IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System (ESMS). Edita manages E&S risks and impacts associated with its operations through a corporate ESMS comprising procedures and work instructions applicable across all production facilities. The ESMS is based on a corporate Safety, Health, and Environment (SHE) policy that is broadly consistent with PS1 requirements. Edita's E&S management approach draws on compliance with applicable national regulatory requirements as a baseline, complemented by adherence to ISO 14001 (environment), ISO 45001 (occupational health and safety), and ISO 22000 (food safety). Edita implements EHS procedures and work instructions to meet its corporate E&S policy commitments, country-level E&S legal and regulatory requirements, and ISO certification requirements. The SHE procedures include risk assessment, permit work, working at height procedure, log-out/tag-out, monitoring and reporting, continuous improvement, incident investigation, contractor management, among others. The latest ISO 14001 and 45001 certification audit report for the existing factories showed a satisfactory level of implementation of these standards with minor non-conformities identified. Edita conducted an Asset Acquisition E&S screening (Gap Analysis) for the Iraq facility in March 2026, all permitting requirements were identified and are being obtained. The brownfield factory in Iraqi is established and will be implementing the corporate ESMS in a phased approach based on operational risks priorities. Going forward, Edita will extend the ESMS applicability to the Iraqi plant to meet IFC PSs and WBG General and Sectoral Guidelines for Food and Beverage Processing performance-based requirements as well as Edita standards and local regulatory requirements (ESAP #1). Edita plan to begin the ISO certification process for the Iraqi facility in 2027 at the earliest, contingent on the successful establishment and stabilization of Edita's management systems at the site.
Organizational Capacity/Competency: Edita has established a dedicated EHS function at both corporate and factory levels. At the corporate level, an EHS Director holds overall responsibility for EHS performance, supported by an EHS Manager. At the factory level, each facility has a Deputy EHS Manager, an EHS Supervisor, and shift coordinators, all reporting to the corporate EHS function. The quality and food safety function mirrors the EHS structure, and procurement/supply chain is centralized at the corporate level. For the proposed regional expansion in Iraq, Edita has appointed a Quality, Health, Safety and Environment (QHSE) Manager reporting to the corporate SHE Senior Manager. A local and dedicated HR “People and Culture” manager responsible for day-to-day worker management is present the Iraqi facility.
Training: Edita operates a structured E&S training program supported by documented plans, training logs, attendee records, and defined competency frameworks. Training needs are identified through risk assessments, incident investigations, audit findings, and competency gap analyses, with a minimum requirement of six SHE training hours per employee annually. Topics covered include chemical handling, confined space entry, electrical safety, fire prevention, forklift operation, lockout/tagout (LOTO), machinery safety, manual handling, permit-to-work, and risk assessment, delivered in part through standardized digital modules for production workers. Supervisors and managers complete the IOSH Managing Safely program; EHS personnel are certified as ISO 14001 and ISO 45001 Lead Auditors and as Train-the-Trainer. Contractors and visitors receive mandatory SHE inductions prior to site access, and sales drivers complete annual safe-driving training. The same training program will be also extended to the Iraqi facility (ESAP #2).
Emergency Preparedness and Response Plan (EPRP). Edita has a corporate Emergency Response and Crisis Management framework implemented through site-specific emergency response plans across all facilities. The framework covers emergency response teams, evacuation procedures, firefighting and alarm systems, ammonia detection, steam-based fire suppression, and integrated smoke extraction systems, supported by annual training and digital monitoring systems for firefighting readiness. Emergency drills are conducted regularly across all sites with records maintained. For the proposed Iraq facility, a dedicated site-specific EPRP will be developed in line with the corporate framework, with trained emergency response teams and coordination with local civil defense authorities will be established prior to commissioning; drills will be initiated during the commissioning phase (ESAP #3).
EHS Monitoring and Reporting: Edita has established a monitoring and compliance framework anchored in a centralized Corrective and Preventive Action (CAPA) system that captures audit findings, incidents, inspections, behavioral safety observations, and regulatory non-compliances, with tracked responsibilities and timelines. Performance is reviewed through monthly plant-level meetings focusing on safety KPIs, environmental compliance, and operational risks, and quarterly executive reviews with the CEO covering critical risks and strategic ESG priorities. Annual ISO audits by accredited certification bodies, routine environmental monitoring, and internal ESMS audits conducted through eREMs— Edita's digital environmental reporting and management platform — provide additional layers of oversight and accountability. This monitoring system will be rolled out in the Iraqi facility as well (ESAP #4).
Supply Chain. Edita has a supplier selection process that integrates quality, environmental, and social criteria, supported by documented supplier E&S qualification requirements. New local suppliers are assessed through document review and on-site inspections conducted by Edita's quality team; existing suppliers are monitored through annual audits and performance evaluations. For the new Iraqi facility, Edita will: (i) roll out its Supplier Code of Conduct to the Iraqi facility whereby it will be signed by and integrated into commercial agreements with all third-party suppliers; and (ii) implement a sustainable sourcing questionnaire for third-party suppliers involved in high-risk agro-commodities — particularly cocoa butter, cocoa powder, and palm oil — to confirm sustainable production practices (ESAP #5).
PS2: Labor and Working Conditions
Globally, Edita has over 8000 employees, of which around 4% are female- spread across three countries, namely Egypt, Morocco and Iraq. 265 direct workers are in the Iraqi facility. Edita outsources workers through worker agencies based on seasonal needs to support industrial operations and has 35 outsourced workers in the Iraqi facility.
Human Resources Policies and Procedures. Edita maintains a suite of HR policies and procedures covering human resources, code of conduct and ethics, anti-discrimination and diversity, supplier E&S requirements, worker grievance mechanism, and contractor management. Edita's Code of Conduct and HR policies include explicit prohibitions on child labour, forced labour, and discrimination, with supplier requirements mandating compliance with national legislation and ILO core labour standards in line with national labor law requirements and PS2. No instances of child or forced labour have been identified in Edita's operations or primary supply chain.
Workers Grievance Mechanism. In all its operations, Edita conducts monthly ‘in touch’ meetings at all factories and distribution centers to provide a forum for workers to discuss workplace concerns. These meetings are documented and presented to the CEO on a regular basis. A formal worker grievance mechanism is accessible to both direct and contracted workers (called VoiceUp), ensuring confidentiality, and allows anonymous submissions, covering issues such as discrimination, harassment and gender-based violence. The mechanism is communicated through different channels, including training sessions, communications, and onsite materials, with contractors briefed during SHE inductions. This mechanism will also be rolled out at the Iraqi Facility (ESAP #6).
Workers Engaged by Third Parties. Edita monitors contractor compliance through: contractual SHE requirements; site SHE inductions; ongoing supervision by Edita SHE representatives; and contractor performance audits. All contractors must demonstrate compliance with minimum wage, working hours, overtime, health insurance, OHS standards, and labor law requirements as conditions of contract.
Occupational Health and Safety (OHS). Significant gaps in OHS at the Iraq facility have been identified at the time of acquisition. Key operational safety risks include weak personal protective equipment (PPE) compliance, gaps in safety culture, and deficiencies in equipment and workplace controls, such as lack of standardized maintenance logs, insufficient isolation and protection systems for electrical and mechanical equipment, and potential manual handling risks due to limited mechanization. Life and fire safety systems, while certified locally, do not meet National Fire Protection Association (NFPA) or Edita standards, with identified issues including inadequate firefighting capacity, absence of sprinklers in warehouses, and poorly defined emergency escape routes. Overall, the site requires upgrades in systems and physical controls, with a structured corrective action plan focused on strengthening SHE management, improving safety culture and training, and upgrading infrastructure to meet international OHS standards (ESAP #7)
Child and Forced Labor. Contextually, the risk of child/forced labor exposure in Edita's supply chain is low in the countries where it operates. As part of Edita’s supplier selection process, it implements a supplier social requirements procedure, which includes requirements on the prohibition of child labor. With respect to the high child/forced labor exposure risk in the sourcing of cocoa derivates and palm oil, Edita will implement additional E&S supply chain management measures to further align with IFC PS2 supply chain requirements. (ESAP #8)
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. Edita monitors and manages consumption of energy, water, and waste generation across its factories in line with PS3 objectives, with performance data and optimization initiatives disclosed in its annual sustainability report.
Energy and Water. The Iraqi facility is at the early stages of metering infrastructure deployment. It is currently operating under a lump-sum electricity agreement with the public grid. Given the instability of the public grid supply in Iraq, the facility relies predominantly on diesel generators for production continuity. Energy consumption in Iraq is expected to be higher than at other Edita sites worldwide due to elevated ambient temperatures requiring greater air conditioning capacity for production processes.
As for water, the Iraqi facility is also connected to the public water grid. Due to the frequent water outages, groundwater serves as the primary supplementary source and the facility draws water from an internal well, that is then treated through an onsite reverse osmosis (RO) system. Edita will collect and share accurate data on both electricity and water consumption once the metering infrastructure is commissioned. (ESAP #9)
Air Emissions. GHG emissions (Scope 1 and 2) are tracked monthly across all plants as part of Edita's environmental monitoring framework. However, there is yet to be any air emissions information pertaining to the Iraqi facility. Edita will hire a third party to conduct baseline measurements of air emissions at the Iraq facility (ESAP #10) and will roll-out the environmental monitoring framework to meet regulatory requirements for air emissions. (ESAP #11)
Waste and Wastewater Management. Solid waste generated by the Iraqi facility, such as plastics, cardboard and food waste, is stored on-site and disposed of through licensed solid waste contractors. As part of Edita’s ESMS, Edita tracks and maintains waste manifests to confirm the final destination of the waste disposal and will roll out the same system in Iraq (ESAP #12).
Edita Iraq’s facility is an industrial park and wastewater is disposed of through the facility’s connection to the Iraqi national drainage system. The production process generates industrial wastewater that is usually characterized by high organic loads and sediments. Edita will test water effluent from the production process to determine if additional wastewater treatment is necessary (ESAP#13) and if so, will take the necessary actions to treat the water prior to discharge (ESAP#14).
PS4: Community Health, Safety and Security
Food Safety Management. All products produced by Edita adhere to food safety and quality standards. All the factories are required to meet the National Food Safety Authority requirements and achieve and maintain ISO 9001 (quality) and ISO 22000 (food safety).
Fleet Management. Edita operates a fleet of approximately 1,200 sales and distribution vehicles, with in-vehicle monitoring systems installed on 1000 vehicles. All drivers receive annual safe-driving training, complemented by a defensive driving program currently being rolled out through an outsourced provider. The fleet is further managed through formal inspection checklists, contributing to an improvement in vehicle collision performance, with the rate decreasing to 1.71 per million man-hours in 2025, down from 1.99 in 2024. In Iraq, a formal vehicle safety assessment for all third-party logistics operators covering raw material inbound logistics, finished goods distribution, and export activities is currently being conducted as part of Edita's Iraq supplier evaluation program.
Security Personnel. Edita has not experienced any material security events. The security arrangement employed in the facilities and distribution centers comprises fences and gates for access control, CCTV cameras, and unarmed security guard directly hired by Edita. Edita’s Iraqi facility is located within an industrial park and based on the current operational assessment, the security risk profile of the Iraq facility does not require extraordinary security measures beyond standard industrial site controls. The large majority of the workforce consists of local Iraqi nationals, which minimizes the exposure profile associated with expatriate or foreign personnel and site perimeter security (access control, guarding, CCTV) is managed in line with standard industrial facility requirements.
