As part of the sustainability-linked loan of R$ 300 million with the International Finance Corporation (IFC), member of the World Bank Group, aiming at promoting sustainability actions, Corsan signed a long-term commitment to adopt the best international practices related to social and environmental aspects.
The Company put together the Social and Environmental Action Plan, which consists of the following deliverables:
> Develop and implement an ESMS in alignment with the requirements of IFC PS1, which include the following elements:
(i) policy,
(ii) identification of risks and impacts,
(iii) management programs,
(iv) organizational capacity and competency,
(v) emergency preparedness and response,
(vi) stakeholder engagement, and
(vii) monitoring and review.
As a component of the ESMS, Corsan will develop key E&S performance indicators that will be regularly reported to top management and will be audited on an annual basis. The monitoring and review will include assessment of compliance with any related legal and/or contractual obligations and regulatory requirements. Under (ii) above, starting from a gap analysis between the regulatory requirements and IFC PSs, Corsan will develop and implement a procedure to identify E&S risks and impacts for all phases of projects (i.e., design, construction, O&M and decommissioning), in alignment with good industry international practice (GIIP), and as required by IFC PS1. The company’s management system will include a risk screening, assessment and management procedure for biodiversity, IPs, and cultural heritage, consistent with PS 6, PS 7 and PS 8. Under (iii) above, Corsan will develop corporate E&S management standards and relevant management programs that describe mitigation and actions that address the identified E&S risks and impacts of the projects undertaken by Corsan, consistent with IFC PSs, and will ensure that such standards and programs, including contractor management and development of project E&S Management Plans (ESMP), are implemented at the level of the projects financed by IFC. The company will also develop and implement a corporate Stakeholder Engagement Framework and implement a grievance mechanism in line with PS1 and a Land Access Policy and Procedure in line with PS5.
> Develop and implement a Plan to mitigate temporary socio-economic impacts associated with any disruption of access and economic activities due to works along the water line right-of-way as part of the implementation of the water loss reduction program.
> Strengthen its current organizational structure at the corporate level and at the level of regional offices to integrate environmental, social and occupational health and safety staff and ensure consistent implementation of corporate E&S policies, plans and procedures across company’s operations.
Further develop the risk identification matrix in terms of potential emergency situations, and develop and implement EPRPs that are tailored to each facility or activity to be performed (construction, regularly scheduled or non-routine maintenance/repair, facility operations). Staff and contractors will be trained on emergency response and drills will be conducted. The company will provide appropriate information to potentially affected communities and relevant government agencies.
> Develop and implement an OHS management system consistent with IFC PS requirements and aligned with GIIP, including the relevant guidelines included in WBG General EHS Guidelines and EHS Guidelines for Water and Sanitation. Corsan will review, update and strengthen implementation of corporate policies, plans and procedures to ensure consistent OHS performance across the regions of operations. The company will review and update the allocation of resources, including personnel, tools and equipment, and organizational structure to support the OHS management system. The procedures will include measures to mitigate and monitor occupational exposure to chemicals at the WTPs.
> Establish policies and procedures for managing and monitoring the OHS and labor performance of contractors in relation to the requirements of Performance Standard 2. In addition, the company will incorporate these requirements in the contractual agreements with its contractors.
> Develop and implement emergency preparedness and response plans for the project sites. The plans will include on-site and off-site emergency scenarios, including appropriate quantitative risk assessments in terms of hazardous materials releases onsite and offsite (i.e., due to transportation). Depending on the site-specific conditions and potential for emergencies to affect nearby stakeholders, the emergency and preparedness plans will have procedures for awareness training including drills and coordination with district/local government emergency authorities.
> Develop a Security Management Plan (SMP) including provisions for security providers in terms of selection of security personnel, rules of engagement (including use of force), appropriate conduct toward workers and communities, training, equipment, facilities, working conditions, and grievance mechanism.
Corsan is upgrading its grievance mechanism for affected communities which will allow expression of concerns about the security arrangements and acts of security personnel.
Link to IFC Website with further information on the Action Plan