IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
The company identifies, and subsequently manages, E&S risks and impacts associated with its operations through compliance with applicable national standards, laws and regulations, the E&S requirements within applicable regulatory permits, the requirements within its ISO certifications and requirements from their clients/customers. While Marquardt Tunisia operations are not subject to the National Environmental Protection Agency (ANPE) requirement for Environmental Impact Assessment (EIA), the company implements environmental risk identification, assessment and develops and implements applicable practices and procedures as per the ISO 14001 standards, including, for example, the management of waste and hazardous waste from its manufacturing processes.
Marquardt Group has a corporate Environmental Policy as well as an Occupational Health and Safety (OHS) Policy which are applied to the project under an integrated management system (IMS). This IMS covers ISO 9001
(Quality), ISO 14001 (Environment) and ISO 45001 (Occupational health and safety) certification as well as International Automotive Task Force (IATF) 16949 requirements across all Group facilities, and which have been extended to include this project.
Marquardt Tunisia has a dedicated IMS team responsible for environmental, health, and safety (EHS) compliance. The team is led by a local IMS manager at each facility, who oversees EHS reviews. Across the Marquardt group, compliance managers are present at all sites, including Tunisia, and meet bi-monthly to discuss new guidelines, feedback, and cultural translation of compliance standards. In addition, the Marquardt Board provides oversight of E&S performance across business activities. At headquarters, key ESG personnel include an ESG Director responsible for overseeing E&S and sustainability initiatives across the Group’s operations and for coordinating the Group’s biannual sustainability reporting.
Marquardt has documented an emergency response plan (ERP) for its operations in the global management manual. Marquardt Tunisia has a general emergency plan, an infrastructure emergency plan and an environmental emergency plan covering natural disasters and chemical spills scenarios. The ERP includes risks such as use of Nitrogen for melting components and use of soldering paste and lists associated actions to be taken to address non-routine incidents related to such. Around 10% of the workforce have been trained in fire safety and operation of fire safety equipment and are named “first intervention team”. Fire detection, fire suppression equipment, evacuation route maps and assembly points have been placed at appropriate locations at the 3 facilities. The compliance team, in coordination with the facility management team, conduct internal audits to ensure implementation of fire safety measures twice a year.
As part of the corporate IMS management, the company monitors key performance indicators (KPIs) such as record of injuries, fire incidents and energy consumption during operations. As mentioned above, these KPIs are reported on monthly basis by the local IMS manager to global management team. All incidents of non-compliance are summarized and discussed in the monthly management meeting and the team analyses inspection outcomes, the root causes of any incidents or non-compliances and monitors the implementation of corrective actions.
Given Marquardt’s demonstrated adherence to the above-mentioned regulatory, certification and customer requirements the IMS at the project level is judged to be appropriate with respect to the scale of the operations, their associated E&S risks and impacts, and therefore the objectives of this Performance Standard.
PS2: Labor and Working Conditions
Marquardt Tunisia currently employs 1968 (approximately 60% females and 40% males) with around an additional 400 jobs expected to be created by 2030. Marquardt has documented Human Resources (HR) policies and procedures that are consistent with the national labor regulations and apply to all employees. Each worker receives a written contract that describes the working conditions and terms of employment. The employment contract follows the Tunisian labor law including provision of medical insurance and compliance to gazette working hours; man hours worked are monitored and in a normal work week do not exceed the hours stipulated by national regulations. If exceeded, the overtime compensation scheme is applied in accordance with the Tunisian labor law. Beyond the existing on-boarding training, HR team will conduct refresher sessions, as part of the annual training plan, around contractual alignment with local labor law (ESAP item 1).
The company has policies and procedures related to its commitment to the non-use of child labor, forced labor, non-discrimination and equal opportunity and freedom of association. Out of the total workforce, there are currently 400 unionized employees and there is a workplace committee that consists of 6 employee representatives. The company code of conduct covers compliance with ESG standards. There is also an anti-sexual harassment directive at Marquardt group level. In place of an employee handbook, Performance Standard 2 (PS2) related policies are detailed in the Marquardt Declaration of Principles on Human Rights and are provided to new hires during the on-boarding program. These are accessible on the company online platform for employees.
The union acts as an important channel for the voicing of employee grievances to management. There is also a whistle blowing procedure in place. Whereas these options allow for grievances to be heard, the company will enhance the grievance mechanism for its internal stakeholders more in line with PS2. For example, the grievance mechanism will allow for submission of anonymous grievances. As currently practiced with the code of conduct, this enhanced grievance mechanism will be included in related training and awareness campaigns conducted by HR department (ESAP item 2).
Marquardt requires its suppliers to comply with national labor laws through inclusion of specific contract clauses. There is an overarching code of conduct published on the company website for suppliers and service providers. Registered suppliers are subjected to regular labor audits undertaken by the IMS and procurement teams of Marquardt Tunisia.
The company has formulated a health and safety policy and a site-specific OHS manual based on Hazard Identification and Risk Assessment. Typical OHS risks for this type of work include fire or explosion hazards, ergonomics, exposure to chemicals and mechanical or electrical risks. There are physical control measures such as product painting robots enclosed in a sealed environment, negative pressure gates between different production areas and clear floor demarcation at each facility to manage safely workflow. Workplace noise, illumination and air quality monitoring records are regularly checked and maintained within the applicable standards. The EHS team collects the incident statistics on a monthly basis from each site. Since start of operations, there has been no fatal work-related accidents, and the Marquardt Tunisia operations continue to monitor incident rates as a KPI on daily basis. The use of PPE such as earplugs in high noise areas will be closely monitored through the IMS audit team updated monitoring checklist (ESAP item 3).
PS3: Resource Efficiency and Pollution Prevention
The company’s operations / production process primary involves the assembly of user interphase vehicle components which do not result in significant quantities of waste and emissions. However, in alignment with the company environmental policy, Marquardt Tunisia is implementing initiatives related to resource efficiency such as baseline tracking of GHG emissions to highlight areas where efficiencies can be improved. At the current operational capacity, the annual GHG emissions are 10,121.49 tons CO2eq. Scope 1 emissions reported for 2025 were 125.72 tCO2eq and Scope 2 emissions were reported at 9,995.77 CO2eq
After project completion and the planned facility expansion, including the implementation of a 1.7 MWp Solar PV implementation for MAT-3, the annual GHG emissions are expected to increase to 16,871 tons CO2eq/year. The new facility is expected to reduce GHG emissions by 887 tons CO2eq/year through the use of renewable energy from the new MAT-3 facility. Quantification of GHG emissions is conducted annually, using internationally recognized methodologies for integration into the Group’s annual sustainability reports.
As driven by the Groups ISO 50 001 certification, under the IMS, the company implements resource efficiency projects across its facilities. In the Environmental Guidelines for Marquardt Tunisia, the company states that measures to increase energy efficiency and thus reduce greenhouse gas emissions are defined and tracked as part of a measurement plan. This is part of the Marquardt plan to reduce its corporate carbon footprint. Greenhouse gas emissions are reduced wherever possible such as the use of variable speed drive (VSD) compressors to improve consumption ratio between electricity consumption and required air flow. Also, in the Heat Ventilation and Air conditioning (HVAC) system, the refrigerants used in closed systems are R410A, R32 and R513. All equipment installed across the Tunisia facilities are selected for low environmental impact.
Electricity is sourced from the national grid for all facilities, and there are no other major air emissions / pollution from the company’s operations. Marquardt Tunisia uses back-up generators and will monitor emissions and ambient air quality at plant boundaries on annual basis (ESAP item 4).
Water for all the facilities is sourced from the local utility supply company. Wastewater is mainly from domestic use and is discharged to the industrial zone wastewater network. To prevent contamination of wastewater, with chemicals used in the process for product finishing, there is dedicated storage space for empty paint cans and contaminated spill kits which are then handled by a licensed company for disposal. Wastewater is tested once a year to confirm quality of water discharged to the sewage system by the industrial zone and compliance with applicable limits.
The company has procedures for storage, and disposal of hazardous and non-hazardous solid waste, consistent with applicable legal requirements. Such waste is collected and disposed of by the available licensed service provider. Due to the lack of hazardous waste handling facilities in Tunisia, the collected hazardous waste is shipped to France for safe treatment. A destruction certificate is shared with Marquardt Tunisia by the collector.
PS4: Community Health, Safety and Security
As the project is located within an existing industrial complex and involves expansion of existing finishing processes, no significant additional impacts on community health, safety, or security are anticipated. To address any increase in local traffic associated with the expansion, including employee transportation buses, the company will implement driver awareness measures on safe driving (ESAP item 5).
The facility employs unarmed security personnel who are also trained in emergency response. The company conducts regular training for security personnel on standard operating procedures, including human rights and community engagement.
