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:
Policy, Environmental and Social Assessment and Management:
Jumia has yet to develop corporate Environmental and Social (E&S) and Occupational Health and Safety (OHS) policies. As per ESAP #1, the company will develop corporate E&S and OHS policies and will further develop and implement an Environmental and Social Management System (ESMS) aligned with IFC Performance Standards requirements. The company will ensure that climate change and occupational health and safety considerations are integrated into its ESMS.
Identification of Risks and Management Programs:
Risks are currently tracked through Health, Safety and Environment (HSE) audits and operational monitoring processes. However, the company has not yet established a formal, documented risk management program covering all countries of operation. No Environmental and Social Impact Assessment (ESIA) was prepared prior to the commencement of warehouse activities, which limits the availability of baseline information and the systematic identification of site-specific E&S risks and mitigation measures.
The company has initiated a regulatory compliance process in each country to ensure full legal and operational compliance. This process has commenced in Nigeria, where the ESIA was expected in June 2026, while in Cote d’Ivoire, the Terms of Reference (ToR) are being finalized. As per ESAP #2, the company will develop country-specific ESIAs aligned with IFC Performance Standards requirements, including the assessment of climate change-related risks. As part of the ESMS development, the company will establish a comprehensive E&S risk identification process and maintain a centralized risk register covering all operations and activities to ensure compliance with E&S requirements and alignment with the company’s E&S policy.
Management Programs:
Jumia has yet to establish formal E&S management programs. To align with IFC PS1 requirements, the company will develop and implement documented management programs covering, at a minimum, waste management, road safety, occupational health and safety, emergency preparedness and response, contractor and third-party service provider management, pollution prevention, and stakeholder engagement.
Each program will define applicable legal and IFC requirements, risk-based mitigation measures, roles and responsibilities at the corporate and country levels, implementation schedules, training needs, monitoring indicators, reporting requirements, and corrective action processes. These programs will be integrated into the ESMS and periodically reviewed and updated based on monitoring results, audits, incidents, grievances, and changes in operations.
E&S Organizational Structure :
E&S oversight is currently decentralized, with no dedicated Group-level E&S/OHS function responsible for establishing, implementing, and monitoring the corporate ESMS across all countries of operation. Group-level audits are conducted by the Group Chief Supply Chain and Operations Officer and the HR Officer, while local implementation is handled by HR and operations teams. Given the company’s multi-country operations and reliance on warehouses, logistics activities, third-party logistics providers, and independent contractors, Jumia will establish a corporate-level E&S/OHS function with clearly defined authority, resources, and accountability for E&S and OHS compliance, monitoring, reporting, training, contractor oversight, and pollution prevention. This function may be led by a suitably qualified corporate E&S/OHS Manager or Director, supported by country-level E&S focal points or managers responsible for ESMS implementation at the country level (ESAP #3).
E&S Training:
Training on first aid, fire safety, emergency evacuation, basic life support, electrical safety, and working at height has been delivered in some countries but is not implemented consistently across all countries of operation. The company does not yet have a formal E&S training plan. As part of the ESMS (ESAP #1), the company will develop and implement a training plan covering E&S policies and procedures, general OHS, road safety, defensive driving, and other relevant topics.
Emergency Preparedness and Response Plan:
Emergency preparedness measures are in place at the site level, including evacuation plans, emergency drills, fire detection systems, and first aid arrangements, although implementation is still ongoing in some countries. Each site has an evacuation plan, clearly defined assembly points, and emergency contact information readily available.
Emergency drills and alarm tests are conducted periodically across selected countries to ensure the readiness and effectiveness of emergency procedures. In some countries, full-scale simulations have also been carried out, including alarm activation and complete evacuation processes. These exercises are recorded through CCTV systems to verify that all procedures are properly executed from start to finish, from alarm activation to the Fire Marshal or Supervisor guiding all employees through safe exits to the designated assembly points.
Fire alarm systems and smoke and heat detectors are in place or are being progressively deployed across warehouses. As part of the ESMS (ESAP #1), the company will formalize and standardize emergency preparedness and response procedures across all operations and ensure full implementation. As per ESAP #4, the company will develop an Emergency Preparedness and Response Plan (EPRP) implementation roadmap to ensure compliance with both national and IFC requirements.
E&S Monitoring and Review:
As part of its ESMS, the company will develop an E&S monitoring plan and procedure that defines Key Performance Indicators (KPIs) to track and evaluate E&S performance. The company will include OHS-related metrics, such as leading and lagging indicators (e.g., incident records, near misses, hazard reporting, and other workplace monitoring data), KPIs covering resource use and efficiency (e.g., water and energy consumption), pollution prevention and control measures (e.g., effluent, solid waste, and hazardous waste management), and the E&S performance of suppliers and service providers. The monitoring procedure will also establish auditing protocols and specify the frequency of audits, as well as the KPIs to be reported regularly to the Board of Directors through an E&S performance dashboard (ESAP #1).
Supply Chain:
The company’s primary suppliers are local entrepreneurs who import mainly electronic equipment, such as refrigerators and mobile phones, as well as mattresses, shoes, clothing, household products, food, diapers, and perfumes. This supplier profile helps reduce the risk of child labor and forced labor within the supply chain. The company has developed a Code of Business Conduct and Ethics covering conflicts of interest, fair dealing, confidentiality, insider trading, protection of company assets, and reporting obligations. It also applies country-specific Know Your Customer (KYC) requirements, which include, at a minimum, company registration documents, government-issued identification for legal representatives, and tax identification information. Suppliers are required to sign and comply with these policies. The company will develop E&S clauses for inclusion in supplier contracts. These clauses will require suppliers to establish and implement E&S policies, comply with national regulations, respect human rights and workers’ rights, and ensure worker health and safety (ESAP #5).
As part of the ESMS (ESAP #1), the company will develop and communicate a standalone Supplier and Third-Party Service Provider Code of Conduct.
PS2: Labor and Working Condition:
Due to the nature of its operations, the Company engages three categories of workers: (a) direct employees hired under fixed-term or permanent employment contracts; (b) third-party workers engaged through service providers; and (c) independent contractors, including drivers and motorcycle riders. At the time of appraisal, the Company employed approximately 1,631 direct employees across its countries of operation, of whom about 35% were women. In addition, the Company engaged third-party workers through service providers, primarily for security and housekeeping services.
Human Resources Policy, Working Conditions, and Terms of Employment:
The Company has established human resources (HR) policies and a Code of Conduct for its direct employees. The HR Manual covers equal employment opportunities, diversity and inclusion, anti-harassment, pay periods, salary deductions, bonuses, grievance mechanisms, disciplinary measures, working hours, overtime, leave entitlements, recruitment and selection, probation, performance reviews, and termination procedures. Employees receive formal employment contracts that typically specify gross salary, probation period, working hours, overtime rates, holidays, and notice periods. The Company has also adopted an Anti-Bribery and Corruption Policy.
To align with IFC PS2 requirements, the Company will update its HR manual to include explicit provisions on the prevention of gender-based violence and sexual harassment (GBVSH), child labor, forced labor, freedom of association, and collective bargaining, and will raise employee awareness on these topics. The Company will also develop and implement a stand-alone Sexual Harassment Policy covering the definition of sexual harassment, disciplinary measures, reporting channels, investigation procedures, and survivor support. This policy will apply to drivers, third-party contractors, and all direct and indirect employees, and relevant provisions will be incorporated into their contracts. Awareness and training on the GBVSH Policy will be provided to all direct and indirect employees (ESAP #6). The Company requires all employees to work 40 hours per week in accordance with statutory requirements. Most employees follow standard office hours, working from 8:30 a.m. to 5:30 p.m. with a one-hour daily break, five days per week. Customer service teams work 40 hours per week across all countries, except in Kenya, where employees work 48 hours per week.
Non-Discrimination, Equal Opportunity, and Worker Grievance Mechanism:
Jumia’s HR policies include explicit provisions to ensure non-discrimination, equal opportunity, and fair treatment throughout recruitment and selection processes.
Grievance Mechanism:
The Company has a documented Whistleblower Policy that is accessible to all employees, including third-party workers. The policy covers violations of the Code of Business Conduct and Ethics, breaches of company policies and procedures, suspected legal violations, fraudulent activities, and questionable accounting practices. The Company also maintains confidential and anonymous reporting channels to support implementation of the policy. To align with IFC PS2 requirements, the Company will expand the Whistleblower Policy into a broader worker grievance mechanism covering discrimination, legal violations, misconduct, and GBVSH-related concerns. The mechanism will define roles and responsibilities for grievance intake and resolution, establish clear response timelines, and include a system to record, track, and report grievances and their resolution status. It will also identify appropriate psychosocial, medical, and legal support services for GBVSH-related complaints and establish a referral pathway. The grievance mechanism and referral pathway will be accessible to all workers, including casual workers. To support effective implementation, the Company will raise workforce awareness and communicate information about the grievance mechanism through online platforms and notice boards. Specialized training will also be provided to personnel responsible for handling GBVSH-related grievances (ESAP #7).
Management of Contractors (Drivers) and Third-Party Logistics (3PL) Workers:
Jumia’s drivers and motorcycle riders are engaged as independent contractors. They are responsible for collecting products from warehouses and collection hubs across the city and delivering them to customers. Drivers and motorcycle riders also collect cash on delivery when customers choose cash payments. At month-end, Jumia reconciles amounts due and deducts any applicable shortfalls from the upfront caution deposit. Their contractual arrangements with Jumia are non-exclusive.The Company has developed and implemented a Partner Code of Conduct covering business ethics and integrity, human rights and labor standards, health, safety and environmental requirements, and data privacy and information security.
Due to their status as independent contractors, the Company does not deduct income taxes or pension contributions on behalf of drivers and motorcycle riders and does not provide compensation for work-related injuries. Jumia will update its Partner Code of Conduct and contractual requirements to make these provisions mandatory for service providers that directly manage drivers and motorcycle riders. Service providers will be required to communicate and enforce drivers’ and motorcycle riders’ rights, responsibilities, and welfare standards and ensure fair, ethical, and transparent labor practices. These requirements will, at a minimum, address legal, contractual, and taxation obligations; fair remuneration arrangements, including measures to assess and mitigate the risk of drivers’ and motorcycle riders’ net earnings falling below applicable minimum wage or equivalent legal thresholds; grievance redress mechanisms; prevention and monitoring of labor unrest or other labor actions; and the prohibition of child and forced labor, including age verification measures to prevent the engagement of underage drivers and motorcycle riders.
The update will also cover whistleblowing; climate change considerations; health and safety, including the respective responsibilities of Jumia, service providers, drivers, and motorcycle riders; general occupational health and safety (OHS) requirements; road safety and prevention of road traffic accidents; exposure to violence, theft, and harassment; weather exposure and fatigue management; access to emergency care and insurance coverage for work-related injuries; prohibition of illicit substance use; GBVSH prevention; child safeguarding; and limits on maximum driving hours and mandatory rest periods. To monitor compliance, Jumia will establish relevant KPIs and targets, conduct regular audits of service providers and their labor management practices, and require annual monitoring reports covering relevant E&S matters, including accidents, theft, violence, harassment, and other incidents.
Legal registration and taxation requirements applicable to drivers and motorcycle riders will also be reflected in the relevant contracts, reinforcing accountability and compliance with applicable regulatory requirements (ESAP #8).
Prior to onboarding third-party logistics providers (3PLs), the Company conducts due diligence and compliance reviews to verify alignment with applicable legal requirements in each country of operation.
Depending on the type of activity, including First Mile Hub, Middle Mile, or Last Mile services, 3PLs are required to submit relevant legal and operational documentation, such as courier licenses, rider permits, Class A driver's licenses, national identification cards, voter cards, driver's licenses, or passports, as applicable. The Company reviews and verifies these documents before authorizing any 3PL to commence operations. Contractual agreements are executed with clearly defined payment terms and conditions. The onboarding process includes contract issuance, contract execution, onboarding, and induction.
Due to the nature of their work, Jumia drivers and motorcycle riders frequently interact with customers, platform users, and members of the public, increasing the risk of GBVSH incidents. As part of its emergency response measures, Jumia will provide drivers and motorcycle riders with appropriate tools to monitor situations and request support during emergency incidents (ESAP #7). Jumia will also establish partnerships with service providers to offer psychosocial, medical, and legal support to third-party contractors (drivers, motorcycle riders, and contracted workers), particularly following incidents involving harassment, assault, or GBV (ESAP #9).
Jumia engages third-party workers through service providers, primarily for cleaning and security services. The Company's policies on OHS, child labor, and business ethics are communicated to contractor workers through induction training and are incorporated into contractual agreements with third-party service providers. As part of the ESMS (ESAP #1), the Company will strengthen oversight of contractors through regular E&S compliance audits and the implementation of a stand-alone Supplier and Third-Party Service Provider Code of Conduct.
Occupational Health and Safety:
The Company has recently developed a site-specific incident reporting procedure for Cote d’Ivoire. The procedure begins with notification of the on-site nurse, who coordinates the response until an ambulance arrives, where necessary. Each warehouse is equipped with an on-site clinic. As part of the ESMS (ESAP #1), the Company will develop an Occupational Health and Safety (OHS) Policy that reflects its commitment to providing a safe working environment and protecting the health, safety, and welfare of employees, contractors, drivers, visitors, and members of the public who may be affected by its operations. The Company will also develop a corporate incident management and reporting framework to track work-related injuries, illnesses, and fatalities; identify OHS trends; record significant damage to property, equipment, or materials; assess potential environmental impacts; and address incidents involving drivers, contractors, passengers, and members of the public. In addition, OHS risk management will be incorporated into induction training for all direct employees, drivers, and third-party workers, reinforcing the Company's proactive approach to workplace health and safety.
PS3: Resource Efficiency and Pollution Prevention:
The primary energy sources used at the company’s offices are grid electricity and diesel fuel for transportation and backup power generation. Project-related greenhouse gas (GHG) emissions are estimated to remain below 25,000 tons of CO2 equivalent per year. In line with its commitment to reducing environmental impacts, the company has also initiated the installation of solar panels in selected countries. As part of the Environmental and Social Management System (ESMS), the Company will establish monitoring systems and key performance indicators (KPIs) to track resource consumption across its operations (ref. ESAP #1).
Pollution Prevention:
The company’s offices use bottled drinking water and municipal tap water for non-potable purposes. Office activities generate only sanitary wastewater, which is disposed of through on-site septic tanks. Under normal operating conditions, the offices do not generate significant air emissions or noise, except for occasional emissions from backup generators during power outages. In addition, vehicles used for company operations may contribute to localized air and noise emissions. The Company will formalize pollution prevention procedures and implement monitoring systems through its ESMS (ref. ESAP #1).
Solid Waste and Hazardous Materials Management:
The company’s offices generate limited quantities of solid waste, primarily from routine office and kitchen activities. Waste oil generated during generator maintenance is collected and disposed of by licensed service providers. Maintenance activities and oil changes for vehicles operated by independent drivers are performed directly by the respective contractors, who are responsible for managing any associated waste generated from these activities.
PS4: Community Health, Safety and Security:
Road safety:
The company will undertake an operational risk assessment for each country of operation, taking into consideration factors such as working hours, live tracking data, complaints, accident history, and climate change impacts. Based on this assessment, the company will develop and implement tools to effectively address the identified risks, including driver alerts for high-risk areas (e.g., flood-prone zones). To prevent fires and minimize the risk of accidents, the company will require drivers to ensure proper vehicle maintenance and conduct routine safety checks. In addition, the company will develop a road safety program that includes online defensive driving training for all drivers, incentives for timely accident reporting, and accident investigation procedures (ESAP #10).
Community-Based Gender-Based Violence
Due to the nature of their work, drivers frequently interact with community members, including users of the company’s platform and individuals along transportation routes, which increases the risk of gender-based violence and sexual harassment (GBVSH). To address this risk, Jumia will establish a Driver Code of Conduct that clearly defines prohibited behaviors, including violence, harassment, and verbal abuse. Jumia will also require its service providers to develop and implement an alert system that enables drivers and motorcycle riders to report and manage GBVSH-related incidents (ESAP #8).
Use of Security Forces
The company employs one to two security guards per shift at each site through a third-party security service provider. At each site and during each shift, one security guard is armed. Going forward, the company will develop and implement a Security Management and Monitoring Plan aligned with the requirements of IFC Performance Standard 4 (PS4) and the Voluntary Principles on Security and Human Rights. The plan will include contractual requirements for guard selection, rules of engagement (including the use of minimum force), training, equipment, facilities, working conditions, and grievance management, all of which will be incorporated into service provider contracts (ESAP #11).
