Policy

Greenback has adopted overarching corporate-level policies. Greenback Mexico has also adopted a suite of E&S policies compliant with corporate-level E&S policies and national law.

Management Programs

Greenback Mexico identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory requirements. As part of the project, Greenback Mexico will establish the ESMS compliant with the applicable national law and standards and the requirements of IFC PSs, WBG General EHS guidelines (ESAP #1). The ESMS, as a minimum, will define the roles and responsibilities of its implementation and will include (i) an E&S and Occupational Health and Safety (OHS) policy aligned with IFC PSs; (ii) procedures for screening and assessing environmental health, safety, and social risks and impacts of the project in operation and new projects; (iii) criteria for site screening and alternative analysis criteria for environmental and social aspects; (iv) a Stakeholder Engagement Plan, including a community grievance mechanism; (v) establishing an ESMS organization structure; (vi) developing and implementing a worker health and safety management and occupational risk mitigation procedures; (vii) preparing an emergency preparedness and response plan (for current and new projects); (vii) monitoring of E&S and OHS performance; and (ix) internal and external audit requirements.

Greenback Mexico will, as part of the ESAP #3, develop a suite of site-specific operational E&S management plans (CESMPs) following the national law and standards, WBG General EHS guidelines (2007), the EIA, and WBG EHS Guidelines for Waste Management Facilities (2007).

Identification of Risks and Impacts

In March 2023, Greenback Mexico commissioned an Environmental Impact Assessment for the Pilot project in Cuautla, Mexico, following national law and standards. The EIA includes a generic construction of an E&S management plan aligned with the national law and standards. The EIA has been approved by the national authority and the related environmental permit was obtained. Greenback Mexico will augment the EIA for the Pilot Project, considering the third microwave-induced pyrolysis module, in line with the national law, the requirements of IFC PSs, and WBG EHS Guidelines for Waste Management Facilities (2007) (ESAP #2).

As part of Greenback’s ESMS, an Environmental and Social Management Plan (ESMP) will be prepared for the construction (CESMPs) of new facilities and Operation (OESMPs) of current facilities to ensure implementation of the ESIA (MIA and EVIS), licenses commitments and compliance with IFC requirements (ESAP #3).

Organizational Structure and Competency

At the Greenback Mexico plant, the E&S activities are led by the CEO and supported by the team in the plant.

Greenback Mexico will establish an organization with the active involvement and support of the top management and Greenback office in the UK and will ensure that sufficient staff and contractor resources are allocated to E&S management. Greenback will appoint, at a minimum, an EHS Manager with experience in ESMS development and implementation. Greenback Mexico will establish its operations-relevant E&S organizational structures, with clearly defined roles and responsibilities (ESAP #4).

Monitoring and Review

As part of the ESMS, Greenback will develop procedures for monitoring and reporting the key E&S performance indicators for its portfolio, including, among others, air emissions, noise levels, safety performance, and community relations and complaints.

Emergency Preparedness and Response (EPRP)

Greenback Mexico has developed the Civil Protection Plan. Greenback will prepare an EPRP (ESAP #1) as a general framework to be implemented for the new facilities as part of the ESMS. The EPRP will follow national law and standards, international best practices, and the requirements of the IFC PS1, PS4, and WBG General EHS guidelines (2007).

Human Resources Policy and Procedures

Greenback Mexico Cuautla plant employs 18 direct workers, including operators and administrative staff (65% male—35% female), working 12-hour shifts and a 4x3 scheme.

Greenback has an Employee Handbook that establishes the duties and rights of Greenback employees and a health and safety policy. Health and Safety Policies and a grievance mechanism have been developed for Greenback Mexico following national law. Specifically, Greenback has documented restricting child labor and an internal grievance mechanism in its policies. As part of the project, Greenback will adopt and implement human resources (HR) policies and procedures in accordance with national law and the requirements of IFC PS2 (ESAP #5).

Working Conditions and Terms of Employment

As part of the HR policies and procedures, Greenback will document workers’ terms and conditions of employment and communicate them at the time of employment concerning workers' entitlement to wages, hours of work, overtime arrangements and compensation, any benefits such as leave for illness, maternity/paternity or holiday, and the grievance mechanism for workers. It will also ensure that all workers have a copy of their contracts.

Grievance Mechanism

As part of the HT policies and procedures, a grievance mechanism for workers will allow employees to raise workplace concerns and address all complaints received, including managing anonymous complaints. Workers will be informed about channels for raising grievances, and the grievance mechanism will be extended to contractor and subcontractor workers.

Occupational Health and Safety

Greenback Mexico will prepare and implement an Occupational Health and Safety Management Plan (OHSMP) for its operation by national law, WBG General EHS Guidelines (2007) and WBG EHS Guidelines for Waste Management Facilities (2007) (ESAP #3). The OHSMP will include detailed procedures for hazard identification and risk assessment; job and task-specific hazard analyses, provision and use of personal protective equipment (PPE); training; safe working procedures; prevention, reporting, recording, investigation, analysis of accidents and incidents, and follow up corrective actions; emergency response; first aid and provision of medical treatment; workplace and health monitoring; measures for prevention of disease spread; fire prevention and fighting system; inspections and audits; performance reporting; and management review. As part of the OHSMP, the company will assess the potential migration of landfill gas (methane) and establish a monitoring, alarm, and mitigation measures in line with the national fire safety codes and WBG General EHS Guidelines (2007).

Supply Chain Management

Greenback Mexico is planning to source waste only from licensed landfill operators. As mentioned previously for the Cuautla plant, the feedstock is separated at the landfill using a semi-automatic separation technology. For this separation process, manpower is used by the landfill operator. Therefore, as part of ESAP #6, Greenback Mexico will establish a supply chain management system aligned with PS2 requirements. The Company will adopt a supplier code of conduct (COC) that includes prohibiting child and forced labor practices and OHS requirements and integrate it into the legal agreements with landfill operators. The Company will establish a system of comprehensive supplier screening and performance audit checklists against the supplier COC.

Greenback developed a module-type plant to transform plastic waste into pyrolysis oil and gas and recover aluminum from the waste feedstock sourced from landfills using microwave-induced pyrolysis. The recycling module installed in Cuautla, Mexico, has a capacity of approximately 2,250 tons p.a. of dried plastic waste being transformed into approximately 1,500 tons of pyrolysis oil, and 47 tons of aluminum with savings of up to 142 kg of CO2 emissions, 26m3 of water and 376 kg of oil-equivalent per ton of consumer laminates compared to other end-of-life options.

Air Emissions

The standard plant is designed with modules that meet the European Union's Industrial Emissions, and the microwave-induced pyrolysis process is powered by electricity; therefore, no emissions are to be generated from the heating process. The pyrolysis gas produced from the transformation of the plastic is condensed to pyrolytic oil; however, there is a remnant of pyrolysis gas that is non-condensable and can be used for power generation. Currently, the Cuautla plant has not installed a power generation system using surplus pyrolysis gas. In this sense, a Condition Precedent prior to the first subscription is proof of purchase of a system that will generate electricity solely using pyrolysis gas as delivered and demonstrated use of a system installed to generate electricity from the module in Cuautla. The flare stack will only remain for safety reasons.

Wastewater

The project will not generate process water and a septic system will be constructed for sanitary purposes, built to collect sanitary wastewater.

Noise

Equipment, such as the crusher, will generate noise during the pilot plant's operation. As per the EIA, the Pilot Project's operation at the landfill area will comply with the ambient noise national limits (NOM-081-SEMARNAT-1994 for industrial zones of 65 - 68 dbA).

Waste Management

The plant will generate non-hazardous and industrial waste that will be collected, transported, and sent to the landfill. For this purpose, specific containers will be placed in the project area for each type of waste. Hazardous waste will be stored, handled, and transported according to national law.

The operation of the pilot project will generate 400 kg of activated carbon per month (coconut activated carbon); For the final disposal, a specialized and licensed company will be contracted for managing the removal of this waste stream.

Since the Greenback Mexico plant is located within an existing landfill area, no significant additional impacts on the health, safety, and security of the local community are expected.

Transport Management

Once the pyrolytic oil is produced, it will be collected and transported in tanker trucks – approximately one truck per day in the full operation stage – and will be directed to potential clients interested in chemical manufacturing, including plastic regeneration. Hence, Greenback Mexico will develop a Traffic Management Plan as part of OESMPs, including risk assessment and management, vehicle, driver, and journey-related practices, and a checklist assessment for road transport monitoring (ESAP #1).

Life and Fire Safety

Greenback Mexico has integrated fire safety measures in the design of the Cuautla facility in accordance with national building and fire safety codes. The company will establish raw material storage with a life and fire safety system, installed in line with the national fire safety codes, and only keep the minimum amount of raw material PET bales outdoors for immediate processing. Raw material PET bales will be covered by roof/sheet to prevent exposure to rain and sunlight and stored in locations nearest to the fire hydrant. The installed passive and active fire safety systems will be audited and certified by a third-party fire safety professional.