings of this due diligence and additional actions to meet PS 2 requirements are captured under Third Party Workers section below.
Proposed Workforce for the Construction and Operation Phases of the Plant in Tanzania. There are no existing operations in the green field site identified for the construction of the Tanzania Plant. At the time of appraisal, the EPC contractor’s construction staff for the Tanzania plant were estimated at about 235 at the peak of the construction period. Once the plant is operational, MPL will hire an additional estimate of 136 new direct staff to run plant operations and an additional estimated 500 new staff as contracted staff for unskilled and semi-skilled core operation work and security services. As construction and operations in Tanzania are yet to commence, IFC due diligence on potential PS 2 risks was limited to the PS 2 contextual assessment for labor issues and risks in Tanzania, review of the ESIA for the Tanzania site and a site appraisal visit-supported by engagement representatives from the national and local government as well as MPL management. Review of MPL’s HR policies, procedures and practices in Uganda also informed this ESRS and ESAP.
Human Resource (HR) Policy, Procedures and Working Conditions & Terms of Employment. MPL has a Human Resource Management Manual for all direct workers in line with Ugandan and international labour laws. Benefits provided include medical insurance, transport and fuel facilitation and employee welfare support. Workers are informed of their labour rights, engagement terms and company HR policies at induction. The Manual captures policies for direct workers on non-discrimination and equal opportunity, Workers Organisations, child and forced labor, grievance mechanisms, occupational health and safety as well as working terms and conditions such as employment contracts, work schedules, leave, pay, statutory deductions, medical reimbursement, PPE, salary reviews, performance bonuses, and benefits such as travel, meal, and housing allowances. The HR manual captures policies and terms for direct workers that are broadly aligned with PS2 requirements, except for the gaps identified below.
While the HR Manual provides working hours and recognizes overtime arrangements across its operations, it does not fully define its overtime policies and complaints about inconsistencies in overtime pay have been raised through worker’s GRMs. MPL will update the HR Manual and procedures to capture overtime hours and maximum overtime for day and shift workers, overtime pay systems including the premium rates for public holidays and weekends and applicable improvements on the overtime approval and record keeping procedures aligned with PS 2 requirements. Country specific requirements for both Uganda and Tanzania will be captured in HR Handbooks. (ESAP #4a).
Non-discrimination and Equal Opportunity. MPL non-discrimination policy prohibits discrimination on the basis of race, nationality, colour, gender, religion, political opinion, ethnicity, health status, or physical disability. The HR Manual provides for alignment with this commitment across all stages of employment, including recruitment, training and development, promotion, and termination. Staff who are non-compliant with the non-discrimination policies are subject to disciplinary procedures. MPL will update its non-discrimination policy to capture all protected groups under the ILO requirements and the intent of PS 2. The company will also review and update its existing policies, codes of conduct, grievance mechanisms, and supervisory practices to strengthen procedures, data protection policies and confidentiality mechanisms and provide safeguards against the adverse treatment, intimidation, or exclusion of job applicants and employees (ESAP #4b).
Workers Organization. At the time of appraisal, none of the MPL workers nor contractor staff were unionized. MPL will document a policy on freedom of association and collective bargaining consistent with applicable national labour laws and PS 2 requirements. The policies will explicitly recognize MPL workers’ rights to form or join trade unions of their choice and to engage in collective bargaining as provided for under local law (ESAP #4c).
Child and Forced Labor. The company does not have documented forced or child labor policies. In principle, MPL has set a minimum age of employment at 18 years, and all job applicants are required to present proof of age in the form of an identification card and/or requisite documentation for statutory deductions. As such, their age verification systems in Uganda are supported by national systems for statutory deductions, applicable to persons of 18 years and above. Though there was no evidence of child or forced labor among MPL direct staff in Uganda, the MPL HR Manual does not have explicit systems in place to track the indicators of child and forced labor among its direct workers.
To meet PS 2 requirements, MPL will document child and forced labor policies aligned with PS 2 requirements. The company will also update the HR Manual to capture indicators for identifying and monitoring child and forced labour risks through its human resources management systems. These will cover both direct and contracted workers and will include (i) description and monitoring of requirements for age verification of for child labor risks; (ii) controls and monitoring of retention of identity documents, recruitment fees or debt obligations, restrictions on worker movement, withholding of wages or benefits and grievances related to coercion or intimidation as indicators of forced labor (ESAP #4d).
Retrenchment. The MPL HR Manual outlines terminal benefits for its direct workers in cases of redundancy including requirements for issuance of notice or payment in lieu of notice, payment of accrued wages and leave, and severance benefits. While there is no anticipated retrenchment, MPL shall update the manual to incorporate the following in per PS 2 requirements: (i) analysis of alternatives to retrenchment of staff; (ii) worker consultation and engagement requirements prior to and during implementation of a retrenchment program; (iii) the circumstances under which MPL must prepare a retrenchment plan; (iv) mechanisms for observance of local statutory retrenchment requirements including issuance of notice, engagement with regulatory authorities, workers representation groups and unions as applicable (ESAP #4e).
Worker’s Grievance Redress Mechanism (GRM). MPL has documented a workers’ GRM procedure that allows for informal and formal hearing processes, representation of involved parties, escalation mechanisms and mechanisms for collective grievances. MPL’s uses suggestion boxes located in locations with privacy and a whistle blowing platform known as “Face-Up” system for receiving and handling anonymous complaints through a QR Code and a toll-free telephone line. The company GRM is also accessible to third-party workers. MPL will update its grievance mechanisms to provide commitments statements on protection from retaliation and reprisal and enhance its data protection systems to meet these commitments. The MPL workers’ GRM does not have documented and specific measures in place for dealing with grievances related to gender-based violence (GBV), sexual harassment (SH) and/or general harassment in the workplace. The current safeguards embedded in the GRM also need to be enhanced to provide protection from discrimination, retaliation and reprisals. To meet PS requirements, MPL will (a) undertake a risk assessment on sexual exploitation and abuse (SEA) for its operations in Uganda and new operations in Tanzania; (ii) update its sexual harassment policy to cover a comprehensive definition of SEA/SH in the workplace and in the communities within which MPL operates; (iii) prevention of SEA/SH in the workplace with applicable extensions to the company contractors and suppliers; (iv) extension of this policy and related mechanisms to cover complaints involving project affected communities and the MPL direct and contractor workforce; (v) incorporation of the currently active focal points for receipt of SEA/SH related complaints; (vi) commitments to training of staff with responsibilities in receiving and handling complaints related to SEA/SH to specifically cover survivor-centric mechanisms, referral pathways, data protection policies and non-retaliation protections (ESAP #5).
Occupational Health and Safety. The main occupational health and safety (OHS) risks at the Uganda operations and in the future project operational phase in Tanzania arise from manufacturing, maintenance, and logistics activities and include manual handling of heavy loads, repetitive physical movements, exposure to moving machinery, and high risk tasks such as hot works, work at height, and confined or restricted access activities. Additional risks relate to exposure to air emissions from production processes, storage facilities, and back up generators, as well as fire and electrocution hazards associated with electrical installations. Road safety risks are present due to the transport of raw materials and finished products. Construction phase OHS risks are discussed under Third-Party Worker below.
OHS risks related to Movit operations are managed through MPL’s HSE Management Manual, which establishes a formal OHS risk management framework based on systematic hazard identification and risk assessment. The framework is supported by permit-to-work systems, operational controls, emergency preparedness, annual OHS operating plans and incident reporting & investigation procedures. The company maintains management plans proportionate to operational risks, including oversight arrangements for contractors and outsourced workers working in MPL premises in Uganda.
MPL’s health and safety policy commits to protecting all workers and other parties within its operational premises that are affected by its operations. Monitoring arrangements include a Health and Safety Committee, trained fire marshals and first aiders, defined management oversight through health and safety KPIs, and structured communication mechanisms. OHS training is integrated into staff induction and reinforced through annual refresher training. Recorded injuries in the last 3 years are primarily cuts on hands, slips, trips and falls, eye exposures to chemicals, burns and electric shocks and road/traffic accidents. The company also monitors ambient air and noise emissions. Records indicate that emissions complied with applicable Ugandan standards and were consistent with WBG EHS guidelines. Daytime occupational noise levels were generally below 75 dBA, with localized elevations near generators managed through controls and PPE. Workers undergo pre employment and periodic medical assessments aligned with statutory and occupational risk requirements, including targeted health surveillance on general medical examinations as well as lung function tests, audiometry, urinalysis, eye examinations, alcohol and drug testing for transport staff, and targeted vaccinations for designated workers. The company provides appropriate personal protective equipment, maintains first-aid facilities and medical referral arrangements, and tracks incidents through an accident register used to monitor OHS performance indicators.
To meet PS requirements, MPL will enhance existing OHS management procedures in line with IFC PS2 and WBG General EHS Guidelines (2007), to include provisions for the development of site-specific risk registers, mechanisms for identification and monitoring of OHS-related disease incidences in affected individuals, road accident prevention and response procedures, gender considerations in risk assessment and monitoring requirements, KPIs with leading and lagging OHS indicators, internal and external training schedule for staff and an annual staff health screening schedule specific to the operational health risks. The company will also strengthen workplace arrangements to better support working mothers and female workers, by providing appropriate lactation facilities in the two plants. (ESAP #6).
Third Party Workers and Supply Chain.
Uganda Operations. MPL undertakes contractor due diligence in its active Uganda operations as part of its procurement process to ensure compliance with local labor requirements. Upon selection, MPL’s HSE Manual requires all contractors to undergo formal evaluation and approval and to operate under written contract agreements incorporating applicable Safety, Health and Environment requirements. However, IFC due diligence found that the labor outsourcing company (Job Connect) and the security contractor do not have ESMS commensurate to their risks and operations.
Contractors are responsible for supervising their personnel on MPL premises, participating in task risk assessments, and, where required, preparing and implementing an HSE Plan subject to MPL review. MPL monitors its contractors, including the labor outsourcing company, to check compliance with local labor and OHS laws monthly. This monitoring has revealed improvement areas in labor and working conditions, including payment of overtime. MPL also monitors contractor HSE performance through meetings and conducts notified audits to verify compliance and ensure corrective follow-up. While MPL has established systems to monitor its contractor’s labor and EHS requirements per local law, the MPL contractor management systems did not have explicit systems in place to adequately capture the full scope of PS 2 requirements on third-party workers.
To meet PS 2 requirements, MPL will undertake a comprehensive labor and working conditions audit of its contractors, including Job Connect and the Security Contractor and provide an improvement plan aligned with PS 2 requirements (ESAP #7a). IFC will monitor implementation of this improvement plan as part of its supervision cycle.
MPL will enhance its Procurement procedures to capture due diligence processes to assess potential contractors’ E&S policies, procedures and ESMS commensurate with the contractor operations. MPL will also provide for the contractual obligations outlined under ESAP#1 on continued contractor monitoring, audit and tracking of improvement actions.
Tanzania Operations. At the time of appraisal, there were no operational contractors at the proposed Tanzania greenfield site. As part of ESAP #1, MPL will capture all the improvements in its contractor management plan as provided in the project ESAP and cascade those requirements to the Tanzania operations.
Construction Phase Contractors. Construction sites present significant OHS risks, including falls from height, struck by incidents, excavation collapse, and contact with moving machinery. Workers undertaking civil works and equipment installation activities in Uganda and Tanzania may face exposure to dust, noise, vibration, hazardous substances, fire, and electrical hazards. Poor housekeeping, limited training, and weak supervision, particularly among subcontracted and casual labour can also exacerbate OHS risks during construction.
The contractor(s) for construction of the Tanzania plant and the installation of equipment in both Tanzania and Uganda are yet to be selected. In addition to the contractor management requirements under ESAP #1 and ESAP#2, MPL will update its standard construction and operation phase contractor agreement templates to include explicit clauses requiring contractors to (i) commit to compliance with labour and occupational health and safety standards aligned with MPL labor and OHS policies; (ii) MPL’s right to monitor and audit contractor labour and OHS practices; and (iii) Contractors to implement and close out identified corrective actions (ESAP #7b).
Supply Chain. MPL operations primarily rely on raw materials such as glycerin, stearic acid, fragrances, white oils, micro-paraffin wax and caustic soda for manufacture of personal hygiene products. As part of ESAP #4d, MPL will communicate its policy commitments on prohibition of child and forced labor to its primary suppliers. As part of ESAP 7#b, MPL will also communicate its OHS requirements to its primary suppliers per the requirements of PS 2.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency (Energy / Water). Electricity for Uganda operations is sourced from the national grid, with back-up power provided by Diesel generators & Solar Panels. Water is sourced from municipal sources. Electricity for the Tanzania plant will be sourced primarily from the national grid, with diesel generators as a standby power source. Water for the project will be sourced from the municipal sources and on site borehole. A hydrogeological assessment was undertaken as part of the ESIA for the new site to confirm groundwater availability. As part of ESAP #1, MPL will provide the borehole water abstraction permits from the relevant authorities, prior to operation of the boreholes at the Tanzania Site.
Air Emissions and Noise. The main sources of air emissions and noise for the project are associated with manufacturing processes, utility operations, on-site electricity generation and vehicle movements within the facility. Particulate matter (PM10 and PM2.5) and gaseous emissions namely volatile organic compounds, Sox and Nox are the principal air pollutants. Similar to the Uganda plant, emissions in Tanzania, including emissions from stacks and boilers and traffic related emissions will be managed through established engineering and operational controls, including dust control, emission abatement systems, and routine monitoring against applicable national requirements, World Bank Group EHS Guidelines and Good Manufacturing Practice (GMP). As part of ESAP #1, MPL will ensure that these systems are cascaded to the Tanzania operations.
Greenhouse Gases (GHG) emissions. The main driver for GHG emissions in the project are from use of fossil fuels, including use of liquid petroleum gas for the boiler in the proposed Tanzania operations. Scope 1 emissions for the project are estimated as 2,648.58 tonnes of CO2 equivalent per year (tCO2e/year) while scope 2 is estimated as 0.89 tCO2e/year.
Waste Management. The project is expected to generate solid waste from production areas, offices, sanitary facilities, and worker and visitor amenities. Identified waste streams include organic waste from cafeterias (e.g. food leftovers, vegetable peels), packaging waste (plastics, paper, cans, glass), office waste, and sanitary waste. Waste will be segregation using separate, labelled dustbins prior to treatment or disposal. Wastes will be removed through licensed service providers. Dedicated waste collection and storage areas are included within the site layout. As part of ESAP #1, MPL will develop a site-specific waste management plan for the Tanzania facility and ensure that the existing waste management systems in the HSE manual are cascaded to the Tanzania operations.
Wastewater. The project is expected to generate wastewater from production activities, offices, sanitary facilities, and worker and visitor amenities. Identified wastewater streams include greywater and blackwater from toilets, bathrooms, and kitchens, as well as wastewater from routine operational activities. MPL will construct an effluent treatment plant (ETP) to process waste water from the Tanzania facility. The ETP will be designed to meet applicable national effluent standards and align with PS 3 requirements, WBG EHS Guidelines and GMP. Before commissioning the ETP, MPL will integrate the augmented effluent monitoring program into the site-specific wastewater monitoring plan for the Tanzania facility, and ensure that wastewater management procedures contained in the HSE Manual are cascaded and implemented at the project site (ESAP #8).
Hazardous Materials. The project will require bulk storage of diesel and heavy fuel oil (HFO), and liquefied petroleum gas (LPG). Pollution prevention and control measures will be implemented for future tanks including: (i) secondary containment for above ground storage tanks; (ii) double walled tanks and piping with continuous leak detection (interstitial monitoring) for any underground storage; (iii) provision of monitoring wells where required; and (iv) documented spill prevention, leak response, and emergency management procedures. Bulk storage systems will be designed, constructed, and operated in accordance with IFC Performance Standard 3, the World Bank Group EHS Guidelines, and applicable Tanzanian regulatory requirements (ESAP #9).
Smaller volumes of caustic soda and LPG will also be stored for production activities. These materials will be managed through controlled storage, handling procedures, and worker training, consistent with PS3 requirements and the company’s HSE Management Manual. As part of ESAP #1, requirements outlined in MPL’s HSE Management Manual will be cascaded to the Tanzania facility through site-specific hazardous materials management procedures.
PS 4 – Community Health, Safety and Security
Community Health and Safety. MPL operations in Uganda are located in a predominantly industrial area, with a few residential properties. The proposed site in Tanzania is located at the outer edge of a largely undeveloped industrial park. The nearest neighbours include farms and some residential properties. Noise and air emissions, wastewater generation, hazardous materials handling, fire risk, and increased traffic may affect nearby residential, agricultural, and industrial receptors at the new site in Tanzania. As part of ESAP #1, and as indicated under PS 3 an PS 1, MPL will enhance its HSE manual to capture identification and mapping of sensitive receptors that would be affected by potential spills, fire risk and air emissions from its plant operations.
The peak construction workforce is estimated at approximately 235 workers, predominantly unskilled labour engaged in structural and civil works. The contractor will engage local workers, including local communities, for semi-skilled and unskilled labor. There will still be some immigrant workers for skill sets are not locally available, especially specialized skill sets for equipment installation. The settlement where the project will be located is predominantly rural with a low population of about 4,000 people. There are no existing commercial residential properties that immigrants in search of temporary or permanent labor can utilize. However, given the site’s proximity to Dar es Salaam (approximately 30 minutes by rail), non local workers are expected to commute daily rather than reside near the site.
During construction, nearby communities may be exposed to increased noise, dust, vibration, and traffic from heavy vehicles. The construction phase of the project will also expose the neighbouring community to road safety risks in the haulage of construction materials and equipment and potential for SEA risk in local workforce recruitment processes. As part of ESAP #2, MPL will undertake a SEA risk assessment on the neighbouring community to capture both the construction and operation phases of the project. Poor sanitation on construction sites can also result in environmental nuisance on immediate neighbours to the construction property. MPL will effect its oversight, monitoring and audit rights provided under ESAP#1, ESAP #2 and ESAP#7 on contractor management, to manage these risk and impacts in accordance with PS requirements.
Road Safety. As part of ESAP #1, MPL will extend and implement its existing traffic and vehicle management policy to capture construction phase and operational phase risks at the MPL Tanzania site. The policy and procedures will cover both company-owned and contracted vehicles. The policy will include requirements for vehicle maintenance, inspections and repairs, verification of drivers’ licenses and certifications, driver code of conduct, compulsory driver training, and a mechanism for receiving and addressing community complaints related to driver behaviour. In addition, the Company will apply the incident reporting, accident investigation, and corrective action procedures enhanced under ESAP #6 to all vehicle related incidents, including those involving company drivers and third party transport providers.
Security Personnel. MPL premises in Uganda are served by contracted unarmed security personnel. MPL premises in Tanzania will also be served by contracted unarmed security personnel-both during construction and operation phases of the project. As part of ESAP #1, MPL will (i) develop checklists to assess social risks posed by its security arrangements, (ii) conduct background checks on past human rights abuses before engaging security staff or security contractors, (iii) provide for training of security personnel on the appropriate use of force towards workers and communities, (iv) extend its community GRM to include complaints on improper conduct and SEA by project construction and operation phase security staff.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
E&S Policy Management Systems, Plans and Programs. MPL’s environmental and social policy commitments are set out in the Occupational Health and Safety and Environment Policy Statement and operationalized through the Health, Safety and Environment (HSE) Management Manual. At the time of appraisal, the HSE Manual was being implemented in Uganda operations, providing the company’s plans and procedures on occupational health and safety, emergency preparedness and response, life and fire safety risk management, resource use, pollution prevention, waste management, hazardous materials management, environmental spills and contractor management. Its commitments to continuous improvement are supported by procedures for incident reporting and investigation, corrective actions, internal training, monitoring and audits. The company will apply and cascade these HSE and ESMS requirements to its Tanzania operations (including construction of the new facility) and further strengthen the system in line with the project ESAP items provided in this ESRS (ESAP #1).
Identification of Risks and Impacts. An ESIA study was prepared for the proposed project in accordance with the local environmental permitting law and an EIA License issued for the project. For routine operational OHS risk identification and management, the HSE manual also provides the MPL hazard identification and risk assessment procedure. To meet PS requirements, MPL shall update the HSE manual and develop site specific risk registers for Tanzania and Uganda Operations, to capture risk related to noise emissions, air emissions, wastewater disposal, security management, environmental spills and road safety risks that would affect the communities in the neighborhoods where it operates. MPL will also develop a legal register for tracking compliance with local E&S permits, licenses and approvals in both countries of operation (ESAP #1).
MPL will acquire equipment to enhance its automated systems in Uganda operations. Prior to the implementation of this initiative, MPL will undertake a PS aligned E&S risk assessment for the installation of equipment in the Uganda operations. MPL will then develop a PS aligned E&S Management Plan specific to the proposed works and incorporate cumulative risks and impacts to the entire operation (ESAP#1b).
Construction Contractor Management. MPL will engage contractors to undertake construction of the new plant in Tanzania and installation of associated equipment. Civil works for the plant will be implemented under an Engineering, Procurement and Construction (EPC) contract, covering all structural and civil components of the facility. MPL will separately engage original equipment manufacturers and specialised contractors to install production equipment and supporting infrastructure.
MPL will review the ESIA for the Tanzania site and the requirements of the project ESAP to develop a PS aligned construction phase environmental, health, safety and social management plan (CEHSSMP) to be implemented by the construction phase contractors. Contractors will be required to prepare and implement CEHSSMP. MPL will also appoint independent qualified E&S personnel as part of the project supervision team to oversee contractor performance and monitor implementation of the CEHSSMP and contract based E&S commitments. The qualified E&S personnel will undertake regular site monitoring, audits, and reporting throughout the construction phase. (ESAP #2).
Prior to contractor mobilization, MPL will develop and execute contracts that integrate applicable EHS clauses in these contracts, as aligned with IFC Performance Standards. These requirements will include compliance obligations derived from the project E&S risk assessments, including the approved ESIA for the Tanzania project and the E&S Risk Assessment for the installation of equipment in Uganda operations (Ref. ESAP#1b), as well as the project ESAP.
As part of ESAP#1, all the updates on contractor management practice developed under the project ESAP, including the requirements discussed in PS 2 and PS 4 sections below, will be integrated into an enhanced Contractor Management Plan aligned with PS requirements and the IFC Good Practice Note on Managing Contractors' E&S Performance. The enhanced contractor management procedures will require MPL to capture due diligence processes to assess potential contractors’ E&S policies, procedures and ESMS commensurate with the contractor operations, prior to engaging them. Any improvements necessary to meet PS requirements on contractor operations on and outside MPL premises, will be captured in legal agreements with each contractor. The enhanced contractor management procedures will also require contractors to undertake site specific OHS baseline assessments, develop project E&S risk registers including coverage of labor risks and task specific EHS risk registers.
Organizational Capacity and Competency. The MPL Chief People & Culture Officer is the designated ESG Champion and manages the MPL ESG team and agenda in the company. He is supported by the Environment Health and Safety (EHS) Officer, a sustainability and compliance officer and HR Officers. The ESG team reports to the MPL CEO and its Board.
The various line managers have designated responsibilities as guided by standard operating procedures (SoPs) applied in EHS management of their particular operational risks. The Plant Head also holds EHS management responsibilities over development of maintenance and expansion projects in the existing Kampala factory, and the development and delivery of the proposed plant in Tanzania.
The procurement Manager is charged with E&S screening of contractors, suppliers and labor outsourcing companies prior to engagement by the company. The HR team then manages labor compliance of labor outsourcing companies while the EHS manager oversees EHS compliance of contractors and suppliers in MPL premises.
For the proposed Tanzania operations, MPL will engage an EHS and a HR Officer prior to commissioning of the Tanzania Plant. This team will report to the Tanzania Plant Manager – who will have delegated E&S management roles cascaded from the corporate ESG team based in Kampala (ESAP #3). For the construction phase, the company will also retain a qualified E&S Consultants as part of the project management team to supervise the Tanzania project EPC Contractor’s implementation of the CEHSSMP (Ref ESAP #2).
EHS Training. The company delivers internal capacity building for staff through in person group trainings and regular tool box talks on priority topics identified by EHS and HR management. In addition, external, certified professionals are engaged to provide occupational health and safety training in line with local legal requirements, including first aid, fire prevention and emergency response, and mandatory qualifications for members of workplace EHS committees. As part of ESAP #1, MPL will provide a training strategy for the planned employment for the Tanzania project.
Emergency Preparedness and Response. MPL has an Emergency Preparedness and Response Plan (EPRP) applicable to its manufacturing and administrative facilities and integrated into the Enterprise Risk Management Framework and Business Continuity Management System. The EPRP identifies emergencies such as fire and explosion, hazardous chemical spills and releases, gas leaks and asphyxiation, product or biological contamination, serious medical emergencies, road accidents, extreme weather events, security incidents such as intrusion, sabotage or civil unrest, and utility failures. The EPRP also provides scenario specific response procedures, activation thresholds, command and control arrangements, evacuation and accountability measures, and coordination with external responders. A formal emergency response organisation is in place with mechanisms for continuous training, emergency drills and periodic audit of emergency response infrastructure and equipment. The EPRP also captures natural disasters and extreme weather events as potential emergency scenarios. As part of ESAP #1, MPL will enhance the current EPRP to (i) include mechanisms for early warning or monitoring to indicate when extreme weather or climate related events are likely to occur; and (ii) assess and address how events such as flooding, prolonged heat, or water shortages could affect critical facilities, including chemical storage areas and essential emergency response infrastructure and equipment.
EHS Monitoring and Review. The HSE Manual provides for monitoring of implementation and evaluation of the performance of the integrated E&S management procedures plans and programs. The company has established a HSE Committee with staff and management representation for joint monitoring and to enhance the HSE performance of all business units. The MPL ESG and Sustainability team also oversees internal and external audits on E&S performance undertaken to facilitate licensing or permitting by local authorities. As part of ESAP #1, MPL will strengthen its HSE monitoring framework by formalizing performance improvement processes and defining clearer performance indicators to demonstrate ongoing alignment with IFC PSs. The company will also cascade these monitoring and review systems, including the improvements under the project ESAP to the Tanzania operations. Reports from the Tanzania operations will be escalated to senior management and the MPL board, through the Uganda based ESG Champion.
PS 2 – Labor and Working Conditions
Workforce at the Uganda Operations. At the time of appraisal, MPL had 569 direct staff of which 23% were women. IFC’s due diligence included review of the existing HR policies and procedures, and a sample of the processes applied in the employment relationship with Movit starting from recruitment to induction, performance review and termination of workers. MPL maintains HR Management Systems and records (pay, deductions, health benefits, OHS monitoring, performance reviews, termination systems, grievance redress), in line with local (Uganda) labor law requirements. IFC due diligence was therefore limited to these available records systems, engagement with Movit Management and engagement with MPL-Uganda staff.
The company also relies on third- party workers in its Uganda operations, to provide semi-skilled and unskilled work in its core operations and for security services. At the time of appraisal, third-party workers were about 1,539 (68% women), majority of whom were engaged through a labor outsourcing company. MPL also engages contractors to undertake operational repair and maintenance services, as well as services such as waste removal from their facility in Uganda. IFC’s due diligence included a review of MPL’s contractor’s oversight systems, as concerns the labor outsourcing company and other contractors. MPL is in the process of enhancing its systems on oversight of third-party workers, hence, available record keeping systems were not comprehensive enough to capture all PS 2 due diligence requirements. As such, IFC due diligence was limited to the site appraisal visit in Uganda operations, available basic record keeping systems already in place, engagement with MPL Management and engagement with Contractor staff in Uganda. Findings of this due diligence and additional actions to meet PS 2 requirements are captured under Third Party Workers section below.
Proposed Workforce for the Construction and Operation Phases of the Plant in Tanzania. There are no existing operations in the green field site identified for the construction of the Tanzania Plant. At the time of appraisal, the EPC contractor’s construction staff for the Tanzania plant were estimated at about 235 at the peak of the construction period. Once the plant is operational, MPL will hire an additional estimate of 136 new direct staff to run plant operations and an additional estimated 500 new staff as contracted staff for unskilled and semi-skilled core operation work and security services. As construction and operations in Tanzania are yet to commence, IFC due diligence on potential PS 2 risks was limited to the PS 2 contextual assessment for labor issues and risks in Tanzania, review of the ESIA for the Tanzania site and a site appraisal visit-supported by engagement representatives from the national and local government as well as MPL management. Review of MPL’s HR policies, procedures and practices in Uganda also informed this ESRS and ESAP.
Human Resource (HR) Policy, Procedures and Working Conditions & Terms of Employment. MPL has a Human Resource Management Manual for all direct workers in line with Ugandan and international labour laws. Benefits provided include medical insurance, transport and fuel facilitation and employee welfare support. Workers are informed of their labour rights, engagement terms and company HR policies at induction. The Manual captures policies for direct workers on non-discrimination and equal opportunity, Workers Organisations, child and forced labor, grievance mechanisms, occupational health and safety as well as working terms and conditions such as employment contracts, work schedules, leave, pay, statutory deductions, medical reimbursement, PPE, salary reviews, performance bonuses, and benefits such as travel, meal, and housing allowances. The HR manual captures policies and terms for direct workers that are broadly aligned with PS2 requirements, except for the gaps identified below.
While the HR Manual provides working hours and recognizes overtime arrangements across its operations, it does not fully define its overtime policies and complaints about inconsistencies in overtime pay have been raised through worker’s GRMs. MPL will update the HR Manual and procedures to capture overtime hours and maximum overtime for day and shift workers, overtime pay systems including the premium rates for public holidays and weekends and applicable improvements on the overtime approval and record keeping procedures aligned with PS 2 requirements. Country specific requirements for both Uganda and Tanzania will be captured in HR Handbooks. (ESAP #4a).
Non-discrimination and Equal Opportunity. MPL non-discrimination policy prohibits discrimination on the basis of race, nationality, colour, gender, religion, political opinion, ethnicity, health status, or physical disability. The HR Manual provides for alignment with this commitment across all stages of employment, including recruitment, training and development, promotion, and termination. Staff who are non-compliant with the non-discrimination policies are subject to disciplinary procedures. MPL will update its non-discrimination policy to capture all protected groups under the ILO requirements and the intent of PS 2. The company will also review and update its existing policies, codes of conduct, grievance mechanisms, and supervisory practices to strengthen procedures, data protection policies and confidentiality mechanisms and provide safeguards against the adverse treatment, intimidation, or exclusion of job applicants and employees (ESAP #4b).
Workers Organization. At the time of appraisal, none of the MPL workers nor contractor staff were unionized. MPL will document a policy on freedom of association and collective bargaining consistent with applicable national labour laws and PS 2 requirements. The policies will explicitly recognize MPL workers’ rights to form or join trade unions of their choice and to engage in collective bargaining as provided for under local law (ESAP #4c).
Child and Forced Labor. The company does not have documented forced or child labor policies. In principle, MPL has set a minimum age of employment at 18 years, and all job applicants are required to present proof of age in the form of an identification card and/or requisite documentation for statutory deductions. As such, their age verification systems in Uganda are supported by national systems for statutory deductions, applicable to persons of 18 years and above. Though there was no evidence of child or forced labor among MPL direct staff in Uganda, the MPL HR Manual does not have explicit systems in place to track the indicators of child and forced labor among its direct workers.
To meet PS 2 requirements, MPL will document child and forced labor policies aligned with PS 2 requirements. The company will also update the HR Manual to capture indicators for identifying and monitoring child and forced labour risks through its human resources management systems. These will cover both direct and contracted workers and will include (i) description and monitoring of requirements for age verification of for child labor risks; (ii) controls and monitoring of retention of identity documents, recruitment fees or debt obligations, restrictions on worker movement, withholding of wages or benefits and grievances related to coercion or intimidation as indicators of forced labor (ESAP #4d).
Retrenchment. The MPL HR Manual outlines terminal benefits for its direct workers in cases of redundancy including requirements for issuance of notice or payment in lieu of notice, payment of accrued wages and leave, and severance benefits. While there is no anticipated retrenchment, MPL shall update the manual to incorporate the following in per PS 2 requirements: (i) analysis of alternatives to retrenchment of staff; (ii) worker consultation and engagement requirements prior to and during implementation of a retrenchment program; (iii) the circumstances under which MPL must prepare a retrenchment plan; (iv) mechanisms for observance of local statutory retrenchment requirements including issuance of notice, engagement with regulatory authorities, workers representation groups and unions as applicable (ESAP #4e).
Worker’s Grievance Redress Mechanism (GRM). MPL has documented a workers’ GRM procedure that allows for informal and formal hearing processes, representation of involved parties, escalation mechanisms and mechanisms for collective grievances. MPL’s uses suggestion boxes located in locations with privacy and a whistle blowing platform known as “Face-Up” system for receiving and handling anonymous complaints through a QR Code and a toll-free telephone line. The company GRM is also accessible to third-party workers. MPL will update its grievance mechanisms to provide commitments statements on protection from retaliation and reprisal and enhance its data protection systems to meet these commitments. The MPL workers’ GRM does not have documented and specific measures in place for dealing with grievances related to gender-based violence (GBV), sexual harassment (SH) and/or general harassment in the workplace. The current safeguards embedded in the GRM also need to be enhanced to provide protection from discrimination, retaliation and reprisals. To meet PS requirements, MPL will (a) undertake a risk assessment on sexual exploitation and abuse (SEA) for its operations in Uganda and new operations in Tanzania; (ii) update its sexual harassment policy to cover a comprehensive definition of SEA/SH in the workplace and in the communities within which MPL operates; (iii) prevention of SEA/SH in the workplace with applicable extensions to the company contractors and suppliers; (iv) extension of this policy and related mechanisms to cover complaints involving project affected communities and the MPL direct and contractor workforce; (v) incorporation of the currently active focal points for receipt of SEA/SH related complaints; (vi) commitments to training of staff with responsibilities in receiving and handling complaints related to SEA/SH to specifically cover survivor-centric mechanisms, referral pathways, data protection policies and non-retaliation protections (ESAP #5).
Occupational Health and Safety. The main occupational health and safety (OHS) risks at the Uganda operations and in the future project operational phase in Tanzania arise from manufacturing, maintenance, and logistics activities and include manual handling of heavy loads, repetitive physical movements, exposure to moving machinery, and high risk tasks such as hot works, work at height, and confined or restricted access activities. Additional risks relate to exposure to air emissions from production processes, storage facilities, and back up generators, as well as fire and electrocution hazards associated with electrical installations. Road safety risks are present due to the transport of raw materials and finished products. Construction phase OHS risks are discussed under Third-Party Worker below.
OHS risks related to Movit operations are managed through MPL’s HSE Management Manual, which establishes a formal OHS risk management framework based on systematic hazard identification and risk assessment. The framework is supported by permit-to-work systems, operational controls, emergency preparedness, annual OHS operating plans and incident reporting & investigation procedures. The company maintains management plans proportionate to operational risks, including oversight arrangements for contractors and outsourced workers working in MPL premises in Uganda.
MPL’s health and safety policy commits to protecting all workers and other parties within its operational premises that are affected by its operations. Monitoring arrangements include a Health and Safety Committee, trained fire marshals and first aiders, defined management oversight through health and safety KPIs, and structured communication mechanisms. OHS training is integrated into staff induction and reinforced through annual refresher training. Recorded injuries in the last 3 years are primarily cuts on hands, slips, trips and falls, eye exposures to chemicals, burns and electric shocks and road/traffic accidents. The company also monitors ambient air and noise emissions. Records indicate that emissions complied with applicable Ugandan standards and were consistent with WBG EHS guidelines. Daytime occupational noise levels were generally below 75 dBA, with localized elevations near generators managed through controls and PPE. Workers undergo pre employment and periodic medical assessments aligned with statutory and occupational risk requirements, including targeted health surveillance on general medical examinations as well as lung function tests, audiometry, urinalysis, eye examinations, alcohol and drug testing for transport staff, and targeted vaccinations for designated workers. The company provides appropriate personal protective equipment, maintains first-aid facilities and medical referral arrangements, and tracks incidents through an accident register used to monitor OHS performance indicators.
To meet PS requirements, MPL will enhance existing OHS management procedures in line with IFC PS2 and WBG General EHS Guidelines (2007), to include provisions for the development of site-specific risk registers, mechanisms for identification and monitoring of OHS-related disease incidences in affected individuals, road accident prevention and response procedures, gender considerations in risk assessment and monitoring requirements, KPIs with leading and lagging OHS indicators, internal and external training schedule for staff and an annual staff health screening schedule specific to the operational health risks. The company will also strengthen workplace arrangements to better support working mothers and female workers, by providing appropriate lactation facilities in the two plants. (ESAP #6).
Third Party Workers and Supply Chain.
Uganda Operations. MPL undertakes contractor due diligence in its active Uganda operations as part of its procurement process to ensure compliance with local labor requirements. Upon selection, MPL’s HSE Manual requires all contractors to undergo formal evaluation and approval and to operate under written contract agreements incorporating applicable Safety, Health and Environment requirements. However, IFC due diligence found that the labor outsourcing company (Job Connect) and the security contractor do not have ESMS commensurate to their risks and operations.
Contractors are responsible for supervising their personnel on MPL premises, participating in task risk assessments, and, where required, preparing and implementing an HSE Plan subject to MPL review. MPL monitors its contractors, including the labor outsourcing company, to check compliance with local labor and OHS laws monthly. This monitoring has revealed improvement areas in labor and working conditions, including payment of overtime. MPL also monitors contractor HSE performance through meetings and conducts notified audits to verify compliance and ensure corrective follow-up. While MPL has established systems to monitor its contractor’s labor and EHS requirements per local law, the MPL contractor management systems did not have explicit systems in place to adequately capture the full scope of PS 2 requirements on third-party workers.
To meet PS 2 requirements, MPL will undertake a comprehensive labor and working conditions audit of its contractors, including Job Connect and the Security Contractor and provide an improvement plan aligned with PS 2 requirements (ESAP #7a). IFC will monitor implementation of this improvement plan as part of its supervision cycle.
MPL will enhance its Procurement procedures to capture due diligence processes to assess potential contractors’ E&S policies, procedures and ESMS commensurate with the contractor operations. MPL will also provide for the contractual obligations outlined under ESAP#1 on continued contractor monitoring, audit and tracking of improvement actions.
Tanzania Operations. At the time of appraisal, there were no operational contractors at the proposed Tanzania greenfield site. As part of ESAP #1, MPL will capture all the improvements in its contractor management plan as provided in the project ESAP and cascade those requirements to the Tanzania operations.
Construction Phase Contractors. Construction sites present significant OHS risks, including falls from height, struck by incidents, excavation collapse, and contact with moving machinery. Workers undertaking civil works and equipment installation activities in Uganda and Tanzania may face exposure to dust, noise, vibration, hazardous substances, fire, and electrical hazards. Poor housekeeping, limited training, and weak supervision, particularly among subcontracted and casual labour can also exacerbate OHS risks during construction.
The contractor(s) for construction of the Tanzania plant and the installation of equipment in both Tanzania and Uganda are yet to be selected. In addition to the contractor management requirements under ESAP #1 and ESAP#2, MPL will update its standard construction and operation phase contractor agreement templates to include explicit clauses requiring contractors to (i) commit to compliance with labour and occupational health and safety standards aligned with MPL labor and OHS policies; (ii) MPL’s right to monitor and audit contractor labour and OHS practices; and (iii) Contractors to implement and close out identified corrective actions (ESAP #7b).
Supply Chain. MPL operations primarily rely on raw materials such as glycerin, stearic acid, fragrances, white oils, micro-paraffin wax and caustic soda for manufacture of personal hygiene products. As part of ESAP #4d, MPL will communicate its policy commitments on prohibition of child and forced labor to its primary suppliers. As part of ESAP 7#b, MPL will also communicate its OHS requirements to its primary suppliers per the requirements of PS 2.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency (Energy / Water). Electricity for Uganda operations is sourced from the national grid, with back-up power provided by Diesel generators & Solar Panels. Water is sourced from municipal sources. Electricity for the Tanzania plant will be sourced primarily from the national grid, with diesel generators as a standby power source. Water for the project will be sourced from the municipal sources and on site borehole. A hydrogeological assessment was undertaken as part of the ESIA for the new site to confirm groundwater availability. As part of ESAP #1, MPL will provide the borehole water abstraction permits from the relevant authorities, prior to operation of the boreholes at the Tanzania Site.
Air Emissions and Noise. The main sources of air emissions and noise for the project are associated with manufacturing processes, utility operations, on-site electricity generation and vehicle movements within the facility. Particulate matter (PM10 and PM2.5) and gaseous emissions namely volatile organic compounds, Sox and Nox are the principal air pollutants. Similar to the Uganda plant, emissions in Tanzania, including emissions from stacks and boilers and traffic related emissions will be managed through established engineering and operational controls, including dust control, emission abatement systems, and routine monitoring against applicable national requirements, World Bank Group EHS Guidelines and Good Manufacturing Practice (GMP). As part of ESAP #1, MPL will ensure that these systems are cascaded to the Tanzania operations.
Greenhouse Gases (GHG) emissions. The main driver for GHG emissions in the project are from use of fossil fuels, including use of liquid petroleum gas for the boiler in the proposed Tanzania operations. Scope 1 emissions for the project are estimated as 2,648.58 tonnes of CO2 equivalent per year (tCO2e/year) while scope 2 is estimated as 0.89 tCO2e/year.
Waste Management. The project is expected to generate solid waste from production areas, offices, sanitary facilities, and worker and visitor amenities. Identified waste streams include organic waste from cafeterias (e.g. food leftovers, vegetable peels), packaging waste (plastics, paper, cans, glass), office waste, and sanitary waste. Waste will be segregation using separate, labelled dustbins prior to treatment or disposal. Wastes will be removed through licensed service providers. Dedicated waste collection and storage areas are included within the site layout. As part of ESAP #1, MPL will develop a site-specific waste management plan for the Tanzania facility and ensure that the existing waste management systems in the HSE manual are cascaded to the Tanzania operations.
Wastewater. The project is expected to generate wastewater from production activities, offices, sanitary facilities, and worker and visitor amenities. Identified wastewater streams include greywater and blackwater from toilets, bathrooms, and kitchens, as well as wastewater from routine operational activities. MPL will construct an effluent treatment plant (ETP) to process waste water from the Tanzania facility. The ETP will be designed to meet applicable national effluent standards and align with PS 3 requirements, WBG EHS Guidelines and GMP. Before commissioning the ETP, MPL will integrate the augmented effluent monitoring program into the site-specific wastewater monitoring plan for the Tanzania facility, and ensure that wastewater management procedures contained in the HSE Manual are cascaded and implemented at the project site (ESAP #8).
Hazardous Materials. The project will require bulk storage of diesel and heavy fuel oil (HFO), and liquefied petroleum gas (LPG). Pollution prevention and control measures will be implemented for future tanks including: (i) secondary containment for above ground storage tanks; (ii) double walled tanks and piping with continuous leak detection (interstitial monitoring) for any underground storage; (iii) provision of monitoring wells where required; and (iv) documented spill prevention, leak response, and emergency management procedures. Bulk storage systems will be designed, constructed, and operated in accordance with IFC Performance Standard 3, the World Bank Group EHS Guidelines, and applicable Tanzanian regulatory requirements (ESAP #9).
Smaller volumes of caustic soda and LPG will also be stored for production activities. These materials will be managed through controlled storage, handling procedures, and worker training, consistent with PS3 requirements and the company’s HSE Management Manual. As part of ESAP #1, requirements outlined in MPL’s HSE Management Manual will be cascaded to the Tanzania facility through site-specific hazardous materials management procedures.
PS 4 – Community Health, Safety and Security
Community Health and Safety. MPL operations in Uganda are located in a predominantly industrial area, with a few residential properties. The proposed site in Tanzania is located at the outer edge of a largely undeveloped industrial park. The nearest neighbours include farms and some residential properties. Noise and air emissions, wastewater generation, hazardous materials handling, fire risk, and increased traffic may affect nearby residential, agricultural, and industrial receptors at the new site in Tanzania. As part of ESAP #1, and as indicated under PS 3 an PS 1, MPL will enhance its HSE manual to capture identification and mapping of sensitive receptors that would be affected by potential spills, fire risk and air emissions from its plant operations.
The peak construction workforce is estimated at approximately 235 workers, predominantly unskilled labour engaged in structural and civil works. The contractor will engage local workers, including local communities, for semi-skilled and unskilled labor. There will still be some immigrant workers for skill sets are not locally available, especially specialized skill sets for equipment installation. The settlement where the project will be located is predominantly rural with a low population of about 4,000 people. There are no existing commercial residential properties that immigrants in search of temporary or permanent labor can utilize. However, given the site’s proximity to Dar es Salaam (approximately 30 minutes by rail), non local workers are expected to commute daily rather than reside near the site.
During construction, nearby communities may be exposed to increased noise, dust, vibration, and traffic from heavy vehicles. The construction phase of the project will also expose the neighbouring community to road safety risks in the haulage of construction materials and equipment and potential for SEA risk in local workforce recruitment processes. As part of ESAP #2, MPL will undertake a SEA risk assessment on the neighbouring community to capture both the construction and operation phases of the project. Poor sanitation on construction sites can also result in environmental nuisance on immediate neighbours to the construction property. MPL will effect its oversight, monitoring and audit rights provided under ESAP#1, ESAP #2 and ESAP#7 on contractor management, to manage these risk and impacts in accordance with PS requirements.
Road Safety. As part of ESAP #1, MPL will extend and implement its existing traffic and vehicle management policy to capture construction phase and operational phase risks at the MPL Tanzania site. The policy and procedures will cover both company-owned and contracted vehicles. The policy will include requirements for vehicle maintenance, inspections and repairs, verification of drivers’ licenses and certifications, driver code of conduct, compulsory driver training, and a mechanism for receiving and addressing community complaints related to driver behaviour. In addition, the Company will apply the incident reporting, accident investigation, and corrective action procedures enhanced under ESAP #6 to all vehicle related incidents, including those involving company drivers and third party transport providers.
Security Personnel. MPL premises in Uganda are served by contracted unarmed security personnel. MPL premises in Tanzania will also be served by contracted unarmed security personnel-both during construction and operation phases of the project. As part of ESAP #1, MPL will (i) develop checklists to assess social risks posed by its security arrangements, (ii) conduct background checks on past human rights abuses before engaging security staff or security contractors, (iii) provide for training of security personnel on the appropriate use of force towards workers and communities, (iv) extend its community GRM to include complaints on improper conduct and SEA by project construction and operation phase security staff.
Stakeholder Engagement
As indicated under PS 4, MPL operations in Uganda are located in a predominantly industrial area, with a few residential properties. The proposed site in Tanzania is located at the outer edge of a largely undeveloped industrial park. The nearest non-industrial neighbours include farms and some residential properties. MPL stakeholder engagement practices are not fully developed and are focused on local environmental permitting requirements. The company does not have any documented stakeholder engagement procedures and its external communication procedures are limited to customer feedback on products in Uganda.
Past community engagement at the proposed new plant in Tanzania has been restricted to institutional stakeholders, including village administration representatives. IFC due diligence on community views was limited to reputational risk review of publicly available information on MPL, institutional/community representatives feedback provided in the project ESIA and in IFC’s site appraisal visit engagement with MPL Uganda workers, Tanzania national and local government officials.
MPL will develop and document a PS 1 aligned, site-specific stakeholder engagement plans (SEPs) for Tanzania and Uganda operations. The SEPs will include stakeholder identification, prioritization and mapping and will incorporate strategies and programs for engagement and reporting to all stakeholders (including communities and institutional/regulatory stakeholders), critical to management of all the E&S risks identified under this ESRS. The community grievance mechanism developed under the SEPs will be equipped to handle complaints and feedback from known and anonymous members of the surrounding community. As provided under PS 2, the community GRM will also allow for specific measures for identification and management of complaints related to SEA for community members who interact with project staff and where necessary, extended to respond to such complaints related to its principal contractors (ESAP #10).
The CEHSSMP developed under ESAP #2 will have a clear SEP and community GRM for implementation by the contractor. The Contract agreements will provide clauses on MPL’s expectations on community engagement, community grievance redress and escalation of issues from the contractor to MPL. The Contractor SEP and GRM will not exempt MPL from directly engaging the community in accordance with PS requirements.
Past community engagement at the proposed new plant in Tanzania has been restricted to institutional stakeholders, including village administration representatives. IFC due diligence on community views was limited to reputational risk review of publicly available information on MPL, institutional/community representatives feedback provided in the project ESIA and in IFC’s site appraisal visit engagement with MPL Uganda workers, Tanzania national and local government officials.
MPL will develop and document a PS 1 aligned, site-specific stakeholder engagement plans (SEPs) for Tanzania and Uganda operations. The SEPs will include stakeholder identification, prioritization and mapping and will incorporate strategies and programs for engagement and reporting to all stakeholders (including communities and institutional/regulatory stakeholders), critical to management of all the E&S risks identified under this ESRS. The community grievance mechanism developed under the SEPs will be equipped to handle complaints and feedback from known and anonymous members of the surrounding community. As provided under PS 2, the community GRM will also allow for specific measures for identification and management of complaints related to SEA for community members who interact with project staff and where necessary, extended to respond to such complaints related to its principal contractors (ESAP #10).
The CEHSSMP developed under ESAP #2 will have a clear SEP and community GRM for implementation by the contractor. The Contract agreements will provide clauses on MPL’s expectations on community engagement, community grievance redress and escalation of issues from the contractor to MPL. The Contractor SEP and GRM will not exempt MPL from directly engaging the community in accordance with PS requirements.
Company Name: Movit Products Limited
Point of Contact: Simon Birungi
Address: Movit Road-Off Entebbe Road
Email: info@movitproducts.com
Phone: +256 709 640 250
Point of Contact: Simon Birungi
Address: Movit Road-Off Entebbe Road
Email: info@movitproducts.com
Phone: +256 709 640 250
Broad Community Support
Broad Community Support is not applicable for this project.
Environmental & Social Action Plan
| S.no | Description | Anticipated Completion Date |
|---|---|---|
| 1 | MPL will enhance its E&S policies, HSE Manual and related procedures to capture (i) enhanced site specific risk registers to capture risk related to noise emissions, air emissions, wastewater disposal, security management, environmental spills and road safety risks that would affect the communities in the neighborhoods where it operates; (ii) a legal register for tracking compliance with local E&S permits, licenses and approvals in the two countries of operation; (iii) provide EHS training strategy for the planned employment for the Tanzania project; (iv) enhance the EPRP per ESRS requirements (v) strengthen its HSE monitoring framework by formalizing performance improvement processes and defining clearer performance indicators to demonstrate ongoing alignment with PSs. The company will also cascade these systems, to the Tanzania operations; (vi) develop a site-specific waste management plan for the Tanzania facility (viii) traffic and vehicle management policy per the ESRS; enhance its Procurement procedures to capture due diligence processes to assess potential contractors’ E&S policies, procedures and ESMS commensurate with the contractor operations. MPL will also provide for contractual obligations on continued contractor monitoring, audit and tracking of improvement actions (x) enhance security personnel management by (a) development of checklists to assess social risks posed by its security arrangements, (b) conduct of background checks on past human rights abuses before engaging security staff or security contractors, (c) provision of training of security personnel on the appropriate use of force towards workers and communities, d) extension of community Grievance Redress Mechanism (GRM) to include complaints on improper conduct and Sexual Exploitation and Abuse (SEA) by project security staff. MPL will provide the borehole water abstraction permits from the relevant authorities, prior to operation of the boreholes at the Tanzania Site. | 09/30/2027 |
| 2 | For the Proposed Equipment Installation in Uganda: MPL will undertake a PS aligned E&S risk assessment for the installation of equipment in the Uganda operations. MPL will then develop a PS aligned E&S Management Plan specific to the proposed works incorporate cumulative risks and impacts to the entire operation. | 08/31/2026 |
| 3 | For the Proposed Tanzania PlantMPL will develop a PS aligned construction phase environmental, health, safety and social management plan (CEHSSMP) to be implemented by the Engineering Procurement and Construction (EPC) contractor. The CEHSSMP will have a clear SEP and community GRM for implementation by the contractor. The Contract agreements will provide clauses on MPL’s expectations on community engagement, community grievance redress and escalation of issues from the contractor to MPL. The Contractor Stakeholder Engagement Plan (SEP) and GRM will not exempt MPL from directly engaging the community in accordance with PS requirements. MPL will undertake a Sexual Exploitation and Abuse (SEA) risk assessment on the neighbouring community to capture both the construction and operation phases of the project.MPL will appoint independent qualified E&S personnel as part of the project supervision team to oversee contractor performance and monitor implementation of the CEHSSMP and contract based E&S commitments. The qualified E&S personnel will undertake regular site monitoring, audits, and reporting throughout the construction phase. For Both Uganda Equipment Installation and the Proposed Tanzania PlantMPL will incorporate contractual clauses in contracts, stipulating the environmental, labor and Occupational Health and Safety (OHS) measures and controls that will be enforced during construction activities. | 08/31/2026 |
| 4 | For the Proposed Tanzania PlantMPL will engage an EHS and Human Resources (HR) Officer prior to commissioning of the Tanzania Plant. These personnel will report to the Tanzania Plant Manager – who will have delegated E&S management roles cascaded from the corporate Environment Social and Governance (ESG) team based in Kampala | 08/31/2027 |
| 5 | MPL will engage an EHS and Human Resources (HR) Officer prior to commissioning of the Tanzania Plant. These personnel will report to the Tanzania Plant Manager – who will have delegated E&S management roles cascaded from the corporate Environment Social and Governance (ESG) team based in Kampala | 11/30/2027 |
| 6 | For Both Uganda and Tanzania Operations. MPL will update the HR Manual and procedures to capture overtime hours and maximum overtime for day and shift workers, overtime pay systems including the premium rates for public holidays and weekends and applicable improvements on the overtime approval and record keeping procedures aligned with PS 2 requirements.MPL will also update its non-discrimination framework to align its non-discrimination policy statement with ILO requirements and the intent of PS 2. MPL will review and update its existing policies, codes of conduct, grievance mechanisms, and supervisory practices to strengthen procedures, data protection policies and confidentiality mechanisms and provide safeguards against the adverse treatment, intimidation, or exclusion of job applicants and employees. MPL will document a policy on freedom of association and collective bargaining consistent with applicable national labour laws and PS 2 requirements. The policies will explicitly recognize workers’ rights to form or join trade unions of their choice and to engage in collective bargaining where provided for under local law. MPL will document child and forced labor policies aligned with PS 2 requirements. The company will also update the HR Manual to capture indicators for identifying and monitoring child and forced labour risks through its human resources management systems. These will cover both direct and contracted workers and will include (i) maintenance of requirements for age verification of for child labor risks; (ii) controls and monitoring of retention of identity documents, recruitment fees or debt obligations, restrictions on worker movement, withholding of wages or benefits and grievances related to coercion or intimidation connected to forced labor. MPL will communicate its policy commitments on prohibition of child and forced labor to its primary suppliers and contractors. MPL will update the manual to incorporate retrenchment per the ESRS | 06/30/2027 |
| 7 | For Both Uganda and Tanzania OperationsMPL will (a) undertake a risk assessment on sexual exploitation and abuse (SEA) for the existing operations in Uganda and the new operations in Tanzania; (ii) update its sexual harassment policy to cover a comprehensive definition of SEA in the workplace and in the communities within which MPL operates; (iii) prevention of SEA and Sexual Harassment (SH) in the workplace with applicable extensions to the company contractors and suppliers; (iv) extension of this policy and related mechanisms to cover complaints involving project affected communities and the MPL direct and contractor workforce; (v) incorporation of the currently active focal points for receipt of SEA/SH related complaints; (vi) commitments to training of staff with responsibilities in receiving and handling complaints related to SEA/SH to specifically cover survivor-centric mechanisms, referral pathways, data protection policies and non-retaliation protections. | 06/30/2027 |
| 8 | For Both Uganda and Tanzania OperationsMPL will enhance existing OHS management procedures in line with IFC PS2 and World Bank Group (WBG) General EHS Guidelines (2007), to include provisions for the development of site-specific risk registers, mechanisms for identification and monitoring of OHS-related disease incidences in affected individuals, road accident prevention and response procedures, gender considerations in risk assessment and monitoring requirements, KPIs with leading and lagging OHS indicators, internal and external training schedule for staff and an annual staff health screening schedule specific to the operational health risks. The company will also strengthen workplace arrangements to better support working mothers and female workers, by providing appropriate lactation facilities in the plants.Apply the incident reporting, accident investigation, and corrective action procedures to all vehicle related incidents, including those involving company drivers and third party transport providers. | 09/30/2027 |
| 9 | For Uganda Operations - MPL will undertake a labor and working conditions audit of its contractors, including Job Connect and the security contractor and provide an improvement plan aligned with PS 2 requirements.For Uganda Operations - MPL will also communicate its OHS, child labor and forced labor policy requirements to its primary suppliers per the requirements of PS 2. | 03/31/2027 |
| 10 | For Both Uganda and Tanzania OperationsMPL will enhance its Procurement procedures to capture due diligence processes to assess potential contractors’ E&S policies, procedures and ESMS commensurate with the contractor operations. MPL will also provide for the contractual obligations outlined under ESAP#1 on continued contractor monitoring, audit and tracking of improvement actions.MPL will update its standard construction and operation phase contractor agreement templates to include explicit clauses requiring contractors to (i) commit to compliance with labour and occupational health and safety standards aligned with MPL labor and OHS policies; (ii) MPL’s right to monitor and audit contractor labour and OHS practices; and (iii) Contractors to implement and close out identified corrective actions. | 12/31/2026 |
| 11 | For Proposed New Plant in TanzaniaMPL will commission an effluent treatment plant (ETP) to process wastewater from the Tanzania facility. The ETP will be designed to meet applicable national effluent standards and align with PS 3 requirements, World Bank Group EHS Guidelines and Good Manufacturing Practice (GMP). Before commissioning the ETP, MPL will integrate the augmented effluent monitoring program into the site-specific wastewater monitoring plan for the Tanzania facility, and cascade the requisite wastewater management procedures from the HSE Manual to the project site. | 12/31/2027 |
| 12 | For Proposed New Plant in TanzaniaMPL will implement pollution prevention and control measures for future tanks including: (i) secondary containment for above ground storage tanks; (ii) double walled tanks and piping with continuous leak detection (interstitial monitoring) for any underground storage; (iii) provision of monitoring wells where required; and (iv) documented spill prevention, leak response, and emergency management procedures. Bulk storage systems will be designed, constructed, and operated in accordance with IFC Performance Standard 3, the World Bank Group EHS Guidelines, and GMP. | 12/31/2027 |
| 13 | For Both Uganda and Tanzania OperationsMPL will develop and document a PS 1 aligned, site-specific stakeholder engagement plan (SEP) for Tanzania and Uganda operations. The SEP will include stakeholder identification, prioritization and mapping and will incorporate strategies and programs for engagement and reporting to all stakeholders (including institutional/regulatory stakeholders) critical to management of all the E&S risks identified under this ESRS. The community grievance mechanism developed under the SEP will be equipped to handle complaints and feedback from known and anonymous members of the surrounding community. As provided under PS 2, the community GRM will also allow for specific measures for identification and management of complaints related to SEA for community members who interact with project staff and where necessary, extended to respond to such complaints related to its principal contractors | 09/30/2027 |
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.