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
Environmental and Social Assessment and Management System:
The Naval Group Corporate E&S Risk Management Policy and Manual, Occupational Safety and Health Policy (OSH) Policy and Manual, Sustainability Policy and Quality Policy and Manual provide the overarching framework for E&S risk management in the Group, and they express corporate commitment to progressively align relevant projects and operations with IFC Performance Standards and apply the framework across relevant subsidiaries. The documents also outline the key E&S topics relevant to the Group operations, and for which risk management procedures should be developed and implemented by all subsidiaries, including Foodtec. Subsequently, Foodtec has adopted the E&S, OHS and Quality Manuals and developed an Integrated Occupational Health, Hygiene, Safety and Protection (OHSP) Policy and Manual for the Cacucao plant construction. The company is also implementing an ISO-aligned quality management system (QMS) and are advanced in their preparation for the ISO 9001 certification.
To comply with IFC PS and the Group policies, Naval Group will (i) expand the Group E&S Risk Management Manual by developing topic-specific procedures, at a minimum, covering E&S risk identification and impact assessment process, ambient air quality, greenhouse gas (GHG) emissions, wastewater and effluent, noise, hazardous materials handling, resource efficiency (water and energy), pesticide use, road transport safety, and E&S monitoring and reporting, each aligned with IFC PS; and (ii) update the Security Management Plan, Internal Emergency Plan, Stakeholder Engagement Plan, Community Grievance Management Procedure, and Waste Management Plan to adequately address related operational risks in line with IFC PS. Foodtec will adopt and implement the new/updated E&S procedures and plans across its operations (ESAP #1).
Identification of Risks and Impacts:
The ESIA for the new Cacuaco plant was completed in 2025 in compliance with Angolan environmental legislation, and environmental permit obtained. The E&S management plan (ESMP) and ESMP and the Integrated Occupational Health, Hygiene, Safety and Protection (OHSP) Policy and Manual are being implemented to identify and manage construction E&S risks. For the ongoing operations at Foodtec’s Viana plant, E&S risk identification and monitoring processes are primarily undertaken by standardized health, safety and environment (HSE) inspection checklists and the quality monitoring checklists; but opportunities exist to further strengthen and expand the methodology and scope of the process in line with IFC Performance Standards. The Group E&S risk identification and impact assessment procedure to be developed under ESAP #1 will be adopted and implemented by Foodtec and will be applied to future risk identification and assessment across the business.
The Viana plant wheat storage silos, back-up generators and direct LPG supply lines present operational fire and combustible Dust risks requiring specialized engineering assessment and mitigation measures. Similarly, the Cacuaco plant will include multiple grain and flour storage silos, which present potential off-site consequences. To adequately address these risks, Foodtec will engage a subject matter expert to conduct, for both sites, (i) a dust hazard analysis for combustible grain/flour dust; (ii) a hazardous area classification for operational areas and activities with inherent combustible dust hazard, (iii) fire and explosion risk assessment (FERA) including consequence analysis commensurate with the major accident risk. The recommended actions will be integrated into the management programs (for the Viana plant) and into the technical design (for the Cacuaco project). For the biscuit plant, which is still in early stages of conceptualization, Foodtec will ensure that an IFC-compliant ESIA is completed prior to commencement of construction (ESAP #2).
Management Programs:
The Foodtec QMS is implemented by a suite of procedures - preventive maintenance procedures; raw material supplier selection procedure; spill management procedure; machine safety procedure; critical operations training procedure; product recall procedure, internal regulation on occupational hygiene and safety, monitoring and audit procedure and emergency response procedure. In addition, the Naval Group E&S risk management programs implemented at Foodtec include: E&S risk management manual, environmental process map; social benefits program, community grievance mechanism program, waste management plan, OHS policy and manual, evacuation plan, security plan, internal emergency plan and a suite of HSE monitoring checklists. These plans and procedures cover some E&S topics in compliance with Angolan law but will be reviewed and updated to comply with IFC PS as part of ESAP #1 actions. For the Cacuaco construction site, the ESMP and the Integrated OHSP Policy and Manual are the primary documents being implemented to manage construction-phase E&S risks.
Organizational Capacity and Competency:
The Naval Group Board of Directors provides corporate direction and bears the ultimate accountability for E&S performance, advised by the Director of People and Compliance. The Foodtec Managing Director (MD) is responsible for overall implementation of the E&S, quality and food safety management systems, and regulatory compliance. The MD is supported by production line managers who ensure that E&S, quality and food safety requirements are adequately embedded into operational processes and related KPIs are met in their respective units. The Group HSE Manager, reporting to the Director of People and Compliance, coordinates ESMS implementation across all Naval Group subsidiaries, including capacity building and reporting. The HSE manager will be supported by HSE coordinators to be embedded in each subsidiary and new project, including Foodtec. The current training regime relates mainly to quality and food safety and a few other HSE topics. Going forward, Foodtec will (i) complete the recruitment and appoint two competent HSE coordinators, one for the current Foodtec operations and the other for Cacuaco project site to oversee the contractor’s E&S performance; and (ii) conduct an EHS training needs assessment and develop and implement an annual E&S training plan covering the key E&S topics defined in the training needs assessment report (ESAP #3).
Emergency Preparedness and Response:
Naval Group has a corporate Internal Emergency Plan that includes emergency response structure, communication and alert systems, evacuation and first aid procedures, emergency scenarios and specific response procedures, emergency equipment and resources, training, emergency drills, institutional responsibilities, and collaboration with external agencies – all suited for the scope of the project. Foodtec has adopted and implemented this Plan in their current Viana operations and has developed an appropriate plan for the construction site. Going forward, as part of ESAP #1 above, the Internal Emergency Plan will be revised and updated to include climate risks (floods and extreme heat), mandatory drill documentation requirements and to incorporate the emergency management measures to be proposed following the fire and dust explosion risk assessment (ESAP #2).
Monitoring and Review:
Naval Group has an Internal E&S Audit Register which defines E&S monitoring and audit methodology, documentation of findings and corrective action management. Although the E&S audits are required to be conducted semi-annually, there is no related documentation. The Group E&S monitoring and reporting procedure to be developed per ESAP #1 will include a comprehensive monitoring and audit structure, including formal requirements on continuous E&S floor level monitoring, reporting to management, and the format, periodicity and key performance indicators (KPIs) to be reported to the Board of Directors – and cover the future agro-commodity supply chain.
Supply Chain:
Foodtec currently imports wheat for pasta production from international traders, with origins in Europe. To obtain the raw materials for the new operations at Cacuaco once constructed, the company plans to establish a local agri-commodity supply chain for maize, rice, and soybeans in the next two years. Currently, Naval Group has a supply chain due diligence policy and procedure, being applied to the wheat importation business. The Group’s supply chain due diligence policy sets general risk-based requirements for identification, assessment, and management of E&S risks across the primary supply chain. To further align with IFC PS, the Group will develop a robust supply chain E&S risk management procedure that applies to all primary and high-risk suppliers and, where feasible, critical sub-suppliers, commensurate with the Group’s leverage over suppliers. The procedure will include, at minimum, supplier screening and risk classification methodology; supplier due diligence with clearly defined exclusion and red-flag criteria; mechanisms for formal decision-making and approval; minimum supplier contractual E&S clauses; training; and traceability, monitoring and documentation requirements, consistent with IFC PS1, and the supply chain expectation of PS2 and PS 6 (ESAP #4).
PS 2: Labor and Working Conditions
Naval Group has employed about 2,000 employees in their Angola operations. From this, Foodtec currently employs 569 employees, 37% of which are women. The Cacuaco plant is expected to generate approximately 2000 new jobs during the current construction and later operations phase of the plant.
Human Resources Policies and Procedures:
The Naval Group’s human resource management is governed by two core Group-level documents: the Group Human Resource (HR) Policy and the Group Code of Conduct and Business Ethics. These documents detail the company’s commitment to uphold the constitutional principles of the right to work, equality, human dignity, and employment protection, while also expecting all workers to act ethically, with integrity, and transparency. The HR Policy also has provisions governing employment, behavior, safety and security, and hygiene and is applied across all subsidiaries, including Foodtec. The Group will update the HR Policy to extend coverage to third party and supply chain workers associated with the planned local agri-commodity supply chain and to formalize periodic monitoring and review requirements, in line with IFC PS 2 (ESAP #5).
Working Conditions and Terms of Employment:
The Group HR policy covers contract requirements (open-ended as the default), working hours, overtime, leave, maternity/paternity, termination, severance, and redundancy procedures. All workers at Foodtec and the Cacuaco project have employment contracts stipulating employment conditions, remuneration, employment rights and available channels for grievance redress. Employment practices follow national law and are subject to periodic governmental audits. The Viana plant employees work on 12-hour shifts to support near-continuous production, with overtime compensation of 20% above standard renumeration.
Non-discrimination and Equal Opportunity:
The Group HR policy recognizes that work is a right and a duty of all, and that fair remuneration, professional training, rest, leave, social protection, and occupational health and safety must be upheld. The policy prohibits any form of discrimination based on ancestry, sex, race, color, disability, religion, political opinion, or social status.
Workers Organizations
The Group HR policy mentions explicit recognition of trade unions, collective bargaining and right to strike, as regulated by national law. At the time of this appraisal, none of the Foodtec workforce was unionized. The company also reported that no past labour action (e.g. strikes) has occurred in its operations.
Grievance Mechanism:
Naval Group has a Group level grievance mechanism available to workers. To implement this, there are physical grievance forms and online PC stations located at the reception areas of Foodtec offices to be used by the aggrieved parties, and an option for in-person grievance submission. The workers on the Cacuaco project have access to the same grievance mechanism. To align with IFC PS, Naval Group will (i) update the grievance mechanism to provide the procedure for submission and management of anonymous or sensitive grievances, including GBV/SEAH related grievances; (ii) extend the grievance mechanism to Cacuaco project contract workers; and (iii) sensitize all workers on the new/updated grievance mechanism (ESAP #6).
Protecting the Workforce:
Foodtec complies with the Group HR requirements and national law, and do not employ children. All current employees and contractors are above 18 years old and are required to provide government-issued identification.
Retrenchment:
Due to the seasonality of some of Foodtec’s operations (e.g., project workers and production seasonality), periodic workforce adjustments may occur across the different business areas. Retrenchments are currently handled in accordance with Angolan labor laws. To strengthen compliance with IFC PS2, Naval Group will develop a Retrenchment Policy that applies across its subsidiaries and sets out a fair and transparent process for workforce reductions, including consultation and communication arrangements, objective and non-discriminatory selection criteria, timely provision of statutory severance benefits and access to workers’ grievance mechanism (ESAP #7).
Occupational Health and Safety:
Key OHS risks for Foodtec include physical hazards such as collisions from road transport, struck-by injuries from site traffic, crush injuries from loading and offloading activities, working at height (mill and storage silos), confined space entry (storage silos and oil storage tanks), fire and explosion hazards (including flammable liquids at the oil and diesel storage areas), and manual handling at the bag stitching machines (flour mill). The Naval Group OHS Policy and Manual establishes a comprehensive OHS Management System applicable to all units, employees, contractors, and service providers at Group facilities. The Manual defines the requirements for identification of OHS hazards and assessment of risks; application of the hierarchy of controls; management of high risk activities through operational controls and safe work procedures (including permit to work where relevant); emergency preparedness and response; occupational health surveillance and worker wellbeing; training, awareness, and worker participation monitoring; incident investigation, and continuous improvement. Medical screening is conducted for all new employees based on job requirements. Periodic health surveillance is conducted every two years for employees between 18-45 years old, with annual screenings for those above 45 years old and workers on night shifts. Foodtec provides monthly, risk-based internal OHS training to workers. The company has recently begun documenting OHS incidents, and the few reported cases to date are minor injuries. No fatalities have been reported across the Group’s subsidiaries in the last three years.
For the Cacuaco project, key OHS risks identified arise from vehicle movements, materials loading and offloading, trenching and deep excavations, lifting operations, working at heights, hot works, chemical storage, work in confined spaces. The ESMP and the Integrated Occupational Health, Hygiene, Safety and Protection (OHSP) Policy and Manual are being implemented to manage construction phase E&S risks at the site.
To adequately implement the OHS management system in line with IFC PS, (i) Naval Group will update the OHS Manual to set Group OHS KPIs, tracking and reporting requirements in line with the Good International Industry Practice (GIIP); (ii) Foodtec will conduct an OHS risk assessment (including exposure to heat stress), at the Viana plant in line with the Group OHS Policy and IFC PS, prepare a time-bound action plan and implement the required mitigation measures; (iii) Foodtec will develop and maintain an OHS risk register for the Viana plant; and (iii) Foodtec will develop and implement an OHS training program that prioritizes the key risks at their operations; and (iv) Foodtec will extend the updated OHS reporting requirements and reporting templates to the Cacuaco project (ESAP #8).
Workers Engaged by Third Parties
Foodtec uses contractors and service providers for specific operational activities (fuel, gas and input material deliveries) and for the Cacuaco project. The current project contract template includes some labor, OHS and stakeholder engagement requirements, but it is not sufficient to meet IFC PS requirements. While the Group OHS, HR, quality and food safety procedures are expected to cover third-party workers, there are no formal structures to enforce and monitor compliance, especially for long term new project contractors with a large workforce. Naval Group will therefore develop a Group Contractor HSE Management Procedure, which will provide requirements on contractor selection, supervision, auditing and reporting requirements. The Procedure will also set minimum provisions to be embedded into contracts with third parties – including provisions related to fair terms of employment, non-discrimination and equal opportunity, freedom of association, prohibition of forced and child labor, occupational health and safety, access to fair grievance mechanisms, and reporting. Once developed, Foodtec will amend existing contracts with active contractors, communicate the requirements to contractor workers in languages they can understand and implement the Procedure for the ongoing Cacuaco project (ESAP #9).
PS 3: Resources Efficiency and Pollution Prevention
Resource Efficiency:
The main energy and water consumption areas at Foodtec are the Viana plant, Cacuaco construction site and road transport (fuel). The pasta production equipment at the plant are designed for energy and water efficiency, and the primary energy sources are grid electricity and LPG and occasionally diesel, for the back-up generators. In future, the company plans to install a dedicated grid power line from the nearest substation to stabilize supply and reduce reliance on back-up diesel generators. The same will apply to the new Cacuaco plant once operational. Foodtec considers energy and water efficiency in equipment procurement decisions (e.g., LPG-fired boilers instead of diesel) and through implementation of practical operational measures, including preventive maintenance to reduce leaks and losses. Energy and water consumption is monitored through utility bills and operational controls. At the Cacuaco construction site, grid electricity is the main source of energy, supplemented by back-up diesel generators. The project ESMP has water and energy efficiency measures, being implemented by the contractor. Fuel consumption by the company fleet is tracked by utility bills. The Group E&S monitoring and reporting procedure to be developed under ESAP #1 will include more robust and appropriate resource efficiency monitoring protocol, with baselines and intensity metrics (e.g., kWh/ton product; m³ water/ton product; liters diesel/vehicle km or liters/ton km) and time bound targets informed by applicable WBG EHS Guidelines, and will be implemented across Foodtec operations.
Air Emissions:
The main sources of ambient emissions (mainly Particulate Matter and fugitive dust) from the project include vehicles/trucks and other moving equipment use, loading/unloading of raw materials and products at the Viana plant and the Cacuaco construction site; while stack emission sources include diesel generators at the operating Viana plant and the Cacuaco construction site. LPG at the Viana plant (consumption estimate ~850 t/day) is supplied through a dedicated line from the national oil and gas agency; and the plant also has eight back-up generators with a total of 6,600kVA capacity. The current measures to mitigate air emissions at the Viana plant include more reliance on grid electricity and LPG, paved walkways and roads, switching off moving equipment after use and automated switch to/from back-up diesel generation. Foodtec will adopt and implement the air quality management and E&S monitoring and reporting procedures to be developed under ESAP #1 for monitoring ambient emissions and stack emissions in their operations.
Greenhouse Gas (GHG) Emissions
The main GHG sources in the project are related mainly to the energy use at the Viana plant and fleet. Foodtec does not currently estimate GHG emissions from their operations. The IFC-estimated annual GHG emissions from these operations exceed 25,000tCO2e/year. Therefore, Foodtec will adopt the Group GHG management plan required under ESAP #1, which will also set a baseline, identify reduction measures, and establish targets and reporting requirements.
Wastes and wastewater management:
The main types of waste produced from the Viana plant and fleet operations include general paper and plastic waste, off-spec materials from the material packaging processes, electronic waste, food-related materials, truck/equipment parts, oils/grease and pesticide packaging and handling materials. The company has a waste management plan, and the solid waste is collected and disposed of by a licensed service provider. Wastewater is generated from sanitary activities, as stormwater, and as process wastewater form the production lines. Process wastewater is typically high in biochemical and chemical oxygen demand (BOD and COD) resulting from organic wastes entering into the wastewater streams, and from the use of chemicals and detergents in various areas within the food processing lines. All the wastewater is currently collected in a secure effluent tank and removed periodically by licensed sanitation tanker services. The company plans to install own wastewater treatment plant after construction of the new biscuit factory and at the Cacuaco industrial complex. The Cacuaco construction site also implements a separate waste management plan, approved by the environmental regulator and has engaged a licensed waste service provider. The Group will (i) update the waste management plan as required under ESAP #1 to include specific requirements on waste identification and classification, waste quantification and on-site waste handling, documentation requirements and disposal due diligence; and (ii) the Group’s wastewater and effluent management procedure to be developed under ESAP #1 will define effluent quality limits consistent with Angolan law and applicable elements of the WBG General EHS Guidelines (Wastewater and Ambient Water Quality). It will also establish a schedule for effluent sampling and testing in compliance with these standards, and will be adopted by Foodtec.
Hazardous Materials Management:
The main hazardous materials include LPG, diesel, lubricants and oils, laboratory chemicals, pesticides, fumigants and solvents. As part of the quality and food safety requirements, these materials are handled at safe distances from food production processes and stored at designated labelled areas. To further strengthen this practice in line with IFC PS, the Group hazardous materials management procedure to be developed under ESAP #1 will include elements on preparation and maintaining of a hazardous materials register, segregation by compatibility, secondary containment (bunding) in chemical storage areas, combustible dust-related fire and explosion control in flour handling areas, emergency response, worker training and PPE use, permitted waste disposal contractors and integration with the site EPRPs; and will be adopted by Foodtec.
Pesticide Use and Management:
Pesticides are used at Foodtec to prevent pest infestations in both raw materials and finished products. Foodtec has set some key safety requirements related to pesticide use in quality and food safety procedures. The Group will develop an integrated pest management (IPM) policy and procedure (under ESAP #1) which will define the types of pesticides permitted, equipment used, storage, handling and application requirements. The procedure will strictly prohibit procurement, storage and use of chemical products that fall in the World Health Organization Recommended Classification of Pesticides Class Ia (extremely hazardous) and or Ib (highly hazardous). Use of Class II (moderately hazardous) chemicals will be permitted only with appropriate controls on their storage, handling and application being in place.
PS 4: Community Health, Safety and Security
Fire and dust explosion risks: The Viana processing plant has six 10,000m3 of wheat storage silos, eight back-up generators with a total of 6,600kVA capacity and direct LPG supply lines. Given the proximity of the plant to other industrial facilities, these assets present potential fire and explosion hazards with possible off-site consequences. Temperature and pressure at the wheat silos are digitally monitored and controlled via automated pressure relief systems. There are fire suppression systems at the diesel storage areas and across the production areas. The site is equipped with onsite emergency response equipment including fire-fighting equipment and fire extinguishers within all buildings. Evacuation and muster points are clearly marked, and visitors are provided with relevant induction. The Cacuaco project site has portable fire suppression equipment, and risks related to fire and dust explosion are minimal at this construction stage. However, the risks will be significant during plant operation given its proximity to residential areas. To adequately assess risk significance and define any additional mitigation for the fire and dust explosion risks at the Viana and Cacuaco sites, the assessments to be undertaken per ESAP #2 above will aid in implementing suitable fire and dust explosion risk management programs to address any identified gaps. In addition, as required under ESAP #1, Internal Emergency Plan will be updated to reflect the findings and outcomes of the fire and dust explosion risk assessment at the Viana plant, including coordination protocols with external emergency services for credible off-site consequences.
Road Transport: Foodtec owns about 25 vehicles, and leases additional trucks on a need basis. The transport and logistics support is provided by an affiliate company, Velotrans. Velotrans employs trained and experienced drivers with appropriate driving permits, and the vehicles are equipped with In-Vehicle Management System (IVMS) and are monitored from a designated control room. As required under ESAP #1, Naval Group will develop a road transport safety management plan to be applied at Foodtec and adopted by Velotrans. The plan will, at minimum, include benchmarks for transport E&S risk assessment, vehicle safety management, driver and journey management, selection and monitoring of contractor transport service, community health and safety, emergency preparedness and response, training, incident monitoring and reporting. Complaints related to GBV/SEAH will be addressed through the external grievance redress mechanisms to be developed as part of the SEP and referenced in the plan.
Security Personnel: To secure assets and facilities, Foodtec utilizes armed guards from a Naval Group affiliate security company. All Foodtec facilities are fenced with 24-hour access-controlled and manned by the security teams. As part of ESAP #1, Foodtec will update the security management plan to align with PS4 and UN Voluntary Principles on Human Rights. Based on the Plan, Foodtec will implement a robust approach to security risk assessments, personnel screening/vetting, hiring and training process including on use-of-force requirements, security code of conduct, access control and crowd management, security equipment provision, site monitoring and surveillance, incident investigation and reporting protocols.
