Title: ENVIRONMENTAL MANAGEMENT PLAN
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MARGINPAR GROUP ENVIRONMENTAL MANAGEMENT PLAN (EMP)
Marginpar Group has established an Environmental and Social Management System (“ESMS”) to
evaluate risks and impacts associated with our operations and monitor ongoing Environmental,
Social and Governance (“ESG”) performance (ESMS00 Marginpar Group ESMS Framework). This
EMP has been developed specifically for Marginpar Group and provides the management measures
to ensure the successful implementation of the Marginpar Group ESMS. The EMP has been compiled
as a guideline for the mitigation and management measures to be implemented to avoid, reduce and
minimise potential environmental impacts arising out of our operations.
ESG Policy
Marginpar Group has developed an Environmental, Social and Governance (ESG) Policy (ESM01
Environmental, Social and Governance Policy Statement) which outlines our commitment to
compliance with relevant national legislation and international standards, and to continual
improvement in terms of our ESG performance.
Legal and Other Requirements
This EMP has been compiled to ensure that our operations are aligned with applicable Kenyan and
Ethiopian legislation governing environmental management, and specifically the Kenyan
Environmental Management Act (EMCA, 2015) and associated policies and regulations, the
Environmental Policy of Ethiopia (EPE) and related legal proclamations. Both the Kenyan (Article 42,
69 and 70) and Ethiopian (Article 44 and 92) constitutions enshrine that every person is entitled to a
clean and healthy environment in accordance with the Constitution and relevant laws and has the duty
to safeguard and enhance the environment.
EMCA, 2015 and EPE state that every person is entitled to a clean and healthy environment which
includes the access by any person in Kenya to the various public elements or segments of the
environment for recreational, educational, health, spiritual and cultural purposes. They also require for
every person (entity) to cooperate with state organs to protect and conserve the environment and to
ensure the ecological sustainable development and use of natural resources.
EMCA 2015 and EPE establish a general framework for environmental law, in part by prescribing
national environmental management principles that must be applied when making decisions that may
have a significant impact on the environment. Marginpar Group is committed to apply these principles
to our operations.
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Title: ENVIRONMENTAL MANAGEMENT PLAN
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The environmental management principles to which we subscribe include but are not limited to;
•
The principle of public participation in the development of policies, plans and processes for
the management of the environment;
•
The cultural and social principles traditionally applied by any community in Kenya for the
management of the environment or natural resources in so far as the same are relevant
and are not repugnant to justice and morality or inconsistent with any written law;
o
The principle of international co-operation in the management of environmental
resources shared by two or more states;
o
The principles of intergenerational and intragenerational equity;
o
Holistic Principle;
o
Sustainable development;
o
Best Practicable Environmental Option (BPEO)
o
Preventative Principle
o
The Precautionary Principle
o
Duty of Care Principle
o
Cradle to Grave Principle
o
Polluter Pays Principle
In additional to legal compliance, Marginpar Group is committed to alignment of our operations
with International Standards of Best Practice wherever possible. This includes but is not limited to;
•
The International Finance Corporation (IFC) Performance Standards;
•
The World Bank Environmental, Health and Safety (EHS) guidelines;
The Marginpar Group ESMS as well as this EMP have been compiled to ensure alignment of our
operations with these standards.
Resources, Roles, Responsibility and Authority
This EMP identifies roles and responsibilities for the implementation of the specific management
plans and procedures described. Ultimate responsibility for the ESG performance of Marginpar
Group lies with the senior management team and, specifically, the Chief Executive Officer (CEO).
However, all of Marginpar Group’s employees are required to be aware of and comply with this
EMP which shall be included in the awareness training programme.
Implementation and maintenance of the EMP is the responsibility of Marginpar Group ESG
Manager. The ESG Manager reports to, and receives the support of, Marginpar Group’s senior
management on the performance of the ESMS. Marginpar Group has and will continue to ensure
that resources are available to implement and maintain this EMP.
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Title: ENVIRONMENTAL MANAGEMENT PLAN
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Inspections, Audits and Reporting Procedures
The adequacy of the implementation of environmental policies, plans and procedures shall be
identified and managed through the following four key activities including;
•
Inspections of the site and activities across the site;
•
Monitoring of selected environmental quality variables;
•
Audits of the site and relevant documentation as well as specific activities;
•
Reporting to Senior Management.
Marginpar Group shall maintain an environmental non-conformance and incident register to
monitor any reported environmental concerns, incidents, and non-conformances.
Reporting is essential for conveying information from the compliance monitoring activities and to
ensure that management is able to take rapid corrective action should non-compliance be
identified or where additional management measures are required.
All audits and inspections must be accompanied by applicable records and evidence (e.g. delivery
slips, photographic records, etc). All reports must be retained and made available for inspection by
management and external auditors where required. All reports shall be signed by the relevant
parties to ensure accountability. Marginpar Group shall make use of the inspections and audits to
continually ensure that environmental policies, plans and procedures are working effectively on site
through a system of self-checking.
Non-compliance with the EMP or any other environmental legislation, specifications or standards
shall be recorded in the non-conformance register. This register shall be sent to the COO on a
regular basis (Monthly), and the COO shall ensure that the responsible party takes the necessary
corrective actions. Non-conformances may only be closed out in the register with signoff from
Senior Management. Upon confirmation that adequate corrective action has been taken. The
register should be utilised to measure overall environmental performance.
Record Keeping
It is essential that an official procedure for control of records be developed to ensure records
required to demonstrate conformity to environmental and social standards are maintained.
Marginpar Group has implement procedures for the identification, storage, protection, retrieval,
retention and disposal of records as part of the ESMS. Records must be legible, identifiable and
traceable.
Management Review
Monitoring the implementation and effectiveness of the EMP is ultimately the responsibility of the
ESG Manager. Marginpar Group management shall ensure that the EMP is reviewed and updated
as required to endure its continued effectiveness. Any revisions to the EMP must be approved by
the Chief Executive Officer before implementation.
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Title: ENVIRONMENTAL MANAGEMENT PLAN
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Identification of Risks and Impacts
Marginpar Group has established a procedure for the identification of the ESG risks and potential
impacts of its activities, as well as the activities of its contractors, suppliers and customers that it
has some control or influence over (ESMS Risk/Impact Identification Procedure).
Risks and impacts are recorded and evaluated in an ESG Risk/Impact Register (ESM03
Environmental, Social and Governance Risk/Impact Register) to identify significant risks/impacts
and the management actions (preventative and/or management measures) required. Identification
of risks and impacts is an ongoing process; the ESG Risk/Impact Register will be
reviewed/updated at least annually, as well as in the event of any changes in operations, e.g. the
involvement of a new contractor/supplier, changes in Marginpar Group services or products and/or
changes in Marginpar Group operational activities.
To ensure the purpose of this EMP will be achieved, the environmental management plans which
follow have been established as follows:
•
Objectives to be achieved
•
Management strategies
•
Tasks
•
Responsibilities
•
Frequency
•
•
Monitoring and reporting
Corrective actions
The following environmental issues that require environmental management plans based upon the
potential impacts of activities by Marginpar Group are as follows:
1.
Air Quality
2.
Energy Management
3.
Waste Management
4.
Water Quality
5.
Sewerage and Sanitation
6.
Hazardous substances Management
7.
Pest Control
8.
Emergency Preparedness and Response
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Title: ENVIRONMENTAL MANAGEMENT PLAN
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Air Quality Management Plan
The main source of pollution to be managed is dust from farming activities and airborne chemicals
from crop spraying.
Performance Objectives:
To minimize the impact to air quality from site operations.
Management Strategies:
a) Use of improved technology where economically feasible.
b) Ensure use of appropriate PPE
c) Evaluate the effect of air emissions where appropriate.
Tasks: The following actions will be undertaken to implement the above management strategies:
a)
EMP awareness training to be included as part of inductions.
Responsibilities:
This EMP is the responsibility of the ESG Manager of Marginpar Group. The actions outlined in this
plan are the responsibility of management, farm manager and employees.
Performance Indicators:
1. Zero complaints relating to air quality management.
Monitoring and reporting any complaints as to the management of onsite air quality will be directed
to the ESG Manager of Marginpar Group as soon as practicable. Complaints and any actions
arising from a complaint will be recorded in a complaints register to be maintained by site
management.
Corrective Actions: maintain complaints register
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Energy Management Plan
The energy management plan is aimed at minimizing electricity use. The main sources of electricity
use are:
•
Lighting
•
•
Site machines & equipment
Office and building blocks
Performance Objectives:
To minimize electricity usage on site.
Management Strategies:
1.
Monitor energy usage to determine high-use areas.
2.
Establish areas of wastage.
3.
Install energy management systems where economically viable.
4.
Take energy rating into account when purchasing new equipment.
Tasks:
The following actions will be undertaken to implement the above management strategies.
1.
Undertake EMP awareness training as part of inductions.
2.
Maintain energy control systems.
3.
Use energy efficient and low energy technology like LED for lighting
Responsibilities:
This EMP is the responsibility of the ESG Manager of Marginpar Group. The actions outlined in this
plan are the responsibility of management, foreman and employees.
Monitoring and Reporting:
Any complaints as to the management of onsite energy usage will be directed to the CEO of
Marginpar Group as soon as practicable.
Complaints and any actions arising from a complaint will be recorded in a complaints register to be
maintained by site management.
Corrective Actions:
Undertake energy monitoring and establish where and how increased usage in electrical energy has
occurred.
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Title: ENVIRONMENTAL MANAGEMENT PLAN
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Waste Management Plan
Performance Objectives
Marginpar Group is committed to waste minimisation and shall incorporate reduction, recycling, reuse and disposal where appropriate. Any solid waste shall be disposed at a registered Municipal
Dumpsite through a National Environment Authority (NEMA) registered waste collector and
transporter as per the Waste management regulations of 2006.
Waste minimisation strategies shall be implemented in order to reduce unnecessary
costs/expenditure as well as to minimise our environmental footprint. Implementing waste
minimisation practices should deliver economic benefits. These may include reduced costs for raw
materials, storage, handling, waste treatment and disposal. In addition there will be benefits to the
environment and public health. Furthermore, direct costs from recycling efforts are returned to the
labour force as an incentive to perform this activity (positive reinforcement).
Our waste management objectives may therefore be summrised as follows;
1.
To meet the objectives of the Kenyan Environmental Management and Coordination Act, 2015
Amended, Waste Management Regulations of 2006 and EPE,
2.
To minimize waste generation by developing strategies for the management and disposal of
all waste produced in accordance with the principles of reuse, recycling and disposal of waste.
3.
To manage waste in a manner that is sustainable and sensitive to the environment.
Cradle to Grave Principle
Marginpar Group shall apply the cradle to grave principle in terms of waste management in
compliance with the EMCA, 2015. “Cradle to Grave” refers to the responsibility a company takes for
the entire life cycle of a product, service or program, from design to disposal or termination.
Management Strategies:
1.
Waste will be separated at source where possible to minimize contamination and maximize
potential for reuse and recycling of materials.
2.
Waste will not be stored on areas where it could contribute to the generation of contaminated
runoff.
3.
Waste management will form part of the onsite induction process.
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Tasks:
The following actions will be undertaken to implement the above management strategies.
1.
The main wastes likely to be produced onsite are papers, boxes, plastic bags, plastic
containers, and food products. Waste shall be sorted into reusable, recyclable and nonrecyclable waste according to the following waste streams;
• General waste. General waste is defined as consisting of non-hazardous substances and
substances that cannot be recycled. Marginpar Group generates general waste mostly in
the form of packaging materials including plastic.
• Organic Waste. Any waste food items (e.g. waste from canteen) shall be stored in a
separate skip for appropriate disposal. Waste from flowers will be reused after composting.
• Recyclable waste. Recyclable materials such as cardboard, paper, tins and glass.
• Hazardous waste. Hazardous waste includes substances such as hydrocarbons (e.g. used
oil), harmful chemicals and other dangerous goods (including used oil, diesel, grease,
lubricants etc), pesticide and fungicide and hazardous waste containers. Marginpar. Such
waste will be disposed in accordance to the country legislation.
2.
All waste storage shall be on kept in specified waste areas within the farms. General waste
shall be stored temporarily within waste skips.
3.
Marginpar Group shall ensure that all waste storage areas are inspected regularly and waste
storage skips/storage areas shall not be allowed to exceed the designed capacity.
4.
Recyclable waste shall be stored in a dedicated storage area. Under no circumstances shall
any non-recyclable waste be stored in this area. Recyclable waste shall be collected on a
regular basis for recycling.
5.
All general waste will be transported offsite by a registered waste removal contractor for final
disposal at a registered facility. Waste disposal certificates will be required from contractors to
ensure appropriate waste disposal.
6.
Any hazardous waste which may be generated on site will require precautionary measures
when handled and shall be dealt with in accordance to Kenyan and Ethiopian legislation and
standards. Hazardous waste may only be disposed of at a licensed hazardous waste disposal
facility. A specialist waste contractor shall dispose of such waste and shall be required to
provide waste manifests and safe disposal certificates. The ‘cradle-to-grave’ principle must be
complied with.
7.
Littering is strictly prohibited. Marginpar Group shall ensure that site remains in a neat and tidy
condition at all times.
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Responsibilities:
ESG Manager
Performance Indicators:
•
Compliance with Kenyan and Ethiopian legislation and applicable standards
•
Zero complaints about waste storage or removal.
Monitoring and Reporting:
Any complaints as to the management of onsite waste nuisance will be directed to the CEO of
Marginpar Group as soon as practicable. Complaints and any actions arising from a complaint will
be recorded the complaints register to be maintained by site management.
Corrective Action:
Marginpar Group will recommend corrective actions
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4.
Water Management Plan
The water management plan is designed to manage sediment and process water usage and waste
water.
Performance Objectives:
To comply with country, county and state laws and by laws on water usage, Water Resource
Management Authority (WRMA) regulations on water abstraction and usage and Environmental
Management and Coordination Act 2015, Water Quality regulations of 2006 and Environmental
Policy of Ethiopia and Ethiopian Water Resources Management Proclamation, 2000
Management Strategies:
The performance objective above will be achieved by the following management strategies.
1.
Divert clean storm water runoff from site to prevent from entering operations area or
neighbouring farms / properties
2.
Ensure waste is located in areas which will not contaminate surface water runoff.
3.
Ensure discharge of process water meets waste requirements.
Tasks:
The following actions will be undertaken to implement the above management strategies.
1.
Monitor storm drain discharge water to ensure that Kenyan and Ethiopian waste water
standards are met.
2.
Undertake EMP awareness training at inductions.
Responsibility:
•
The EMP is the responsibility of the ESG Manager.
•
The actions outlined in this plan are the responsibility of ESG Manager, relevant management
team member, and employees.
Performance Indicators:
No contaminated runoff.
Monitoring and Reporting:
•
•
Any complaints as to the management of onsite waste nuisance will be directed to the ESG
Manager of Marginpar Group as soon as practicable.
Complaints and any action arising from a complaint will be recorded in a complaints register
to be maintained by site management.
Corrective Actions
Investigate any non-complying runoff.
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5.
Sewerage and Sanitation
Sewerage waste generated on site will be monitored to ensure it does not contaminate underground
water.
6.
Hazardous substances Management
Marginpar Group uses a significant amount of hazardous substances.
Tasks:
1.
Marginpar Group shall ensure that any containers in which hazardous substances (e.g.
pesticides, fungicides, etc) are stored shall be clearly marked as to the contents therein. The
storage of such hazardous substances shall be confined to specific and secured areas.
2.
Appropriate measures must be implemented to prevent spillage during use of hazardous
substances.
3.
Any excess or waste material or chemicals should be removed from the site and should
preferably be recycled. Any waste materials or chemicals that cannot be recycled shall be
disposed of at a suitably licensed waste facility.
4.
Marginpar Group shall ensure that all relevant personnel on site are properly trained
concerning the proper use, handling and disposal of hazardous substances. If required, advice
shall be obtained from the manufacturer with regard to the safe handling and storage of
hazardous materials.
7.
Alien Vegetation Management
Marginpar Group shall implement an alien vegetation management programme which shall aim to
eradicate and control alien vegetation on the properties under the control of Marginpar Group.
Control involves killing the alien plants present, killing the seedlings which emerge, and establishing
and managing an alternative plant cover to limit re-growth and re-invasion.
Tasks:
1.
Weeds and invader plants will be controlled in the manner prescribed for that category by the
relevant legislation in the respective countries;
2.
Institute an eradication/control programme for early intervention if invasive species are
detected, so that their spread to surrounding properties can be prevented,
3.
Institute a monitoring programme to detect alien invasive species early, before they become
established and, in the case of weeds, before the release of seeds.
4.
Any action taken to control weeds or invader plants must be executed with caution and in a
manner that will have minimal environmental impact. Alien vegetation shall be disposed of in a
responsible manner so as to prevent the potential for further dispersal or establishment of alien
vegetation.
5.
The use of herbicides shall only be considered if alternative methods are not feasible or
practical. Application of herbicides shall only be undertaken by a suitably qualified individual in
accordance with the relevant regulations. Herbicides shall only be administered by a registered
Pest Control Operator (PCO).
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8.
Pest Control
Marginpar Group shall ensure that waste management procedures minimize the potential for
attraction of pests. Where required, pest control shall be undertaken by a registered service provider.
9.
Environmental Awareness Training
Each employee has the potential to impact a facility’s environmental performance, both positively
and negatively. Therefore, it is important for all employees to understand the environmental impacts
associated with our operations and their responsibilities to minimize those impacts. Environmental
awareness training will enhance employees’ understanding of environmental issues and reinforce
the importance of environmental performance both at work and in their personal lives.
Performance Objectives
Training and environmental awareness is an integral part of the Marginpar Group ESMS. The
purpose of awareness training is to ensure that all employees performing tasks that have the
potential to cause a significant environmental impact, are competent to perform their duties, thereby
minimising negative impacts on the environment.
This procedure aims to ensure that environmental training needs are periodically identified, including
general environmental awareness and job-specific environmental requirements of Marginpar Group
employees by providing training relevant to their levels of responsibility.
Management Strategies:
Marginpar Group differentiates between two types of ESMS-related training:
•
Awareness training
•
Competency training
Awareness training is not job-specific and is applicable to all employees, contractors and visitors to
Marginpar Group. Awareness training addresses those issues regarding the ESMS that are
applicable to all employees, contractors and visitors towards maintaining a functional ESMS.
Competency training is job-specific training and is applicable to individuals as identified to be relevant
for specific jobs, tasks or job descriptions. Training material for competency training shall be
developed / provided by a competent person(s) knowledgeable in the relevant field related to a
specific training content or need.
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Marginpar Group shall ensure that all relevant employees are trained and capable of carrying out
their duties in an environmentally responsible and compliant manner, and are capable of complying
with the relevant environmental requirements. To obtain buy-in from staff, individual employees need
to be involved in:
•
Identifying the relevant risk;
•
Understanding the nature of risks;
•
Devising risk controls; and
•
Given incentive to implement the controls in terms of legal obligations.
Tasks:
1.
All employees shall have been given an induction presentation on environmental awareness
upon appointment or as an annual refresher course for existing employees. Where possible,
the presentation needs to be conducted in the language of the employees.
2.
All training must be formally recorded and attendance registers retained.
3.
The environmental training should, as a minimum, include the following:
• General background and definition to the environment;
• The importance of compliance with the Marginpar Group ESMS and associated policies
and procedures including this EMP.
• The environmental impacts, actual or potential, of their work activities;
• The environmental benefits of improved personal performance;
• Their roles and responsibilities in achieving compliance with the environmental policy and
procedures and with the requirement of the applicant’s environmental management
systems, including emergency preparedness and response requirements;
• The potential consequences (legal and/or other) of departure from specified operating
procedures;
• The mitigation measures required to be implemented when carrying out their work
activities; and
• All operational risks must be identified and processes established to mitigate such risk,
proactively. Thus the applicant needs to inform the employees of any environmental risks
that may result from their work, and how these risks must be dealt with in order to avoid
pollution and/or degradation of the environment.
Responsibility:
ESG Manager
10. Emergency Preparedness
Marginpar Group emergency preparedness process is managed through Marginpar Group senior
management with support from the Health and Safety Team. Emergency procedures have been
detailed in the Emergency Preparedness and Response Plan (Emergency and Casualty procedure).
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REVISION HISTORY:
Revision
Date
Descriptions of changes
Requested By
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