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Sierra Leone

Sierra Tropical Limited

$37 million
Agribusiness
ESRS
Proposed
plantation southeast asia

Project Facts

Project Facts

Project Facts

Sierra Leone
Guarantee Holder
Dole Asia Holdings Pte. Ltd.
Investor Country
Singapore
Environmental Category
A
Date SPG Disclosed
August 02, 2018
Projected Board Date
October 26, 2018
Project Type
Non-SIP

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed in advance of the MIGA Board consideration of 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 the MIGA Board of Directors.  Board dates are estimates only.

Any documentation which 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.

The Project consists of the development of a greenfield agro-industrial operation that will cultivate, harvest and process pineapple for export to throughout the world. The Project has identified potential leasable land in Lugbu Chiefdom, Bo District, for development. Part of this area has already been leased and the remaining area will be leased before the Project moves into commercial planting. Once additional nurseries are launched and the required seeds are produced, commercial planting will begin. Thereafter, commercial harvesting, along with the establishment of a fruit processing facility will commence.

The Project is a Category A under MIGA’s Policy on Environmental and Social Sustainability (2013) mainly due to the significant adverse E&S risks impacts that may be diverse and irreversible, which include the contextual risk of the project, the size of land-take and the sector (agri-business). Key environmental and social issues include land acquisition and economic displacement; use and management of pesticides and fertilizers; soil conservation and management; water management; impact on cultural heritage (sacred groves); waste management; occupational health and safety issues during crop production; and risks related to food and beverage processing.

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

  • 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
  • PS 5: Land Acquisition and Involuntary Resettlement

PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not relevant as the Project Area is comprised of mainly agricultural fallow land (farm bush) and farms. According to the Project’s Environmental and Social Impact Assessment (ESIA) study (September 2016), most forests in the Project’s concession zone are secondary, except for a few sacred groves and the tract of gallery forest along the river banks which appears to be dwindling. Appropriate mitigation measures are included in the ESIA, which include the creation of buffer zones and habitat corridors, as well as a High Conservation Value Assessment/Biodiversity Study prior to any land clearing and development.

PS7 (Indigenous Peoples) is not relevant to this Project since no indigenous communities were identified to reside in the Project Area. PS8 (Cultural Heritage) is not triggered except for the need to implement a “chance finds” procedure.

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

  • WBG General EHS Guidelines;
  • WBG EHS Guidelines for Perennial Crop Production; and
  • WBG EHS Guidelines for Food and Beverage Processing.

The documents reviewed by MIGA:

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

Environmental and Social Assessment

The Project falls under the scope of the Sierra Leone Environment Protection Agency (EPA-SL) Act (2010). As part of the permitting process, a Scoping Report for the Project was produced and submitted to the EPA in January 2015. Thereafter, an ESIA Study Report was developed aligned to national legislation in September 2016 and submitted to EPA-SL for review and approval in July 2018. The scope of the ESIA of this Project is a new agro-processing facility which consists of a pineapple nursery, the establishment of plantations, construction of administrative buildings, security posts, a boundary wall and worker’s accommodation, within the project footprint.

The following Environmental and Social Management Plans (ESMPs) have also been developed by STL as part of the ESIA study to manage impacts during construction, operations and decommissioning:

  • Occupational Health and Safety Plan;
  • Waste Management Plan;
  • Pesticide and Chemical Management Plan;
  • Emergency Response Plan;
  • Resettlement Policy Framework;
  • Community Development Action Plan;
  • Public Consultation and Disclosure Plan; and
  • Closure Plan.

Public hearing meetings will be held to disclose the ESIA Study Report both in Bo District and the Project Area and a summary report of the meetings will be submitted to EPA-SL. Following approval of the Report by EPA-SL, a gap comparative analysis will be carried out, based on the existing ESIA and the MIGA PSs.  

An ESIA for the construction and operations of the fruit processing plant will be developed in line with the PSs and submitted to EPA-SL in February 2019. The ESIA for the fruit processing plant will include a suite of ESMPs that will provide the mitigation measures that the Project will implement during construction and operation.  STL shall also calculate the total carbon dioxide (CO₂) equivalents for the processing plant based on its electricity and diesel consumption. These amounts will be reported in the MIGA Annual Monitoring Report (AMR).

 

Management Program

The Project will develop and implement an Environmental and Social Management System (ESMS) for the agro-processing facility (including the fruit processing plant) in line with PS 1 requirements. In addition, the following certifications or their equivalents, will be applied as required during the operations phase:

  • ISO 22000: 2005, Food Safety Management Systems (FSSC) Certification, which specifies requirements for a food safety management system and the ability to control food safety hazards. This system also integrates the seven principles of the Hazard Analysis and Critical Control Points (HACCP).
  • Global Good Agricultural Practice (GAP), which are voluntary standards for the certification of production processes of agricultural products around the globe.
  • SA 8000, a social certification standard that helps organizations demonstrate their dedication to the fair treatment of workers and reflects the labor provisions contained within the Universal Declaration of Human Rights and International Labor Organization (ILO) convention.
  • Rainforest Alliance certification, which ensures that products are grown and harvested using environmentally and socially responsible practices.

In addition, an Ebola and Malaria Preparation and Response Plan will be developed as part of the ESMS, in consultation with local Health Officials.

 

Organizational Capacity

As per the ESMP, an Environmental, Social, Health and Safety (ESHS) Officer will be appointed for the Project. S/he will report directly to STL management on EHS issues. Roles and responsibilities of the EHS officer will include, but will not be limited to:

  • Ensure on-going improvement of environmental, health and safety standards;
  • Review Occupational, Health and Safety (OHS) policies and plans, as required;
  • Participate in OHS meetings and training (including emergency response training), as required;
  • Ensure compliance with national legislation, international standards, company standards and internal procedures;
  • Act to immediately rectify any unsafe situations or acts;
  • Ensure workers are provided with personal protective equipment (PPE);
  • Maintain the inventory of safety equipment and supplies;
  • Organize and train personnel in first aid;
  • Maintain records on accidents, incidents, near misses, emergencies and fatalities;
  • Coordination of the Emergency Response Team; and
  • Report regularly to regulatory agencies and stakeholders.

 

Environmental Preparedness and Reponses

As indicated above, an Emergency Response Plan (ERP) has been developed for the Project in line with PS 1 requirements. The Plan details management procedures for issues related to spills and leaks of fuels, oil, chemicals and fertilizer; major and minor accidents; medical health cases; as well as civil unrest and disturbance. As per the ERP, an Emergency Response Team (ERP) will be constituted from members of the Project’s management team.  

 

Stakeholder Engagement

Stakeholder engagement during the ESIA process was carried out through Focus Group Discussions (FGD) within the villages where the Project Site is located. Upon submission of the ESIA Report to EPA-SL, STL will hold public hearing meetings to disclose the ESIA Study Report both in Bo District and the Project Area.  A Public Consultation and Disclosure Plan (PCPD) has also been prepared as part of the ESMPs which details the engagement to be carried out during the operations phase of the Project. The PCPD should allow the effective participation of those identified as disadvantaged or vulnerable, as per PS1 requirements.

 

External Communications and Grievance Mechanisms

A grievance mechanism for the Project has been included as part of the PCPD. As per PS 1 requirements, the Grievance Mechanism should seek to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate and readily accessible. The Project will need to appoint a Community Relations Officer/Community Liaison Officer to manage and address grievances raised by the affected community.  

 

Monitoring and Review

The following monitoring plans are also included in the Projects ESMPs:

  • Climate monitoring;
  • Noise and air quality monitoring, in line with EPA requirements;
  • Surface and ground-water monitoring; and
  • Community development monitoring.

During the implementation stage, environmental monitoring and auditing of the Project will be undertaken in accordance with the EPA Act (2010) and STL will submit quarterly and monitoring reports to EPA-SL. STL will also submit to MIGA an Annual Monitoring Report (AMR) on environmental and social performance prepared in accordance with MIGAs Performance Standards and the WBG General EHS Guidelines and EHS Guidelines for Perennial Crop Production.

 

PS 2: Labor and Working Conditions

The Project currently has 160 casual workers, but will ultimately create over 1,500 formal jobs by 2019 and potentially reach 3,500 formal jobs by end of 2021. Landholders as well as the local community will be given priority with regards to employment, especially non-skilled workers initially for land clearing and preparation. The Project will also ensure the provision of equal employment opportunities to women. It is not anticipated that any worker accommodation will be constructed, as all the workers will be from the Project Area. However, if worker’s accommodation is deemed necessary the Project will develop and implement an overall strategy for worker accommodation to ensure that it complies with PS2.

 

Human Resources (HR) Policies and Procedures

Labor practices in Sierra Leone are regulated by various legislation, including: Employers and Employed Act (Chapter 212); The Trade Unions Act (Chapter 221); and Recruiting of Workers Ordinance (Chapter 216). To fulfill and comply with MIGA’s Performance Standard (PS) 2: Labor and Working Conditions, a Human Resources (HR) Policy and relevant procedures will be prepared. The HR manual and procedures to be developed include, amongst others: terms of employment and recruitment, training and development, performance management, promotion, transfer, demotion and separation, remuneration, benefits and other assistance schemes, working hours, leave, disciplinary code, grievance mechanism, employee relations and safe working conditions.

Priority will be given to local landowners for unskilled employment. This will be done in consultation with the Chiefdom.

 

Worker Grievance Mechanism

STL will include, in line with PS 2, for the construction and operation phases, a mechanism where grievances of employees and sub-contractors related to environment, health and safety issues will be handled. All workers will be informed about the grievance mechanism at the time of employment. The grievances can be raised anonymously and reviewed in one-week intervals followed by the initiation of corrective action within two days for grievances of high importance. Internal grievances will be handled by the HR Manager who will ensure that they remain confidential. 

 

Retrenchment Plan

In the event of any retrenchment, STL will develop and implement a Retrenchment Plan in line with PS 2 requirements, in consultation with workers, their organization and if appropriate, the Government.  

 

Occupational Health and Safety

The Sierra Leone Factories Act (1974) addresses health and safety issues with regards to workers. The Project has developed an Occupational Health and Safety (OHS) Plan which identifies potential hazards, risks to the local community as well as management responsibilities. STL will also monitor OHS by tracking non-reportable accidents in less than three days, as well as near misses. OHS analysis, trends and recommendations (e.g. for preventative actions) will be submitted to the ESHS Officer who will be responsible for implementing and reviewing the OHS Plan.

In addition, safety signage will be developed to advise employees and others of specific hazards in work locations and areas that are prohibited for entry. Firefighting equipment will be provided and workers will be provided with mandatory personal protective equipment (PPE). STL will raise safety culture and awareness among all its employees and will commit to providing ongoing safety training according to an annual training plan.

 

Supply Chain

The Sierra Leone Child Rights Act (2007) sets the minimum age for employment at 15. However, the Project will not employ workers under 18 years of age. The potential for child and forced labor in the supply chain will also be monitored and contracts with sub-contractors and suppliers will include Environmental Health and Safety (EHS) requirements and provisions consistent with PS2 to address labor issues including child and forced labor.

 

PS3: Resource Efficiency and Pollution Prevention

Baseline conditions were established for the study area through field measurements for air quality and dust; noise; soil; agricultural land suitability; water quality; and ecology (see ESIA Annexes for more details).

 

Water Supply

Water for irrigation and spraying will be obtained from the Sewa River.  The total irrigation water requirements from the Project are 7,585,000 m³ per year. Water for the cannery will be sourced from approximately four boreholes. A Water Management Plan will be developed to reduce water consumption in line with PS3 requirements. Irrigation water conservation techniques will also be implemented, which include:

  • Regular maintenance of the irrigation system, as well as that of its associated channels and infrastructure;
  • Reducing evaporation by avoiding irrigation during periods when evaporation is elevated (e.g., in periods of higher temperatures); and
  • Reducing evapotranspiration by using shelterbelts and windbreaks.

 

Waste Management and Disposal

A Waste Management Plan has been developed for the Project and the main types of waste expected to be generated include:

  • Agricultural waste, specifically plant waste (biomass from vegetation clearing, pruning, etc.) that will be used as compost. Burning of biomass on-site will be avoided unless necessary;
  • Solid waste, generated by day to day activities of workers (paper, plastics, food, etc.) as well as from the fruit processing plant, will be separated at source; and
  • Hazardous Waste, which includes waste oils, fuel filters, pesticide/fertilizer containers and packaging will be disposed of in assigned and labeled waste receptacles and stored safely for transportation to and disposal at a hazardous waste management facility.

Staff will be trained in the safe handling and disposal of agricultural, solid and hazardous wastes.

 

Wastewater

Grey and black water from the offices will be directed via a sanitary sewage system to septic tanks which will be emptied by a licensed sewage management company, when required. The fruit processing plant waste water disposal system will have an extensive lagoon treatment system with settling, aeriation and flocculation steps.

 

Air Emissions

Main sources of air pollution during construction and operation were identified in the ESIA as dust and exhaust emissions from the movement of vehicles and machinery along dirt roads. Principal pollutants resulting from these sources are dust and particulate matter (PM). As per EPA -SL requirements, the quantity of PM10 in the air was recorded within and around twenty-one settlements in the study area during the rainy season, which resulted in barely recorded levels of particulate matter, which is below the World Health Organization (WHO) Air Quality Guidelines.

During operations air emissions may also be produced from the disposal or destruction of crop residues or processing by-products by burning, as well as PM and odor from the fruit processing plant. Therefore, biomass will be used as much as possible as compost and burning will be used as an absolute last option. Techniques to prevent and control particulate matter and odor emissions from the processing plant will be in line with the Guarantee Holder’s Headquarter Corporate procedures.

 

Pesticides Use and Management

The Project will use crop protection products only when necessary, per the Guarantee Holder’s Code of Conduct, and will not use any products banned for either unacceptable health or environmental risk by the United States EPA, Japan or the European Union.  In line with PS3, the Project has committed to the selection and use of chemical pesticides that are low in human toxicity and have minimal effects on non-target species and the environment.

A Pesticide and Chemical Management Plan (PCMP) has been developed for the Project which outlines the measures for the prevention and mitigation of pesticide’s (and other agrochemicals) in ground and surface water following their application. The PCMP includes an integrated pest management (IMP) approach, in line with PS 3 and procedures for the selection, procurement, storage, handling, and ultimate destruction of all out-of-date stocks of pesticides and chemicals.   

 

PS4: Community Health, Safety and Security

Community health and safety risks associated with the Project include safety risks from increased traffic as well as vehicle and/or machinery injuries on roads and access routes around the community. In addition, hazardous products and chemicals (e.g., pesticides), may affect community health through dermal contact, ingestion, or inhalation. STL will therefore ensure that the risk of exposure to hazardous products is minimized by following guidelines for the transportation, storage, handling, usage, and disposal of pesticides and agrochemicals.

A Security Plan in line with PS4 will be developed to be implemented during the operation of the Project. Security will be provided in a manner that does not jeopardize the community’s safety or the Security Provider(s) relationship with the community and that is consistent with national requirements. International best practice will be applied to hiring, training and mobilizing security personnel. The Security Provider(s) will ensure that security personnel have not been involved in past abuses and are adequately trained.

 

PS5: Land Acquisition and Involuntary Resettlement

The Project will lead to economic displacement as it will lease land from 300 landholders. However all land acquisition is being carried out in line with PS 5 requirements, as follows: (i) the land transactions are being carried out voluntarily, through willing lessee-willing lessor agreements and compensation is being carried out in line with PS 5 requirements; (ii) while land policy and land ownership in the provinces are under the Chiefdom and not by individuals, in this Project there have been negotiated compensation settlements agreed upon by the Client, the Project Affected Persons (PAPs) and the Chiefs; (iii) in addition, there would have been alternative options for land acquisition, as there is no land scarcity in and outside the Project Area; and (iv) as the Project is not acquiring 100% of each PAPs land, there are no impacts on livelihoods as the Project is not changing the land use of the PAPs or local community. In addition, a Community Development Action Plan (CDAP) that focuses on establishing sustainable livelihood projects and capacity building within the affected community has been developed.

The Project will therefore ensure that it implements and monitors the livelihood restoration strategies within the CDAP.

The Project will be assessed against the EPA-SL Act (2010). As mentioned previously, the ESIA Study Report was submitted to EPA-SL in July 2018 for review and approval. STL will hold public hearing meetings in both Freetown and the project area to ensure public participation in the decision-making process. The ESIA Report will thereafter be gazetted and circulated to national professional organizations for comments.

A stand-alone Public Consultation and Disclosure Plan (PCDP) has been developed for the Project, to help structure a systematic communication with the stakeholders during construction and operations. The details of the stakeholder engagement activities conducted for the ESIA study are presented in Annex A of the ESIA Study Report (Minutes of the Focus Group Discussions) as well as Section 8.3 of the PCPD.

The PCPD will be updated during the Public Disclosure and during the operations phase of the Project.

Consultations during MIGA due diligence revealed support for the project given the compensation for the land, need for employment and the general economic boost to the area.

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