Professional Documents
Culture Documents
The publication is distributed with the understanding that neither the authors, nor the
organizations and countries they represent, nor the publisher, are engaged in
rendering technical advice. The publication is intended as a reference and for
informational purposes only, and is not to be relied upon for operational or any other
purposes. Implementation of the publication is solely the responsibility and risk of the
final users. The material in the publication is set out in good faith for general
guidance, and no liability can be accepted for any possible loss or expense incurred
as a result of relying on the information contained herein. Neither IFC nor any other
member of the World Bank Group shall be liable for any direct, indirect, incidental,
special, consequential, punitive or exemplary damages, including, but not limited to,
damages for loss of profits, goodwill, use, data or other intangible losses (even if IFC
has been advised of the possibility of such damages) in any way arising or resulting
from use or reliance on the publication or any such conclusion or determination. The
publication is distributed subject to the condition that it shall not by way of trade or
otherwise be sold, or otherwise circulated on a commercial basis without IFCs prior
written consent.
IFC does not guarantee or provide any warranties as to the accuracy, timeliness,
completeness, reliability or usefulness of this publications content, and is not
responsible or liable for any such content or your use thereof. The views, advice,
opinions and other statements herein are not reviewed or endorsed by, and do not
necessarily represent the views and opinions of, IFC or its Board of Directors, the
World Bank or its Executive Directors, or the countries they represent.
Table of Contents
Welcome & How to Use
This ESMS Toolkit
Environmental and social responsibility is becoming more and
more important in todays global economy. There are thousands
of environmental and social codes and standards in the world
today. The codes and standards define the rules and the
objectives. But the challenge is in the implementation. An
environmental and social management system helps companies
to integrate the rules and objectives into core business
operations through a set of clearly defined, repeatable
processes.
As you go through the Toolkit, you may want to refer back to the
companion publication, the ESMS Implementation Handbook,
which gives more background on each of the nine ESMS
elements.
Acknowledgments
1. Policy
Policy
Introduction
Environment
Environmental laws and regulations
Resource utilization efficiency (energy, water, important input materials, etc.)
Greenhouse gas (GHG) emissions
Release of pollutants into air, water, and land
Handling, storage, and disposal of hazardous chemicals
Hazardous and non-hazardous wastes
Recover, reuse, treatment, and proper disposal of waste
Consideration of non-chemical means to control economically significant pests and vectors
Conversion of forest lands or wetlands
Retrenchment
Consideration of alternatives and mitigation in case of retrenchment
Payments and benefits in compliance with national law
Grievance mechanism
Transparent process for receiving and resolving worker complaints
No retaliation or discrimination
Child labor
Minimum age for employment
Conditions for engagement of young workers
Forced labor
Freedom of movement, freedom to resign
No retention of identification papers or money to detain workers
Occupational health and safety
Safe work environment and dormitories, if applicable
Emergency prevention and response system
Personal protective equipment and appropriate training
Documentation and reporting of accidents, near misses, and illnesses
Appropriate use of potentially hazardous chemicals in accordance to Material Safety Data
Sheets (MSDS) and International Chemical Safety Cards (ICSC).
Workers engaged by third parties
Extension of labor policies to labor contractors, recruiting agencies and other third parties
Grievance mechanism for contracted workers
Supply chain
Extension of policies and monitoring of supply chain with respect to child labor, forced labor
and worker safety to supply chain
Identifying your risks can seem like a daunting task, but dont
be overwhelmed. You can scale your program to be
appropriate for the size and complexity of your company.
But remember, small companies can have the same risks
and potentially severe environmental and social impacts as
large companies.
ENVIRONMENTAL RISKS
My company has Potential negative impact (A yes
RISK FACTORS the following response means that there is a
conditions potential negative impact)
Our operations require large quantities Yes/No Water resources depletion in the region.
of fresh water. Contamination of ground or surface
water sources in the region due to
discharge of surface runoffs.
Our operations have high Yes/No High energy consumption.
requirements for power supply.
We require large quantities of fuel Yes/No Air emissions.
(gas/diesel/etc.) for our operations.
We have various processes and utility Yes/No Air emissions. Solid waste (e.g. waste
equipment, which may generate air from equipment maintenance, fly and
emissions (e.g. boiler, diesel generator bottom ash from coal-based boilers).
set, incinerator, grinder, etc.). Hazardous waste (e.g. waste oil, oil-
soaked filters and rags). Liquid waste
(e.g. boiler blow-down, waste oil).
Noise generation.
We generate large (or significant) Yes/No Solid waste. Liquid waste.
quantities of solid or liquid waste from Contamination of land, groundwater
our manufacturing or production and/or surface water due to improper
processes. disposal of solid and liquid waste.
We dispose of our solid waste in our Yes/No Contamination of land, groundwater
landfill or citys landfill facility. (due to leachate) and/or surface water
(due to run-off).
We generate hazardous or toxic solid Yes/No Contamination of land, groundwater
or liquid waste such as chemical and/or surface water (due to run-off) if
residues and sludge from wastewater disposed improperly.
treatment plants.
We discharge our wastewater (process Yes/No Contamination of receiving water body
effluent) in a nearby river, lake or any and aquatic life. Eutrophication due to
other water body. high BOD5 or COD.
We treat our wastewater and sewage Yes/No Energy consumption. Solid waste
(from toilets, washrooms, etc.) before generation (e.g. sludge from treatment
it is discharged. process, treatment chemicals). Land
and/or water contamination due to
improper disposal of solid waste (e.g.
sludge).
We do not re-use (part of) our treated Yes/No Water consumption.
wastewater (process effluent) for
processing purposes.
We use some banned or restricted Yes/No Non-fulfillment of regulatory
chemicals/materials in our processes. requirements. Air, land or water
pollution depending on current usage.
Exposure of workers or consumers to
banned chemicals.
We face problems related to Yes/No Use of chemicals. Chemical exposure
pests/vectors. to workers. Land or water
contamination due to disposal of
infested material.
We require large extensions of land. Yes/No Loss of biodiversity. Soil degradation.
GHG emissions.
2. Identification of Risks and Impacts
Inputs Process Outputs OHS hazards Risks and potential Opportunity For
steps and potential negative impacts on Waste
negative impacts the environment and Reduction/Energy &
on workers community Water Savings
Water, Operational Waste, Injuries, long- Environmental Improved process,
energy, activity emissions, term illnesses pollution, shortage reuse and recycling
raw byproducts of resources
materials,
chemicals,
labor etc.
What inputs What is the What waste What type of What type of negative How can the activity
activity? does the negative impact impact could this be improved to
are needed to
(This should activity could this activity have on the prevent those
carry out the be one step produce? activity have on environment and the negative impacts from
activity? in an workers? surrounding occurring?
operational community?
process.)
2. Identification of Risks and Impacts
Where are people most likely to become injured? Identify trip, slip and fall hazards (from
falling objects or a fall from an elevated area), as well as areas where someone could
become injured by vehicles.
Are equipment, tools, and machinery designed and maintained efficiently to reduce worker
strain? Can they be operated safely?
Where are workers exposed to hazardous chemicals, pathogens, excessive dust, noise,
sun, and extreme temperatures? Do workers have appropriate personal protective
equipment (PPE)? Is it being used correctly?
Is the work area lighting sufficient?
Are chemicals labeled and safely stored with compatible materials? Are there any existing or
potential leakages from containers?
Where could fires, explosions, or the accidental release of hazardous materials occur? Is
there adequate and appropriate response equipment close to those areas?
Are exit doors unobstructed and well-marked? Are they unchained and equipped with panic
bars?
Are any passages blocked due to the layout of the facility or improperly stored materials?
Which areas have high levels of water consumption or discharge? Identify all potential water
consumption and discharge sources.
Are input materials being used efficiently? Is material wasted at any point?
Where is most of the waste produced in the facility? How is the waste managed?
Has your companys use of land negatively affected nearby residents (e.g. through emission
of pollutants or land encroachment)?
In general, are there places or work processes with clear bad habits?
After the walk-through, meet with the team and discuss your observations. You can also discuss
previous incidents or accidents and their consequences, so that you can take steps to prevent
similar situations in the future.
The information you collect in the walk-through will form the basis of the Action Plans you will
prepare as part of your Management Program in Chapter 3.
2. Identification of Risks and Impacts
High
(high probability, high impact)
Probability of Occurrence low impact)
Low High
Severity of Impact
What is the risk What is the likelihood How severe would What are the highest Any additional
that has been that this risk will occur the potential impacts priority risks based on notes.
identified? (Use and create negative be, if the risk should the likelihood of
previous tools to impacts? occur? occurring and the
identify risks.) severity of the impact?
3. Management Programs
Management Programs
Introduction
Outline of Procedure
Instructions
The risk or problem that you
prioritized through your risk
assessment is the treetop.
The root causes are the roots
of the tree. Root causes are
gaps in the implementation of
your management system.
Group similar root causes into
the appropriate ESMS
element: Policy, Identification
of Risks and Impacts,
Management Programs,
Organizational Capacity and
Competency, Stakeholder
Engagement, and Monitoring
and Review.
In the area outside of the tree,
you can include information about external factors that may influence your business but are
beyond the direct control of your company. These may include your external environment,
such as the weather or a natural disaster, and other factors, such as government policies,
economic trends or market forces.
As with the other exercises, you should conduct this activity with a diverse group of
employees to ensure that you capture different perspectives within the company.
The root cause tree diagram is a useful tool to help you move beyond the surface-level challenges,
and dig deeper to identify root causes.
3. Management Programs
You can also use the "5 Whys technique to facilitate a robust conversation about root causes.
Outline of Procedure
As you implement your action plan, you should define the procedures that you will follow.
Procedures clearly systematize actions so that they become routine, daily processes and practices.
Procedures and work instructions can be communicated in different formats, such as text,
flowcharts, or pictograms. You should use the format that is most effective for your company staff.
The outline below includes the important components of a well-defined written procedure.
Title: Procedure X
A sample list of some of the relevant topics for specific groups is presented in the table below. You
should select the specific training modules for each of the target groups based on the relevant risks
and potential improvement opportunities.
ESMS team Introduction to IFC Performance Standards and the nine ESMS elements;
Environmental legal requirements; Identification and evaluation of
environmental and social risks and impacts; Root cause analysis; Stakeholder
engagement; Monitoring of performance indicators; Internal auditing;
Environmental and social reporting.
HR Department Introduction to ESMS and IFC Performance Standard 2 Labor and Working
Conditions; Hiring, non-discrimination, anti- harassment, remuneration and
other labor policies; Effective complaint management and resolution
procedures for workers; Worker-management interaction.
Workers and Introduction to ESMS; ESMS policies; Instructions on new or modified
Managers operational procedures relevant to the tasks performed (e.g. waste
management procedure; storage and handling of hazardous chemicals; use
and maintenance of PPE); Emergency response procedures; Instruction on
complaint management system; Worker-management interaction.
plans
Formulate ESMS manual (document
procedures)
Communicate environmental and social
performance targets to employees.
IMP
team
Define training program to ensure
implementation of new/improved procedures
Conduct awareness and training programs on
environmental, OHS, and labor issues.
IMP
engagement plan
(high probability,
(high probability, low high impact)
Probability of Occurrence
impact)
Low High
Severity of Impact
5. Emergency Preparedness and Response
2.0 Definitions:
2.1. EMERGENCY: Situation that poses immediate threat of:
a. Injuries and damage to health
b. Fatalities
c. Damage to property
d. Damage to environment
2.2. FIRE EMERGENCY: Situation that poses or signals immediate threat in the form of:
a. Uncontrolled fire or imminent threat of uncontrolled fire
b. Smoke or burning
c. Uncontrolled release or spillage of flammable or combustible substance
d. Sounding of fire alarm
3.0 Responsibility and Authority: This procedure is the responsibility of the operations manager
or designate. The operations manager shall report to the general manager in matters related to
emergency preparedness, and shall have total authority during emergency situations. The
operations manager shall have the authority to declare a state of emergency. In the absence of
the operations manager, these authorities shall revert to the general manager.
3.1. The EHS Manager shall:
a. Review and revise this procedure at least once a year;
b. Ensure that everyone is aware of their responsibilities as defined in this procedure;
c. Ensure that required fire detection, alarm and response equipment is present in all
designated areas;
d. Assemble fire brigades in each work area in accordance with the work area
supervisors;
e. Regularly schedule and deliver training to fire brigades;
f. Regularly schedule and organize evacuation drills in all work areas;
g. Analyze the results of drills (e.g. evacuation time) and take appropriate action.
3.2. The HR Manager shall:
a. Ensure that responsibilities as defined in this procedure are included in job
5. Emergency Preparedness and Response
descriptions.
3.3. The Maintenance Manager shall:
a. Regularly test all emergency equipment to ensure it is in working condition;
b. Schedule maintenance of emergency equipment by an approved contractor;
c. Take immediate action when equipment needs to be repaired or replaced.
3.4. The Work Area Supervisors shall:
a. Ensure that fire brigades participate in training;
b. Regularly remind workers of their responsibilities in the event of a fire;
c. Conduct a head count of workers gathered at muster points.
3.5. Fire brigades shall:
a. Participate in trainings organized by the EHS Manager;
b. Respond to the fire and provide medical aid as explained in the work instructions of this
procedure and in trainings.
3.6. All workers shall:
a. Participate in evacuation drills;
b. Immediately inform a member of the fire brigade or work area supervisor in the event of
a fire;
c. Evacuate the building through the nearest exit when the fire alarm sounds;
d. Gather at the designated muster points.
3.7. Other responsibilities as defined in the work instructions.
f. The telephone operator will remain on duty and serve as the information and control
center unless instructions or conditions dictate otherwise.
g. As soon as the electrical department is notified, the electrician shall cut off the power
supply of the affected area, bring the elevators (if available) down to the ground level
and provide an adequate lighting arrangement (with emergency lighting if extra light is
required) for firefighting or evacuation.
h. The maintenance department shall reach the fire hydrant pump room (if safe) for
smooth pump operation.
i. The work area supervisor (or the shift in-charge) will make appropriate decisions
regarding building evacuation and firefighting with the help of an internal trained team
and/or notifying the citys fire department.
4.2. BUILDING EVACUATION: It is essential to make decisions quickly and evacuate the
premises in order to prevent the loss of lives. The evacuation procedure should be handled
with expertise and without delay. When evacuation from the building is necessary,
everyone must leave through the nearest exit or as advised. In labor-intensive industries,
many people will have to be evacuated in a very short time. In the past, many workers in
the textile industry, for example, have lost their lives due to blocked or locked exists, or an
insufficient number of exits. Make sure exit routes can be used in case of an emergency.
a. Close but do not lock doors behind you as you leave the building.
b. Employees and visitors should gather near the designated muster point in a safe area
that is upwind from smoke or toxic gases and will not hamper emergency vehicles or
services when they arrive.
c. In order to ensure that everyone is accounted for, conduct a head count of all
employees and visitors.
d. Employees are not to re-enter the evacuated building until they are so advised by the
designated officer (operations manager or safety manager).
e. Only trained and competent personnel equipped with suitable PPEs can perform any
required rescue operations (for a trapped employee/visitor, for example).
4.3. MEDICAL AID: Treat all minor injuries with first aid, but remember that first aid is only
temporary. First aid provides the immediate treatment that is needed before a doctor can
reach the victim onsite, or before the victim can be transported to a doctor. What you do in
the critical moments after an injury occurs could save a life, so it is important to know the
basic first aid procedures. Review them often so you will be prepared if you suddenly find
yourself in an emergency situation. The most important thing to do when someone is injured
is to survey the scene to determine if the situation is safe, or if the victim must be moved
from a dangerous location to a safe place. Call for emergency medical help immediately for
all life-threatening situations and send people to guide the emergency team to the victim.
4.4. FIRST AID FOR FIRE INJURIES AND BURNS
a. Move patient to fresh air.
b. Move the patient from the heat of fire.
c. Do not allow crowding around the patient.
5. Emergency Preparedness and Response
5.0 Emergency Response Team: The purpose of the Emergency Response Team is to deal with
catastrophic accidents within the company. The teams responsibilities are to immediately meet
when an emergency situation is reported and to determine the course of action.
6.0 Reference Documents: Evacuation plan, plant map with locations of emergency exits,
firefighting equipment and first aid stations.
7.0 Records: Training logs, drill logs, firefighting and medical equipment maintenance and
inspection logs; water gauge and pressure inspections logs
2.0 Definitions:
2.1. Nature of the Spill: Determined by the level of risk from the hazardous substance and the
level of containment of the spill. One can distinguish between minor and major spills
2.2. Minor Spill: Limited risk to workers and environment. An example of a minor spill is a spill
of 5 ml of concentrated Sulfuric Acid, which is a small volume that can easily be neutralized
and removed.
2.3. Major Spill: Large risk to workers and environment. An example of a major spill is the
uncontrolled release of ammonia in an unventilated enclosed area. If the volume is large it
may represent a high risk to persons in the area.
3.0 Responsibility and Authority: This procedure is the responsibility of the operations manager
or designate. The operations manager shall report to the general manager in matters related to
emergency preparedness, and shall have total authority during emergency situations. The
operations manager shall have the authority to declare a state of emergency. In the absence of
the operations manager, these authorities shall revert to the general manager.
3.1. The EHS Manager shall:
a. Review and revise this procedure at least once a year;
b. Ensure that everyone is aware of their responsibilities as defined in this procedure;
c. Ensure that equipment for the containment and cleanup of leaks and spills, and
appropriate PPE, is present in all designated areas;
d. Ensure that MSDS and ICSC are available in all locations where hazardous chemicals
are stored or in use;
e. Identify workers responsible for handling or storing hazardous chemicals in accordance
with the work area supervisors;
f. Assemble Emergency Response Team;
g. Regularly schedule and deliver training (i) on the response to minor spills/leaks to
workers responsible of handling and storing hazardous chemicals, and (ii) on the
response to major spills/leaks to the Emergency Response Team;
h. Regularly schedule and organize evacuation drills in all work areas;
5. Emergency Preparedness and Response
i. Analyze the results of drills (e.g. evacuation time) and take appropriate action.
3.2. The HR Manager shall:
a. Ensure that responsibilities as defined in this procedure are included in job
descriptions.
3.3. The Operations Manager shall:
a. Ensure that workers responsible for handling and storing hazardous chemicals and the
Emergency Response Team participate in training;
3.4. Workers responsible for handling and storing hazardous chemicals shall:
a. Participate in trainings organized by the EHS Manager;
b. Respond to minor spills/leaks and provide medical aid as explained in the work
instructions of this procedure and in trainings.
c. Immediately contact the Emergency Response Team in case of a major spill/leak.
3.5. The Emergency Response Team shall:
a. Participate in trainings organized by the EHS Manager;
b. Respond to major spills/leaks and provide medical aid as explained in the work
instructions of this procedure and in trainings.
3.6. All workers shall:
a. Participate in evacuation drills;
b. Evacuate the building through the nearest exit when they hear the alarm;
c. Gather in the designated muster points, conduct a head count, and inform their
supervisor if someone is missing.
3.7. Other responsibilities as defined in the work instructions.
c. The telephone operator will contact public authorities when appropriate. Provide the
following information:
i. State that this is an emergency.
ii. Provide your name, telephone number and location.
iii. Provide the location of the incident.
iv. Provide the time and type of incident.
v. Provide the name and quantity of material involved.
vi. Note the extent of injuries, if any.
d. Evacuate personnel from the spill area.
e. Shut off equipment as you leave the area.
f. Direct personnel to the nearest fire exit. Do not use elevators.
g. Do not touch any harmful substance. Take precautions to protect yourself if necessary.
h. DO NOT go back in to an area where a chemical spill has occurred! Untrained rescuers
who do not wear proper protective equipment can be overcome by toxic or asphyxiating
fumes. Contact Operations manager and Lab Manager.
i. Close doors to prevent further contamination. Secure the area to keep non-emergency
response personnel away from danger.
j. The Emergency Response Team will isolate contaminated individuals and treat as
per MSDS or ICSC.
k. In conjunction with expert assistance, the Emergency Response Team will minimise
the spread of contamination and commence decontamination/clean up procedures.
4.3. MEDICAL AID: Treat all minor injuries with first aid, but remember that first aid is only
temporary. First aid provides the immediate treatment that is needed before a doctor can
reach the victim onsite, or before the victim can be transported to a doctor. What you do in
the critical moments after an injury occurs could save a life, so it is important to know the
basic first aid procedures. Review them often so you will be prepared if you suddenly find
yourself in an emergency situation. Follow the instruction on MSDS or ICSC.
a. Remove victims from spill area to fresh air (but do not endanger your own life by
entering areas with toxic gases).
b. Immediately remove contaminated clothing.
c. Flush skin or eyes with running water for 15 minutes.
d. Get medical attention for victims.
5.0 Emergency Response Team: The purpose of the Emergency Response Team is to deal with
catastrophic accidents within the company. The teams responsibilities are to immediately meet
when an emergency situation is reported and to determine the course of action.
5. Emergency Preparedness and Response
General Manager
Operations manager
EHS Manager
6.0 Reference Documents: Evacuation plan, plant map with locations of emergency exits, MSDS,
ICSC, and first aid stations.
7.0 Records: Training logs, drill logs, MSDS, ICSC, spillage containment and medical equipment
maintenance and inspection logs.
2.0 Definitions:
2.1. Emergency: Situation that poses immediate threat of:
a. Injuries and damage to health
b. Fatalities
c. Damage to property
d. Damage to environment
4.0 Work Instructions: The Emergency Response Centre (ERC) shall monitor the weather
conditions for potential flooding. The ERC shall keep track of weather conditions that may cause
flooding (e.g. approach of a typhoon or other natural storm) and alert the ERT members when
necessary. The ERC shall make a public announcement via the P/A system when a flood-
warning signal has been confirmed (both during and after office hours). Upon notification of a
flood warning, all personnel shall be advised to return indoors as soon as possible.
4.1. Flood Response Procedure
a. Pre-Flood Planning
i. Staff and train an emergency response team (ERT), whose members are willing
to stay on site during flooding (if safe to do so). Ask for volunteers. Arrange for
support/assistance during flooding for families of those who will remain at the
facility. Also, notify local emergency preparedness authorities about your plans to
have personnel on site.
ii. Designate a weather monitor, who will report weather conditions and keep the
ERT Coordinator up to date on conditions before, during and after a flood. Involve
local government and liaise with other businesses.
iii. Give the ERT Coordinator the authority to implement the plan, based on
predetermined checkpoints (e.g. when the approaching water is within a certain
distance from the facility). This responsibility includes shutting down operations
and sending personnel home.
iv. The ERT Coordinator shall ensure that the manager(s) carry out predetermined
tasks at each warning stage of a storm. To guarantee this, task checklists should
be distributed to all those involved, completed and returned to the ERT
Coordinator.
v. Assess levels of insurance coverage for flood damage.
vi. Install appropriate system to warn employees in real-time.
vii. Provide safe shelters or structures that can protect employees and designate a
safe evacuation route to them.
viii. Provide radio and communication systems and appropriate PPE.
b. Advance preparedness steps
i. Identify all critical areas of a facility, and make sure someone on all shifts knows
the proper shutdown procedures and is authorized to implement them.
ii. Maintain an updated list of telephone numbers and contacts for local emergency
response agencies and the industrial property insurance company. Contact local
authorities to plan and coordinate activities before the need for emergency action.
That way, both you and they will be better prepared.
iii. Arrange backup communications, such as two-way radios or cellular phones, and
5. Emergency Preparedness and Response
iv. Call in key personnel and notify contractors to start repairs. Make sure safety
systems are fully implemented before work is allowed to begin.
v. Begin salvage processes as soon as possible to prevent further damage: cover
broken windows and torn roof coverings, clear fallen trees.
vi. Clean roof drains and remove debris from roof to prevent drainage problems.
vii. Visually check any conductors and exposed insulators before restarting main
electrical distribution systems.
6.0 Emergency Response Team: The purpose of the Emergency Response Team is to deal with
any catastrophic accidents. The team should meet immediately when an emergency situation is
reported to determine the course of action.
5. Emergency Preparedness and Response
General Manager
Operations Manager
Shift-in-charge
EHS Manager
Doctor/Site Medical
Superintendent
ERT member 1
ERT member 2
ERT member 3
Neighbors
Transportation resources
7.0 Reference Documents: Evacuation, search and rescue plan, facility layout plan with locations
of emergency facilities.
8.0 Records: Training logs, drill logs, firefighting, rescue operations, and medical equipment
maintenance and inspection logs.
Stakeholder Engagement
Introduction
2. Create a list of all the relevant stakeholders for your company. Relevant stakeholders
include: stakeholders who are directly and indirectly affected by your company;
stakeholders who have an interest in your company operations; stakeholders who may have
complaints or concerns related to your operations; stakeholders who have an ongoing
relationship with the company; and stakeholders who can influence your company
operations. You should be as specific as possible in your list. For example, you should list
each of your main clients and suppliers independently, and disaggregate communities by
identifying legitimate local leaders or other relevant actors.
3. Discuss each stakeholder group and record each ones key concerns, issues and interests
related to your company.
STAKEHOLDER ISSUES/CONCERNS/INTERESTS
4. Place these stakeholders on the stakeholder map according to the degree to which they are
impacted by your operations and their capacity to influence your company operations.
Quadrant 1= Quadrant 2=
Involve as needed Proactively
High
approach and
Capacity to Influence
support them
Quadrant 3= Quadrant 4=
Keep them Respond to their
informed concerns
Low
Low High
5. Categorize the stakeholders according to their current relationship with your company:
supportive, supportive with conditions, neutral, negative. Stakeholder engagement
should serve to maintain positive relationships with supportive stakeholders and help you
address the concerns of less-supportive stakeholders. Remember, stakeholders
relationships with the company can change over time. We recommend that you conduct this
type of analysis periodically to ensure that you are engaging with your stakeholders
appropriately.
6. Prioritize your stakeholders for engagement.
7. Create strategies to engage with the prioritized stakeholders. As you determine your
engagement strategies, keep current initiatives of the company in mind. You should also
create tiered engagement strategies for stakeholders in each of the four quadrants on the
stakeholder map.
Source: Strategic Community Investment: A Good Practice Handbook for Companies Doing Business in
Emerging Markets. IFC (2010).
6. Stakeholder Engagement
A quick and practical technique for identifying affected communities is through an Impact Zoning
Map (see box below). By mapping your companys sphere of influence for different types of
environmental and social impacts, you can begin to identify distinct groups by impact area. You can
then use that information to prioritize the key stakeholders for consultation.
You should assign priority to individuals and groups who are directly adversely affected by your
companys activities; however, it can be challenging to distinguish between who is directly affected
and who is not. Communities that live just outside of your designated impact area can still feel that
they are impacted by your company, and may feel they have been arbitrarily excluded from the
engagement process.
1. Draw a sketch map of the key design components of the project, both on- and
off-site, that may give rise to local environmental and social impacts (e.g. land
area used/affected; air and water pollution receptors, etc.). This may be
performed more efficiently by using aerial photographs or satellite images.
2. Identify the broad impact zones for each of these components (e.g. the area of
land take, air and water pollution receptors, etc.).
3. After identifying and mapping broad stakeholder groups, overlay those groups
with the impact zones.
4. Through consultation with legitimate stakeholder representatives, verify which
groups are potentially affected by which impacts.
Source: Doing Better Business Through Effective Consultation and Disclosure. IFC (1998).
6. Stakeholder Engagement
The table below provides examples of stakeholders that may be impacted by, or may influence,
your operations. Once you have created a stakeholder map and identified the concerns, you can
create an engagement plan and determine the engagement method, the necessary information to
be disclosed or reported back to your stakeholders, and the key information you would like to obtain
from your stakeholders.
Grievances Log
7. External Communications and Grievance Mechanisms
KEY ASPECTS OF
EFFECTIVE GRIEVANCE COMPANYS METHOD
MECHANISMS
Provide ease of access Form and instructions on website that people can fill in and submit
to confidentially online.
communicate or file Email address.
complaints, including Telephone hotline.
anonymous ones Suggestion boxes located outside the company gate and in strategic
places (e.g. in churches, municipality, and civic centers).
Weekly visits by a designated community liaison to affected
villages or other stakeholders to record complaints or concerns.
Publicize the system so Distribute brochures at churches, schools and civic centers,
that stakeholders know it highlighting the companys profile and operations. The brochures
exists and how to access should include instructions for external stakeholders to communicate or
it file complaints, and explain your companys procedures for handling
complaints.
Hold a meeting with community leaders and other stakeholders for
the general manager/designated community liaison to explain your
written procedures.
Be transparent about the Summarize all cases in detail include information about whether the
process and outcomes complaint was accepted, and provide information about the process
and timeline for investigation and resolution of the case.
Post case summaries on the company website and/or report back
to the complainant through a letter/email/community liaison.
Implement a predictable Assign an employee or team to record complaints and work with
and defined process that the relevant staff and external stakeholders to investigate
includes assignment of complaints, determine the necessary actions in response, and
responsibility, time limits report back on the outcomes.
and monitoring of
outcomes
Make the system a Management team periodically reviews complaints and the complaint
source of continual system to monitor the effectiveness of the system and integrate results
learning into the companys systems.
Company conducts perception surveys among affected
stakeholders to learn about their awareness of the mechanism,
and to assess the perceived trustworthiness of and ease of
access to the grievance mechanism and its outcomes.
7. External Communications and Grievance Mechanisms
Grievances Log
Instructions:
You should keep a logbook or database of grievances in order to monitor their progress towards
resolution. This tool will also enable you to analyze the grievance information and use it to improve
your operations and proactively prevent future concerns. This log illustrates the type of information
that is useful to record about each grievance.
1. GRIEVANCE IDENTIFICATION
NUMBER
2. DETAILS OF COMPLAINT
3. PROFILE OF COMPLAINANT(S)
3.1 Gender
3.2 Age
4.2 Phone
4.3 Email
4.4 Address
Other
Odor
Noise
Effluents
Company vehicles
Security personnel
Other
Monitoring Plan
Auditing Guidance
9. Monitoring and Review
Monitoring Plan
Instructions
Your monitoring plan will help you determine if your action plans and improved procedures are
achieving your established objectives. A sample template for developing a monitoring plan is
presented below.
PERFORMANCE INDICATORS
Performance Indicators Monitoring Protocol Monitoring records
What parameters How frequently will you collect How will you
will you monitor to samples? know if you are
determine your working towards
What methods, tools, and
success? that indicator?
equipment will you use to collect
For example, and analyze samples? What records
cholinesterase levels for will you maintain
workers exposed to What standards or benchmarks will
and review?
pesticides. you use to establish acceptable
values?
Who will be responsible to collect,
analyze, and act upon the data?
PROCESS INDICATORS
Processes Indicators Monitoring records
What will you monitor to How will you know if you are working
evaluate progress against your towards that indicator?
action plan?
What records will you maintain and
For example, the percentage of pesticide review?
applicators that can explain the work
instructions for handling pesticides.
9. Monitoring and Review
Auditing Guidance
Instructions
This auditing guidance provides a comprehensive overview of the steps that an auditor would take to
assess various aspects of your business. You should review this auditing guidance to gain insight into
the types of issues and questions that auditors consider. This will broaden your view of potential risk
areas and elements of the ESMS beyond those that you may have targeted in your initial risk
assessment.
A. PREPARATION
Collect audit and inspection reports on the companys environmental and labor performance for the previous
two years.
Collect corrective action plans generated from previous audits or inspections and review the status of each
action item that was agreed upon. Are they all closed out? Focus your review on open items and the
underlying factors that prevent you from completing the corrective action plan.
Ascertain the general level of PPE use on the organization. Ensure that auditors wear the same PPE as
employees are required to wear: head, hearing, eye, skin protection, protective boots, clothing, etc. Do not
allow any auditor to enter work areas without the clothing/gear required for the operations activity and that
employees are required to wear.
Obtain site plans for all the relevant operational areas. Ensure auditing team has a working knowledge of the
operations to be evaluated.
Research and refer to current local environmental and labor laws and regulations.
Basic labor code issues: (i) regular weekly work hours, (ii) labor contract provisions, (iii) rest periods, lunch,
etc., (iv) overtime requirements, limits and exceptions, (v) hour averaging and banking hours, (vi) minimum
wage, (vii) social system payment liability, (viii) annual leave, (ix) laws to protect disadvantaged workers, (x)
severance pay.
Basic environmental code issues: (i) wastewater, (ii) storm water, (iii) spill prevention and response, (iv)
construction/demolition/remodeling, (v) hazardous materials, (vi) hazardous waste, (vii) toxic chemical
release, (viii) air emissions, (ix) solid waste.
Review regulatory permit(s) conditions and specific requirements along with most recent review and
corrective action reports.
Review certification(s) audit reports (e.g. ISO 14001, OSHAS 18001, BSCI or SA8000) for nonconformance,
mandatory remedial actions, recommendations, etc. Summarize status of items (open or closed).
Review the stakeholder engagement plan and records of grievances by external stakeholders. Pay attention
to: emergency preparedness and response capability to include the community if necessary; use of
chemicals and accidental releases of hazardous materials affecting community, e.g. dyes and chlorine;
discharges of wastewater or other wastes to areas affecting local communities; exacerbation of flooding;
limits of water availability use and physical access; diminution of quality of life due to the operation.
Research and understand the national and local context of labor union rights and activity, local environmental
groups and community activist organizations.
Schedule sufficient time to conduct the scope of the audit. Announce the availability of confidential meeting
schedules with employees; schedule, arrange and conduct while protecting employee confidentiality.
Meet with the senior management and department managers before conducting audit activities to review
ESMS issues and the purpose of the audit.
Share an agenda and itinerary for the meeting with senior management and local supervisors.
With department managers, review the prior audit reports and performance to date in meeting corrective
actions.
Discuss non-retaliation against cooperating workers; inform management that future audits will include
reviews of the continued employment of workers interviewed.
C. OPERATIONAL WALK-THROUGH
Conduct operational walk-through following production processes. Refer to previous relevant physical walk-
through assessments of the facility; determine if all previous nonconformance/action items are closed out - if
not, why not?
Minimize the number of managers and supervisors that accompany you on the walk-through. One or two
escorts of non-supervisory staff based on knowledge/responsibilities are usually sufficient.
During the walk-through, be aware of your body language and the message this sends to workers; ensure
that you are equipped with/wearing the same PPE required of employees.
Verify that fire exits in buildings (e.g. storage or maintenance areas, administrative buildings, etc.) exist and
open on demand; no means to prevent exit; panic bars in good working order; clear egress once exit opened;
emergency exits clearly marked; nearest exits clearly marked; hose cabinets equipped with hoses, nozzles,
etc.; prohibited areas clearly marked; electrical cabinets closed and sealed; lockout/tag-out procedures and
tools (tags, locks, warning labels and signs) clearly available near electrical cabinets; first aid cabinets and
equipment; emergency lighting; emergency preparedness and evacuation plans in place; and that employees
are trained on using these.
Ask an employee to show you how to get out, assuming that there is now a fire; follow the employee; ask
another to tell/show you what happens if he/she was just injured.
Indoor working conditions should be verified for adequacy if there is potential for risks such as heat, light,
noise and dust. Use measuring devices to determine air quality, noise level, and temperature.
Following the walk around, conduct a walk-through of the dormitory facilities, canteens, washrooms and
changing rooms (if relevant). Note the condition and adequacy of these areas.
Suggest best practice to supervisors and managers during the walk-through; ensure that the suggestion is
filtered by processes/operations practicalities.
Give sufficient attention to all ESMS elements during the operation/dormitory walk-through. Knowledge of
procedures, training using the procedures, awareness of complaints management and resolution procedure,
employment rights, HR policy and provisions, etc.
Pay special attention to areas identified in previous corrective action requests. Focus on open non-
conformances from previous audits: why did they occur? Elucidate the underlying cause and make an effort
to diagnose and prescribe preventive and ameliorative measures. The individual who is responsible for the
item is not as important as why it occurred and how the company can prevent non-conformances and
unplanned events in the future.
D. INTERVIEWING WORKERS
Select at least 5 percent of workers, max. 100 workers. Conduct individual and group interviews for balanced
response.
Select workers who are representative of the workforce population (gender, race, age, religion, functional
departments, etc.).
If the factory has contracted or migrant workers, make sure to include them as well.
Do not allow supervisors or managers to influence selection of workers for interviews or the interviews.
Conduct on-site interviews in areas that protect worker confidentiality and where the worker would feel
comfortable. Make sure supervisors or managers are not in or near the space where the interviews are
conducted. Keep them away from the selection and interview process.
Make sure to tell the workers that everything they say is confidential and that management has been warned
against retaliation.
Plan for an average of fifteen minutes per interview; however, use common sense in terminating interviews
that are becoming nonproductive and extending interviews with people who are candid or openly addressing
critical issues.
Formulate questions prior to the interviews to make sure you cover all specific areas of the ESMS review
through the aggregated interviews. Always ask employees how processes may be improved, water use
reduced, energy saved, waste reduced, etc.
If you plan to take notes, ask the workers if it is OK and clearly explain reason for taking notes. Try to
minimize note taking as much as possible during the interview. Finish writing your notes immediately after
the interview, so you have accurate documentation.
Have your worker representatives recommend a preferred approach to building rapport with workers.
Ask workers specifically about follow up on previous corrective action plans. What non-conformances remain
open; what issues presented through the complaints management and resolution mechanism remain open?
Is the environment comfortable to work in, in terms of temperature, exposure to heat and sun?
Do they feel that chemicals, waste and other substances are stored or disposed of safely and
appropriately at the facility? Is there sufficient access to Material Safety Data Sheets (MSDSs)
and/or International Chemical Safety Cards (ICSCs) and appropriate training in their use? What is
the managements response to any expressed issues through the complaint management and
resolution mechanism?
If the organization employs contract workers, make sure to ask questions that address possible violations
and areas of abuse. Do you feel different from a permanent employee? Why?
Conduct some worker interviews off-site if possible.
The stakeholder mapping exercises and stakeholder consultation meetings should help identify the relevant
population that is affected by the facility and its activities.
Select a sample of individuals that represent the views of this affected community. This group may include
members of the public as well as NGOs, campaign groups, trade unions, local businesses and government
authorities. If possible, target NGOs that are industry-specific. Seek out former employees if possible, but
filter out disgruntled former employees or those with a personal agenda against the company.
Gauge awareness of the grievance mechanism. Has it been tested? Does it work? Does the company
utilize it in practice or ignore it? Is it taken seriously?
LABOR ISSUES:
Make sure you review the relevant documents for the following areas:
1. Human resources: Management-worker committee meeting minutes, memos and letters, budgets
related to implementing labor policy, training material, logs and curricula or written communications to
workers that address all issues, training records and instructor qualifications.
2. Working conditions: Contracts for all workers; policies and procedures related to wages, benefits, hours
and leave; evidence of communication and training on wage calculation; personnel files; time cards;
payroll records and pay stubs (selected without management interference); criteria used to set
performance pay bonuses; and employment and termination records.
3. Are employees payment methods secured? Can employees opt to have payments deposited into an
account? Are employees paid in cash at the facility (which can lead to significant risks during their
commute)?
4. Collective bargaining: Collective bargaining policy, agreement and documentation (such as minutes and
records of collective bargaining sessions).
5. Discrimination: Discrimination policy; related procedures; documentation handling discrimination issues;
diversity training and attendance log; hiring, promotion and termination records; gender demographics in
facility at worker and manager levels.
6. Retrenchment: Policies and procedures for workforce reduction, severance and transition;
documentation of prior workforce reductions; minutes of management meetings and communications to
workers on this issue.
7. Complaint management and resolution mechanism: Documented procedure, communications, records
and logs of grievance handling.
8. Child labor: Procedure for age verification, documentation of apprentice program, birth and medical
records and school records of workers.
9. Forced labor: Employment contracts (as well as for those workers hired through recruitment agencies),
payroll records, timesheets and wage deduction, worker passports and IDs.
10. Health and safety: Accident and medical treatment logs, equipment safety logs, logs of fire and safety
drills, health and safety risk analyses, government health inspection reports, safety certificates and
training curriculum and logs, and evidence of changes to all of this when company processes, methods,
chemicals, materials are changed, reordered, etc.
Select files and/or records at random to generate a representative sample of the workforce population and
functional distribution in the factory. Seek some files to corroborate interviews conducted earlier.
Balance your time and effort investigating all areas of labor standards at work. Document review is
particularly critical for wages, working hours, health and safety, use of sub-contractors, hiring and termination.
If the operation employs contract workers, address potential areas of abuse in the document review.
Specifically review the contract with the workers.
Identify all significant incidences of non-conformance in preparation for your management meeting.
Make sure you review the relevant documents for the following areas:
1. Emergency response and preparedness: Examine the facility's emergency response procedures and
9. Monitoring and Review
accident reports, as well as documents indicating that workers have been trained on these issues.
2. Environmental management: Examine any company environmental policies and environmental
management system policies and reports, including sustainability reports, energy consumption records,
guidelines and monitoring, resource use and waste generation. Note the status of previously identified
non-conformances.
3. Insurance: Identify documents that indicate legal permits have been obtained, insurance policies are in
place and the relevant legal authorities notified of the facility's activities.
4. Technical: Documents on production processes, and storage, purchase and maintenance of facility
equipment. Availability of MSDS/ICSCs and employee training and orientation to the specific risk posed
by materials in use; response to submissions through the complaint management and resolution
mechanism.
5. Waste disposal: Policies, procedures and guidelines on elimination and recycling of waste emissions
and effluents to air, water and land, including monitoring of the quantity and quality, treatment and
disposal of all waste, including wastewater and solid waste; are employees/area supervisors queried for
opinions on improvements?
6. Hazardous material: Inventory of chemicals and toxicology sheets (MSDS/ICSCs from
ILO/WHO/EU/UNEP, etc.). Avoid total reliance upon manufacturer's statements. Does procurement
mandate furnishing such materials (MSDS/ICSC)?
7. Health and safety: Check for the existence of logs of accident and fatality rates and monitoring of these
statistics; health and safety guidelines or handbooks for workers; job hazard analyses and engineering
corrections to eliminate hazards at the source, as opposed to requiring employees to mitigate
environmental hazards; provision of appropriate PPE that cover actual, defined technical, physical,
biological and chemical hazards in the workplace; records of OHS Committee meetings, training, Tool
Box safety meetings, etc.
8. Work environment: Look for guidelines, reports, logs and "ecomaps" of the facility work environment that
monitor emissions of dust, odors, sources of noise and vibrations and worker exposure to heat and cold.
LEL meters and audible and visual alarms are mandatory wherever there may be accumulations of dust
or ambient dust.
Present your preliminary findings with particular emphasis on the positives as well as areas for improvement
and why. All new and previously existing non-conformances must be addressed. Seek clarification on any
findings or issues raised during the audit.
Work with the department managers and supervisors on a corrective action plan that details specific actions
to be taken and timelines for their completion.
Go over any outstanding corrective action requests from previous audit reports.
Make sure senior management signs off on the corrective action plan.
Address:
Copyright
The material in this publication is copyrighted. IFC encourages the dissemination of the content
for educational purposes. Content from this publication may be used freely without prior
permission, provided that clear attribution is given to IFC and that content is not used for
commercial purposes.
November 2015