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West Bank and Gaza

Nakheel Palestine for Agricultural Investment

$16.61 million
Agribusiness
Environmental and Social Review Summary
Proposed

Environmental and Social Review Summary

Nakheel Palestine for Agricultural Investment in West Bank and Gaza

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.

Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.

MIGA has been asked by Palestine Development and Investment Company (“PADICO Holding”) and Siraj Palestine Fund I, Ltd (“Siraj”) to modify the guarantees issued to The Palestinian Recycling Company (“TPRC”) and Siraj Palestine Fund I, Ltd. (“Siraj”) for their investment into Nakheel Palestine for Agricultural Investment (“Nakheel” or the “Project Enterprise”) in West Bank and Gaza (the “Host Country”) due to changes in the project structure, scope of the investment, increase in the guaranteed investment, and renewal of the guarantee period. The original Contracts of Guarantee (CoGs) were issued by MIGA on September 29, 2011 to Al Mashreq Real Estate Company, Palestine Industrial Estate Development Company, and TPRC, for their equity investments in Nakheel (the Project).

The Project involves harvesting, processing and sorting dates and seedlings and consists of the expansion from two Medjool date palm farms, approximately 193 hectares in Jericho, in the West Bank acquired in 2011 to eight farms in 2021 spanning in total approximately 380.6 hectares. Nakheel initially relied on agreements with other companies to package and store the dates; however, in 2014, acquired its own packaging facility.

The scope of the Project supported by MIGA’s guarantees includes: (i) Nakheel’s 8 farms (the two farms, Husseini and Mashroo’ Inshai, which were supported by MIGA in 2011 and an additional 6 farms acquired from 2011 to 2021), in total planted with more than 42,000 date palms; (ii) rooftop solar power plant on top of packaging and sorting/ grading facility that covers 20% of Nakheel’s electricity needs; (iii)  packaging facility that serves post-harvest handling of dates including services related washing, drying, disinfestation, grading, and packing of dates; (iv) sorting and grading house that can process 20 metric tons (MT) of dates per day; and (v) cold storage facility (at -18 degrees Celsius) with a storage capacity of 2,800 MT. Packaging facility, sorting and grading house, cold storage facility and the rooftop solar plant comprise one industrial facility. All farms and Project facilities are located near the city of Jericho in West Bank and Gaza’.

All farms are leased from private individuals or the Ministry of Waqf (a religious endowment) and Religious Affairs of the Palestinian Authority. The table below provides a summary of the farms.

Land name

Size in dunums[1]

Number of trees

Year added

Lease term ends in

Husseini Farms2

1,000

9,422

2010

June 2035

Mashroo’ Inshai Farms[2]

935

12,191

2010

June 2035

Farm 124

123

1,535

2011

October 2036

Farm 95

90

1,147

2011

October 2036

Farm 890

200

858

2012

July 2037

Faisal Farm

120

821

2012

February 2032

Sultan 1 Farms

532

6,657

2017

April 2030

Sultan 2 Farms

806

9,697

2017

August 2034

Typical activities at the farms include removing palm thorns and applying hand pollination (Jan- March), bunch arching and thinning to increase air circulation and placing offshoots to nurseries (March – May), tying and securing bunches to trees, removing excess limbs and putting rings in bunch centers (June -July), harvesting (August- September) and clean-up (October- December).

Sorting of dates and packaging process is manually intensive and includes: (i) sorting of dates on six automatic conveyor belts, (ii) drying or humidification to reach the desired humidity ratio, (iii) dates washing in the automatic line with humid soft brushes and air dryer, (iv) automatic grading scaling and packaging, (v) preparation of pallets in line with the quality standards (GlobalG.A.P.TM (Good Agricultural Practices) and ISO Food Safety System Certification (FSSC) 22000: 2018) and (vi) shipping locally to Palestinian retailers or abroad (Italy, Norway, Turkey, Indonesia, Malaysia, Qatar, Lebanon). The sorting and packaging facility only receive the dates from farms owned and operated by Nakheel; dates are currently not sourced from other growers in the region.

In 2021, Nakheel commissioned a rooftop solar plant consisting of 1299 mono- facial modules with an overall capacity of 580 kilowatt-peak (kWp) comprised of two different module types based on individual capacity- 445 watt-peak (Wp) and 465 Wp. The plant was constructed by the SunEnergy, a local Engineering Procurement and Construction (EPC) contractor. The same company now provides the Operations and Maintenance (O&M) service. This includes operator services, module cleaning, preventative and corrective maintenance and parts replacement.

 

1] 1 dunum is 0.1 hectare 
[2] Husseini and Mashroo’ Inshai farms were a part of the original MIGA cover

This project is category B under MIGA's Environmental and Social Sustainability Policy (2013) as it has impacts which are largely reversible and readily addressed through mitigation measures. The key potential environmental and social risks related to the Project include stress on water resources; pest management; crop residues and other solid waste pollution; workers health and safety; community health and safety; and Nakheel’s capacity and commitment to implement the Environmental and Social Management System (ESMS).

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

  • 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
  • PS7: Indigenous Peoples

The land plots for each farm and the plant are leased from different individuals and the Ministry of Waqf (a religious endowment) and Religious Affairs of the Palestinian Authority under willing lessor- willing lessee agreements. The Project did not result in any physical or economic resettlement. Thus, PS5 Land Acquisition and Involuntary Resettlement does not apply.

The Project sites are located on heavily modified agricultural land and there are no significant impacts related to biodiversity, thus PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply.

No sites of cultural / historical value were identified within the boundaries of the Project area, neither were any resources of heritage value identified. Therefore, PS 8 Cultural Heritage does not apply. Nevertheless, the Project has developed a Chance Find Procedure (Jan 2019) in line with the requirements of PS 8.

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

  • General EHS Guidelines (2007)
  • Food and Beverage Processing (2007)
  • Annual Crop production (2016)

The following key documents were reviewed by MIGA:

  • Nakheel Palestine Environmental and Social Management System (ESMS) documentation including:
    • Quality and Food Safety Policy (2012)
    • Environmental Planning Manual (2013)
    • Environmental Risk Register (2015)
    • Strategic Framework for Stakeholder Engagement (Dec 2020)
    • Grievance Mechanism Policy (Jan 2018)
    • Emergency and Preparedness Procedure (2012)
  • Nakheel Palestine Human Resources (HR) documentation including:
    • Equality and Diversity Policy (Jun 2020)
    • Environmental and Social Performance Grievance Mechanism (2018)
    • General Safety Checklist Forms (2020-2021)
    • General Safety Procedure (Jan 2012)
  • Due Diligence Report. Nakheel Palestine Environmental and Social Assessment. IBIS Environmental Social Governance Consulting South Africa Pty (IBIS, Aug 2016)
  • External Environmental and Social Due Diligence Report. (Universal Group for Engineering and Consulting, Nov 2016)
  • Nakheel Palestine Social and Environmental Management Annual Report 2014
  • Nakheel Project Environmental Assessment Report prepared for MIGA (Jan 2011)
  • Nakheel Palestine Annual Monitoring Reports (AMRs) to MIGA (2018, 2020, 2021)

 

MIGA E&S team conducted a monitoring site visit on the Project in April 2019. At the time MIGA visited two farms, the processing and sorting facilities and the cold storage area. In addition, MIGA conducted a virtual site visit in January 2022 that included all facilities under the new cover. In addition to reviewing project documentation, MIGA conducted a series of interviews with Nakheel staff.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS as Annex 1. Through the implementation of these measures, the Project is expected to be 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

Nakheel has developed a Quality Management System (QMS) for Food Safety Management which is certified against the International Standards such as GlobalG.A.P.TM (Good Agricultural Practices, issued on 4th Jan 2021 and valid until 27th Nov 2021) and ISO Food Safety System Certification (FSSC) 22000: 2018 (last issued on 7th Mar 2022 and expires on 23rd Feb 2025).  GlobalG.A.P recertification is currently in progress. In addition, Nakheel is in the process of pursuing GlobalG.A.P Risk Assessment on Social Practice (GRASP) certification. The certification is designed to complement the Project’s existing GLOBALG.A.P certification with specific aspects of workers’ health, safety and welfare.

 

Nakheel has also developed and is implementing an Environmental & Social Management System (ESMS). ESMS documentation consists of procedures such as Waste Disposal Procedure, Emergency Procedure, General Safety Procedure, Pest and Insect Control, Training Procedures, Health and Safety (H&S) Hazard Identification Procedure, General Safety on Farm Instructions, Incidents Report, First Aid Procedures and Electricity Hazards Procedures. As per the ESAP, the ESMS will be updated to include E&S Policy, Stakeholder Engagement Plan, Supply Chain Policy and Security Procedure. More details on each item are provided in the paragraphs below.

 

Policy

 

As a part of the QMS Nakheel has established a Quality and Food Safety Policy (2012). Nakheel will update the policy to specifically define the environmental and social objectives and principles, outline the framework for environmental and social assessment and management process, describe responsibilities for managing E&S aspects and manifest management commitment in terms of E&S. The policy will be communicated to all levels within Nakheel by means of displaying the document at the Project sites and conducting a refresher training for all employees (as per the ESAP).  

Identification of Risks and Impacts

The Palestinian Environmental Assessment Policy (PEAP, 2000) does not require Environmental Impact Assessment for agricultural projects. In order to assess E&S risks and impacts, Nakheel developed an Environmental Planning Manual (2013) that provides a process for identifying and assessing environmental risks. This manual describes Nakheel’s activities (e.g transportation of raw dates, processing and packaging) and the risks associated with these activities (waste disposal, land/ air/ water pollution, dust, noise, vibration etc.). Each risk is assessed in terms of the severity of impacts and the probability of harm, assigned a level of significance (Low, Medium, High) and recorded in the Environmental Risk Register. The Environmental Risk Register was last updated in 2018 taking into account changes in activities such as changes to the production process and introduction of new equipment.  Appropriateness of the risk register is discussed annually during Nakheel’s management review meeting. The Risk Register informs the Operational Environmental Plan. As per the ESAP, Environmental Risk Register and the Operational Environmental Plan will be updated to include changes in Nakheel’s activities, new acquisitions and expansions, as well as social and health and safety issues.

To address the E&S risks associated with Nakheel expansion (e.g. acquisition of new farms), the Project carried out E&S assessments in line with MIGA PS requirements and developed a time-bound action plan to address identified gaps, which included improper storage of fertilizers and pesticides, missing fire extinguishers, missing licenses for using water wells, and missing fencing around the farms.  Nakheel’s Agriculture and Quality Control departments has overseen the assessment and the implementation of the action plan.

Management Programs

Nakheel has developed an overarching Operational Environmental Plan that is aimed at reducing water, electricity and fuel consumption in its activities, as well as ensuring the proper management of waste streams. Environmental mitigation measures are adequately reflected in workplace procedures and plans such as farm specific waste management plans. As per the ESAP, the Project will update the Operational Management Plan and develop an occupational health and safety (OHS) and a Social Management Plan (SMP). The SMP will cover such aspects as community employment opportunities, traffic and road safety, community investment and indigenous peoples issues. These plans will reflect performance indicators, targets, or acceptance criteria (e.g. number of H&S accidents for deciding whether the risk is acceptable/ tolerable or additional mitigation measures are required) that can be tracked over defined time periods, and with estimates of the resources and responsibilities for implementation. Nakheel will also require the O&M contractor for the solar plant to develop OHS Management Plan for the rooftop solar plant operations (as per the ESAP). 

Organizational Capacity and Competency

Nakheel’s Quality Manager responsible for the Quality Control Department has the overarching responsibility of managing the Project’s health safety and environmental aspects. The Quality Control Department, which currently consists of one person (the Quality Manager), is responsible for developing procedures and associated E&S training plans. The Quality Manager works in close collaboration with: (i) farm agronomists to oversee aspects such as irrigation programs, pesticide use among others, and with (ii) farm supervisors on aspects related to health and safety. Nakheel will appoint a qualified Health, Safety and Environment (HSE) staff in addition to Quality Manager to manage HSE risks (as per the ESAP)

Training is provided throughout the year as per the Training Program established on the annual basis by the HR and Quality Departments and the Chief Agronomist. Internal training includes use of pesticides and fertilizers, new employee induction, farms operation (dethorning, harvesting), and plant operation. These internal training sessions also cover health and safety aspects. External training is mostly associated with the QMS certifications and Palestinian Labor Law. Training records are documented and filed.

Nakheel’s operations also involves servicing the rooftop solar plant. As per the ESAP, the Project will require the O&M contractor to appoint a HSE staff to manage solar plant E&S risks and impacts in line with the requirements of MIGA PSs.

Emergency Preparedness and Response

Nakheel has developed a set of emergency response and preparedness (ERP) procedures and plans in line with the requirements of MIGA PSs and include the identification of areas where accidents and emergency situations may occur. The following emergency scenarios are considered: fire, first aid and earthquake. Drills are periodically conducted and documented.

Monitoring and Review

Nakheel’s General Safety Procedure (Jan 2012) describes the requirement for regular monitoring and inspections of Nakheel’s farms and facilities. These include weekly internal monitoring site visits by the staff of the Nakheel’s Quality Control Department and monthly visits by the public safety officer. Such visits are resulted in the safety mitigation plans. Nakheel’s Quality Manager monitors the implementation of the mitigation measures.

Annual monitoring reports will also be developed and submitted to MIGA throughout the guarantee period.

Stakeholder Engagement

Nakheel has developed a Strategic Framework for Stakeholder Engagement (Dec 2020). The document describes the list of external and internal stakeholders including neighboring communities and Nakheel staff. The framework contains an analysis of stakeholder needs and mitigation measures to satisfy these needs. For example, to mitigate community risks Nakheel is committed to manage emissions, reduce dust, noise and other nuisances. The Framework will be complemented by the Stakeholder Engagement Plan (SEP) to account for such elements as disclosure and dissemination of information, consultation and participation, grievance mechanism, and ongoing reporting to affected communities in a culturally appropriate manner (as per the ESAP).

 

External Communication and Grievance Mechanisms

Nakheel developed a Grievance Mechanism Policy (Jan 2018) focused on addressing public grievances related to community health and safety, environmental issues and social concerns. It describes the steps for filing, acknowledging and responding to grievances or complaints from the public, as well as for arranging grievance meetings and escalating grievances to Nakheel management, as required.  The policy also describes grievance communication channels including emails and phone numbers with a possibility of contacting the Chief Executive Officer, as well as the time required to process, acknowledge and resolve each complaint. As per the ESAP, the Grievance Mechanism Policy will be updated to provide appropriate channels for grievances related to gender-based violence (GBV) and sexual harassment.  The mechanism will ensure that confidentiality of the persons raising the complaint is protected and that they are able to make report using different communication channels (anonymous, verbal, face-to-face, written etc.) and have access to support services (e.g. medical and psycho-social facilities in the areas to address GBV concerns, women support groups and NGO’s).   

PS2:  Labor and Working Conditions

Nakheel has a permanent workforce of 84 individuals of which 15 are women including three female employees at management positions. Nakheel hires a significant number of seasonal workers during the harvesting season in August- October each year. The numbers vary each season/ year. In 2021 Nakheel hired 741 temporary workers, 211 of which were females. Workers are hired directly by Nakheel and most of them are return workers. Most of the seasonal workers reside in Jericho and nearby. Dormitories are provided for 15- 25 seasonal workers that do not reside in Jericho.

To combat the spread of COVID-19 Nakheel has developed a set of procedures and measures in line with the requirements of the Palestinian government and the World Health Organization. Sanitation and hygiene measures include daily health screening and automated temperature checks, requirement for social distancing, office partitions, additional handwash stations and changing rooms, adjusted work schedule for plant employees and work from home arrangements for staff not directly involved in the production process. Employees at the sorting and packaging plant were observed wearing masks and safety goggles. 

Working Conditions and Management of Worker Relationship

Nakheel developed and is currently implementing a HR Management System based on the Palestinian Labor Law (2000) which is compliant with the requirements of the International Labor Organization (ILO). It includes principles for non-discrimination at employment, accident prevention, prohibition of employment of children below the age of 15 (and restricting the types of work for those below 18 years old to non-hazardous and not potentially harmful activities), and also sets requirements and conditions of work including working hours, annual and maternity leaves, salaries (including overtime payment), work contract and occupational health & safety. Nakheel provides medical insurance benefits to all employees (permanent and seasonal).

All permanent employees have a work contract based on Nakheel Employees Handbook which has been reviewed and stamped by the General Administration for Labor Inspection of the Palestinian Authority. Temporary workers have an Employee Form which includes background information (name, age, address, etc.), position and salary. Worker age is verified based on their identification documents prior to employment as a permanent or as a seasonal worker.

The Palestinian Labor Law sets the principle of freedom of association and unions. Reportedly, some workers have joined unions and the relation with the unions is good. Nakheel has not experienced any strikes and there are no reported ongoing litigations with employees.

The Project has developed an Equality and Diversity Policy (Jun 2020) which states that Nakheel opposes all forms of unlawful and unfair discrimination and that all employees, whether part time, full time or temporary, will be treated fairly and equally. Nakheel will develop an Anti-Harassment Policy which will contain clear definitions of harassment and GBV. The Policy will include a procedure to file complaints and explain how the GBV incidents are reported, investigated and recorded, as well as disciplinary measures for alleged perpetrators. Nakheel will also update its training plan to include periodical training on GBV risks for Nakheel staff (as per ESAP).

Grievance mechanism

Nakheel has developed a formal Employee Grievance System (2012) that describes an open process for managing complaints in Nakheel. As per the ESAP, the system will be updated to account for GBV risks and will include the possibility of reporting anonymously, formally or informally using different communication channels (verbal, face-to-face, written etc.), guarantee of confidentiality, secure management of information relating to a report, access for the complainant to support services, a transparent investigation without any retribution (as per ESAP).

Occupational Health and Safety

Typical occupational health and safety risks in Nakheel operations include falls from heights when working on the palm trees, injuries related to thorn removal process, risks related to handling hazardous substances such as pesticides, risks related to transportation between the Nakheel facilities, slips, trips and falls, risks associated with rotating equipment (e.g. entanglement) at the processing facility, noise, vibration and heat and cold stress.

Nakheel’s H&S Management System was developed in July 2013 in line with MIGA PSs and consists of the following procedures and instructions: H&S Hazards Identification Procedure, General Health and Safety Procedure, General Safety on Farm Instructions, Incidents Report, General Safety Checklist, Noise Management Procedure, Electricity Hazards Procedure, Employee Training Record and First Aid Procedure. H&S incidents and accidents at Nakheel are reported and investigated and the health and safety statistics is accurately maintained. As mentioned above, as per the ESAP the Project will update the existing H&S Management System with a comprehensive OHS plan to reflect current OHS risks of the Project.

Safety signs are generally present throughout the facilities. Emergency contact numbers and pesticides warnings are posted at the entry gates. Personal protection equipment (PPE) is provided to workers and includes safety shoes, gloves against perforation and safety goggles. At the sorting and packaging facilities, workers are provided with changing rooms equipped with lockers for their belonging, clean sanitary installation and potable water dispensers. At the farms, workers are provided with potable water, shaded resting areas and tents. Sorting and packaging facilities are equipped with good lighting and ventilation and manual handling is minimized to light loads. The sorting and packaging facilities are also provided with interlocks, emergency stop buttons and guarding. The cold storage facility is equipped with a safety release mechanism and an alarm and the time personnel can spend inside the refrigerator is regulated and limited.

Dormitories are equipped with air cooling, fridge, kitchenette and sanitary facilities.

Nakheel will make sure that the pesticides storage and mixing areas at the farms are compliant with World Bank Group General EHS Guidelines and, in particular, equip such areas with eyewash stations, equip first aid kits with the content suitable for the pesticide trauma and provide additional training on responding to accidents related to hazardous material handling (as per the ESAP).

Supply Chain

Nakheel is in the process of developing of a Supply Chain Policy in line with MIGA PS requirements to ensure that current and future suppliers and service providers are screened against the risks of forced and child labor and that the on-going monitoring provisions are in place (as per the ESAP). The Policy will be a part of the ESMS. Nakheel will also require the O&M contractor to develop their own Supply Chain Policy in line with MIGA PS 2 and apply it to the future procurement of solar panels and associated parts (as per the ESAP).

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency

Nakheel’s Operational Environmental Plan (2015) contains strategic goals and objectives for reducing electricity, fuel, water and paper consumption, as well as reducing solid waste. Nakheel also implements measures to maintain a long-term soil productivity. Reportedly, soil samples are taken prior to planting new trees or replacing dead ones and sent to a laboratory for nutriment analysis. No nutriment depletion is detected and no evidence of soil erosion was observed at Nakheel’s farms. Nakheel has developed a Farm Management Procedure (2013) which lays out the rules for balanced fertilizers usage, soil incorporation of crop residues and use of compost (e.g. leaves and brunches are turned into compost).

Greenhouse Gases

The Project is not a producer of a significant amount of the Greenhouse Gases (GHGs).  The total annual electricity consumption is around 1,500 Megawatt-hours (MWh), 30 % of which is supplied by the rooftop solar plant. The Project’s annual GHG emissions is estimated at 1,300 tons of CO2 equivalent.           

Water consumption

Nakheel’s annual water consumption for irrigation needs is approximately 2.7 m3 per kilogram of dates produced (2021). Water is sourced from the groundwater wells located at the farms (7%) and purchased from outside sources- primarily from the neighboring water well owners (93%). There are two water pools (2 x 100,000 m3) developed by Nakheel specifically for irrigation where the water is stored.  The water resources study conducted for Nakheel by a third party engineering consulting firm in November 2016 concluded that despite the scarcity of water resources in the region and the increase of water demand for Nakheel, adverse impact on communities or the environment associated with Nakheel’s current and future irrigation needs were not identified and are not anticipated. Nakheel has implemented water conservation measures including the (i) the adoption of a computerized drip irrigation system; (ii) the installation of tensiometers for irrigation scheduling; (iii) the construction of a water pipeline connecting the farms and enabling them to share water; and (iv) the purchase of water from outside sources (approximately US$1.2 million annually).

Pollution Prevention

Air, water and land pollution from Project activities is not significant, and the Project is implementing measures to minimize and control pollution including the use of renewable energy, dust suppression and following the strict rules for sewage disposal. There are no rivers or other environmentally sensitive receptors close to the farms. Sewage waste from the farms is collected in a septic tank and transported off the farms by private vacuum tanker providers, whereas the sewage system at the sorting and packaging plant is connected to the public sewage line. Nakheel consumes 80% of its electricity from the grid and the rooftop solar plant provides for 20% of the electricity needs.

Wastes

Farm wastes at Nakheel include leaves and bunches that are turned into compost, as well as domestic waste generated by farms workers (plastic bags, metal cans etc.). It also includes hazardous waste such as empty pesticide containers and fertilizer packaging which are transported to the municipality landfill. The Project will update its Waste Management Plan to ensure compliance with the WBG EHS Guidelines in terms of proper disposal of hazardous waste (as per the ESAP).

Waste from the sorting and processing facility, such as damaged plastic boxes, are segregated and sent back to the supplier for recycling. Paper is also segregated in the office area and sent to a third-party recycling company. All other wastes are collected by the municipality and disposed of at a municipal landfill.

Pesticide Use and Management

Nakheel’s Farm Management Procedure and its Pesticides Record Form contains instructions for the application of pesticides. The Quality Department reviews and ensures that all pesticides are used in line with Palestinian and International regulations including Food and Agriculture Organization guidelines. The list of pesticides used is also verified by Food Safety auditors (ISO 22,000, GlobalGAP) and no issue was reported. The main pesticides used in Nakheel’s farm activities include: Copper Hydroxide (Fugoran), Triflumuron (Alsystin) and Abamectin (Vermitec). The Quality Department monitors that pesticides concentration are in line with suppliers’ recommendation. According to the Quality Department these are never exceeded. No large quantities of fertilizers, pesticides or other chemicals are stored at Nakheel farms. Pesticides regularly replenished by the third-party contractor.

The Project will update current procedures and practices to ensure that they comply with the WBG EHS Guidelines in terms of storage, handling, application and disposal of pesticides and other hazardous substances (as per the ESAP).

PS4:  Community Health, Safety and Security

Community Health and Safety  

None of the Nakheel farms or other facilities are located in close proximity to residential areas. Farms were developed on arid land with no known ecosystem services to local communities. Road safety is the primary potential adverse impact to community health and safety associated with the transportation of dates and personnel. To manage the risks related to transportation Nakheel has developed a Traffic Safety Procedure (Jul 2013) that lays out requirements for journey management plans, requirements for vehicle maintenance, driver training and responsibilities.

As discussed under PS 3, the quantities of hazardous materials are limited and stored in a secure location without any community access to these materials. Nakheel has developed a set of emergency response and preparedness procedures which includes assistance and collaboration with the local government agencies, and other relevant parties, in their preparations to respond effectively to emergency situations.

Security Personnel

Palm tree farms are fenced and have clear boundaries. Signs are posted at each entrance describing the requirements for visitors and security contact details. Security guards are present at the sorting and packaging plant. As per the ESAP, Nakheel will develop a Security Procedure to include: i) screening of security contractors for past involvement in crimes/ abuses related to sexual harassment and GBV; ii) training of security personnel on the requirements of the Nakheel’s anti-harassment and the Equality and Diversity policies and the; iii) the roles and responsibilities of security staff in grievance redress; iv) training of security personnel in human rights (including combatting GBV; v) rules of engagement and use of force, and; vi) responsibilities of Nakheel staff and resources, such as dedicated personnel to oversee the management of security at Nakheel and its farms.

PS7: Indigenous Peoples

Based on the IBIS ESDD Report, in 2016 there were nomadic Bedouin communities present near the Project facilities and there was Bedouin camp located South-West from the sorting and packaging plant.  These tribes, which are semi-nomadic agro-pastoralists, moved from the Negev Desert in late 1940s to the rural areas around Hebron, Bethlehem, Jerusalem, Jericho and the Jordan Valley. As they have informally settled in the area, they remain vulnerable to forced displacement in the West Bank.   Per the criteria outlined in the MIGA PS 7, these Bedouin tribes are considered Indigenous Peoples. The ESDD report confirmed that the Project did not result in: (i) impacts on lands and natural resources subject to traditional ownership or under customary use; (ii) relocation of indigenous peoples from lands and natural resources subject to traditional ownership or under customary use; and (iii) impact on critical cultural heritage, and therefore, the Project does not require Free, Prior and Informed Consent from the Bedouin community. The report, however, recommended that any future Nakheel’s development did not interfere with pathways used by Bedouins for moving and grazing their cattle.

Nakheel’s Stakeholder Engagement Plan will include specific provisions for culturally appropriate consultation with Bedouin communities. In addition, Nakheel will engage with the qualified third parties (e.g. from the specialized NGO’s or research institutions) to identify development opportunities for Bedouin communities and screening measures to prevent potential impacts that can be included in the Social Management Plan (as per the ESAP).

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

Broad Community Support is not applicable for this project.

 

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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