Lionpro Group

SIA “L.J. Linen” of Latvia (LJL) is seeking MIGA coverage for Transfer Restriction and Inconvertibility (TR), Expropriation (EXP), and War and Civil Disturbance (WCD) for its investment into Lionpro (K) Limited (LPK), the Project Enterprise (PE) in Kenya for a duration of up to 10 years. Further information on the proposed MIGA guarantee is available in the Summary of Proposed Guarantee.

LPK, a related company to LJL and part of the LionPro Group (LionPro), is a trading company focused on the African region, with operational activities based in Kenya. While LPK is responsible for the local execution of operations such as importation, warehousing, sales to local customers, product mixing, re-bagging, quality testing, and potentially sourcing new local products, LJL retains full operational oversight. As the central sourcing entity, LJL manages supplier relationships, sources animal protein products (including blood meal, fish meal, feather meal, and poultry meal) primarily from the European Union (EU), and conducts pre-shipment risk assessments, testing, and post-arrival claims handling and investigations. LJL also provides strategic direction to LPK and is actively working to diversify its portfolio by adding vegetable proteins (e.g., soybean, sunflower, maize). The investment covered by a MIGA guarantee will support LPK’s current operations and planned expansion (the Project). For purposes of this ESRS, LJL, LionPro, and LPK are collectively referred to as the “Company”.

The Company works with a third-party logistical contractor in Kenya - Mitchell Cotts Freight Kenya Ltd (Mitchell Cotts) since 2021, responsible for performing the operation functions: mixing of animal feed, re-bagging, storing and distribution to end customers. Activities are currently centralized in Nairobi in warehouse spaces owned or rented by Mitchell Cotts. The Company plans to expand its operations and is aiming to increase its inventories of existing animal protein products and other vegetable meals. The Company’s end consumers are the feed millers and farmers. The Company supports feed millers and farmers with planning and forecasting, education and training. The Company prepares custom mixing of the protein feeds based on agreed recipes to enhance feed quality and nutritional benefits. 

The expansion plans involve sourcing animal and vegetable protein from within and outside Kenya, opening new warehouses, showrooms/stores in different locations within Kenya operated by third parties, diversifying the product range (add vegetable protein), introducing new planning systems (potential IT development), and purchasing equipment for product mixing, bagging, packaging, sorting, and storing. The Company plans to open a showroom/store in Thika, and Nakuru, followed by Mombasa, Kisumu, Eldoret, and Meru. 

The Project is Category B under MIGA’s Policy on Environmental and Social Sustainability (2013). The Project is expected to have potentially limited adverse Environmental and Social (E&S) risks and impacts, which will be few, site-specific, largely reversible, and readily addressed through mitigation measures. Key E&S risks and impacts include the Company’s capacity to develop and implement an Environmental and Social Management System (ESMS) to manage and oversee E&S risks and impacts associated with the Project, including supply chain and contractor management. Other E&S risks include labor and working conditions (including workers occupational health and safety, grievance redressal mechanism), emergency preparedness and response community health and safety. 

While all Performance Standards (PSs) are applicable to this Project, based on available current information, the Project will have impacts which must be managed in a manner consistent with the following PSs:

• PS1: Assessment and Management of Environmental and Social Risks and Impacts
• PS2: Labor and Working Conditions
• PS3: Resource Efficiency and Pollution Prevention
• PS4: Community Health, Safety and Security

The existing warehouse is operational and is located on the outskirts of Nairobi. The three new warehouse locations are yet to be confirmed but the preference is to rent or acquire existing warehouses. In the event that a new build is required, the land will be acquired through a voluntary transaction, on a willing buyer-willing seller or willing renter basis, in addition, the preference is for the warehouse location to be in busy areas where there is high traffic volume. Hence, the following PSs are not triggered for the Project - PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples; and PS8: Cultural Heritage.

In addition, the following World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines are applicable to the Project:

• General EHS Guidelines (2007)
• Poultry Processing (2007)
• Meat Processing (2007)

The following key documents were reviewed by MIGA:

• LionPro, Environmental and Social Policy, April, 2025;
• LionPro, Work Safety and Health Policy April, 2025;
• LionPro, Work Safety and Health Instructions, April, 2025;
• LionPro, Human Resources Policy, April, 2025;
• LionPro, Good Manufacturing Practices certification (GMP+)  record (valid till April 2027);
• LionPro, Sample employment contract for direct employees, July, 2024
• LionPro, Group Partner onboarding process, January, 2024;
• LionPro, Group Sales Team Code of Conduct [undated];
• Mitchell Cots: Environmental and Social Management System (ESMS) (July, 2024)
• Mitchell Cotts: Fire Safety Section from Quality Health, Safety and Environment Manual, July, 2024
• Mitchell Cotts, Emergency Preparedness and Response Procedures – Warehouse Operations [undated];

In addition to reviewing the aforementioned documents, MIGA’s E&S due diligence included a site visit to the operational warehouse in Nairobi in February 2025, meetings with key management staff from the Company as well as meetings with Mitchell Cotts representatives and meetings with the Directorate of Veterinary Sciences (DVS) of Kenya.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS.  Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System: The Company has in place a certified feed safety management system that includes hazard analysis and risk management, traceability and documentation, feed safety monitoring, transport and storage conditions, supplier evaluation, crisis management and training and competence. The Company relies on Mitchell Cotts to manage E&S risks and impacts of the activities. Mitchell Cotts has an Environmental and Social Management System (ESMS) in place in line with PS 1 requirements and documented in an ESMS manual. The ESMS is supported by E&S risk assessment tools and operationalized through management plans and standard operating procedures. The implementation of the ESMS is the responsibility of Mitchell Cotts’s Quality, Health, Safety and Environment (QHSE) department. 

The Company will develop and implement a fit for purpose ESMS which will include among others: (i) risk and impact register, (ii) management plans and procedures to address the identified risks (iii) monitoring and reporting (ESAP #1). Where possible, The Company will review and assess potential areas of integration between the feed safety management system and the ESMS to streamline risk management, avoid duplication and have a unified approach to managing feed safety, environmental and social protection.

Policy: The Company has an E&S Policy applicable to all its subsidiaries which articulates its E&S commitments. As part of the ESMS development, The Company will revise, update and roll out the E&S policy (ESAP #1).

Identification of Risks and Impacts: The Company’s feed safety management system includes a hazard analysis that follows the Hazard Analysis and Critical Control Points (HACCP) that aims to identify potential hazards and establish controls at critical points in the feed handling process. The ESMS to be developed will include: (i) a risk identification process to identify potential E&S risks and impacts across its activities including site selection of new warehouse / storefront locations (ESAP #1). 

Management Program: The ESMS to be developed by The Company will include management plan templates to support the operationalization of the ESMS (ESAP #2).  Mitchell Cotts ESMS is supported by management plans and procedures to mitigate identified risks, including emergency preparedness and response, waste management, emissions control, labor conditions among others.

In relation to contractor management, the ESMS will include E&S contractor selection and management procedure that includes E&S screening and evaluation for selecting third-party contractors or service providers and regular monitoring of its contractors (ESAP #2). In addition, The Company will revise and update its legal agreement template to include E&S provisions, including the right to terminate contracts with third parties that fail to meet The Company’s E&S requirements (ESAP #3).

Organizational Capacity and Competency: The E&S functions are supervised by The Company’s Chief Executive Officer (CEO), as well as the regional, and country heads of sales. Mitchell Cotts organizational structure includes a HSEQ Manager and Environmental, Health, Safety (HSE) officers. The HSE officer oversees among others the activities at the existing warehouse. The Company will designate or hire an E&S resource, responsible for the development and implementation of the ESMS (ESAP #4).

Emergency Preparedness and Response: Mitchell Cotts has an Emergency Preparedness and Response Procedure that applies to the Company’s warehouses. This procedure addresses various types of emergencies, including fire or explosion, chemical spill or gas leak, medical emergencies, natural disasters, security threats, electrical failures, releases of hazardous energy, and structural collapse. The Company will develop an Emergency Preparedness and Response Plan as part of the ESMS in line with PS 1 requirements (ESAP #2).

Monitor and Review: The Company holds a Good Manufacturing Practices (GMP+) certification a recognized Feed Safety and Quality Assurance standard for trade in feed, valid until April 2027. Certified auditors conduct certification audits for companies seeking to maintain the GMP+ certification carried out by accredited, independent certification bodies annually. As part of its ESMS, The Company will establish a monitoring plan that details monitoring and control for each identified E&S risk (ESAP #2). 

Stakeholder Engagement, External Communication, and Ongoing Reporting to Affected Communities: As part of the ESMS, The Company will develop a stakeholder engagement plan (SEP) that outlines information sharing and feedback process in line with PS 1 requirements (ESAP #2), including the dissemination of information about disease prevention, collaboration with the DVS on medical tests, and informing affected communities about disease risks and prevention measures.

Grievance Mechanisms: The Company will develop a Grievance Redress Mechanism plan as part of its ESMS  reflecting the following: (i) grievance submission channels (email, complaint box, web form or online portal, verbal submission and confidentiality options stated; (ii) acknowledgement of receipt; (iii) designated focal point or committee responsible for receiving and logging complaints, investigating and coordinating response, communicating outcomes; (iv) resolution and process and timelines; (v) communication of outcome; (vi) appeal or escalation option; and (vii) documentation and record keeping (ESAP #2). Mitchell Cotts has a grievance mechanism available to all stakeholders, that among others, covers LPK’s activities. Grievances can be submitted via various channels and recorded in a grievance log.

PS2: Labor and Working Conditions 

LPK currently employs a total of eight personnel—comprising direct employees and contractor workforce,—primarily based at the Nairobi warehouse. 

Human Resources (HR) Policy: The Company has a high-level HR policy outlining key commitments on workforce management and labor practices, broadly aligned with PS 2 requirements. The HR policy will be updated to include terms of workers’ organization and participation, prohibition of child and forced labor, gender-based violence (GBV) and sexual harassment, as well as communication strategies to inform all workers about their rights and responsibilities (ESAP #5). 

Working Conditions and Terms of Reference: The Company’s employee agreements define key employment terms, including roles and responsibilities, working hours, compensation, benefits, leave entitlements, and disciplinary procedures. 

Grievance Mechanism: The Company’s HR policy includes a grievance redressal process, which will be updated to include: (i) scope; (ii) step-by-step process (raise a grievance, acknowledgement, resolution, communication of outcome, appeal); (iii) record keeping; (iv) communication and awareness and (v) non-retaliation (ESAP #6). The GRM will be made available to all workers (permanent and sub-contracted).

Occupational Health and Safety (OHS): Key OHS risks of handling animal protein feed include: (i) biological risk due to pathogens if the animal feed is not properly rendered (heat-based treatment) by the producers; (ii) dust exposure due to fine particles of the feed which may cause respiratory irritation, skin and eye irritation; (iii) manual handling and ergonomics. The Company conducted a risk assessment that identified the following key hazards electrical risks, manual lifting, and potential mechanical injuries. Workers operating the mixing unit will be Mitchell Cotts personnel, operating under Mitchell Cotts’ safety procedures. The Company will develop an OHS management plan that considers key OHS risks and control measures for the handling of animal feed including personal protective equipment (PPE), safe handling, training and use of the new machinery (ESAP #2).

Workers Engaged by Third Parties: The Company partners with service providers (Mitchell Cotts) to manage logistics operations, including transportation from the port to the warehouse and on-site warehousing services.  The Company will develop and implement an HR checklist and conduct regular monitoring of third-party contractors (recruiting workers for LPK’s operations) HR practices to verify alignment with the Company’s HR policy, host country regulations, and PS 2 requirements (ESAP #7). 

Supply Chain: The Company is responsible for procurement, which includes, among others, sourcing products from third-party animal feed ingredient producers. The Company has in place a procurement procedure and supplier assessment procedure that covers the supplier evaluation, selection, monitoring of performance and periodic review of supplier. The supplier assessment will incorporate a review of (i) OHS performance and (ii) labor requirements (i.e. minimum age of employment, no forced labor) (ESAP #8).

PS3: Resource Efficiency and Pollution Prevention 

The transportation and warehouse activities are expected to generate minor air, dust, water and soil pollution. Potential nuisance impacts related to the broader community are expected to be limited. Impacts will be mitigated by standard pollution prevention and control measures described in Mitchell Cotts’ ESMS.

Wastes: Animal protein feed waste is not hazardous, but it may pose biosecurity, odor, pest, and environmental risks if mismanaged. The Company will develop a waste management procedure as part of its ESMS that includes among others, waste identification (spillage, expired feed, contaminated /damaged); response and cleaning; disposal options based on host country regulations and roles and responsibilities (ESAP #2). 

PS4: Community Health, Safety and Security

Community Exposure to Disease: Potential risks to community health and safety associated with the Project include the possible spread of diseases such as Bovine Spongiform Encephalopathy (BSE, commonly known as mad cow disease), avian influenza, and others if the produce is not properly rendered. The animal protein feed imported by the Company undergoes a rendering process guided by veterinary principles to prevent the spread of animal diseases and zoonoses, in compliance with EU standards  (the animal protein feed is screened by the European Food Safety Authority whose requirements are aligned with the World Organization for Animal Health (WHOA) standards on feed safety) and/ or Feed Safety and Quality Assurance standard. Parts of cattle that theoretically may BSE are separated into special risk material that cannot pass into the food chain according to regulation (EC) 1069/2009. In addition, all special risk material is also tested for BSE. LPK adheres to Kenyan regulations overseen by the Directorate of Veterinary Services to import animal feed. Prior to shipment, animal protein is tested by third-party laboratories in the country of origin checking on safety and quality. 

The Company’s feed safety management system includes feed safety procedures that describe safe handling, storage and monitoring of animal feed. The Company will maintain certification under a recognized Feed Safety and Quality Assurance standard and maintain compliance as part of its feed safety management system.

Security Personnel: Mitchell Cotts provides security for the warehouse and ensures the personnel are regularly trained and screens the security firm's background before contracting.  

Broad Community Support is not applicable for this Project.

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org. 

• Environmental and Social Action Plan

   

For additional information, please contact: 

• Contact Name: Ivanda Leja

• Address: Antonijas street 5, Riga

  • E-mail: Ivanda.leja@lionpro.com

MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org