MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 1 of 8
Date:
Environmental, Social and Governance
Management Framework
Issued :
Revised :
Reissue :
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 2 of 8
Date:
INDEX
1. INTRODUCTION ......................................................................................................................... 3
1.1 SCOPE ............................................................................................................................................................................................ 4
2. ESMS DOCUMENT LIST ............................................................................................................ 4
3. ELEMENTS OF THE ESMS ....................................................................................................... 5
3.1 POLICY .......................................................................................................................................................................................... 5
3.2 IDENTIFICATION OF RISKS AND IMPACTS ............................................................................................................................... 5
3.3 MANAGEMENT PROGRAMMES .................................................................................................................................................. 5
3.4 ROLES AND RESPONSIBILITIES ................................................................................................................................................. 6
3.5 AWARENESS AND TRAINING ..................................................................................................................................................... 7
3.6 STAKEHOLDER ENGAGEMENT .................................................................................................................................................. 7
3.7 EMERGENCY PREPAREDNESS PROCEDURE............................................................................................................................. 7
3.8 ONGOING REPORTING ................................................................................................................................................................ 7
3.9 MONITORING AND REVIEW ....................................................................................................................................................... 8
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 3 of 8
Date:
1 Introduction
Marginpar BV is a leading supplier of summer flowers in the European market, sourced primarily
from its farms in Kenya and Ethiopia and outsourced farms in Tanzania and Zimbabwe.
Established in 1988, the company’s activities encompass the entire flower value chain including
collaboration with flower breeders, flower farming, logistics and marketing. Marginpar BV markets
and distributes most of its flower production through FloraHolland Flower Auctions.
Marginpar has established an Environmental and Social Management System (“ESMS”) to
evaluate risks and impacts associated with its operations and monitor ongoing Environmental,
Social and Governance (“ESG”) performance. The purpose of the ESMS is to ensure compliance
with the requirements of the following:
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IFC Performance Standards (2012);
International Labour Organization (ILO) Core Conventions and Basic Terms and Conditions
of Work;
World Bank General Environmental Health and Safety (EHS) Guidelines (2007); and
applicable World Bank industry sector EHS Guidelines (2007),
United Nations Guiding Principles on Business and Human Rights;
Local legislation, rules, regulations and statutory requirements
Certification requirements for key sustainability certification organizations and business
membership organisation;
All other relevant sustainable business requirements.
This Framework documents that system, and describes its various elements and the structures
that have been put in place to implement and maintain the system. Marginpar is committed to
continually improving this system and will do so through regular reviews and updates and the
application of the ‘plan-do-check-act’ cycle.
Figure 1: ESMS cycle of continuous improvement.
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 4 of 8
Date:
1.1 Scope
The ESMS relates to all of Marginpar’s activities, as well as the activities of suppliers,
customers and service providers undertaken on behalf of Marginpar, that it has some
control or influence over. The scope of the ESMS will be reviewed annually and the
implementation of any system changes will be the responsibility of Marginpar’s ESG
Manager.
2. ESMS Document List
Marginpar implements an overarching management system which have been developed
in accordance with Global Standards. This system provides the framework for all of the
company’s activities and is supported by numerous policies and procedures.
Whilst this management system provides the overarching framework for the Marginpar
ESMS, the following policies and procedures are specifically highlighted in terms of their
importance for the successful implementation of the ESMS;
• Human Resource Manual and policies including, disciplinary and grievance
handling policy, gender constitution, gender policy, forced labour policy,
discrimination and harassment policy, child labour and minors policy, confidentiality
policy, sexual harassment policy, employees with special needs policy, separation
and exit procedure, freedom of association policy, HIV/AIDS policy and training
policy and procedures.
• Health and safety policy and procedures including, PPE needs assessment, high
risk jobs register, safety for reservoirs, dam and lagoons, fire safety policy, hygiene
policy, health and safety policy, emergency and casualty procedures, PPE policy,
visitors’ hygiene, health and safety procedure, hygiene health and risk safety
analysis.
• Other policies including:
o Ethical and anti-corruption policy
o Security provisions
o CSR policy
o Industrial attachment policy
o Waste Management
o Customer complaints procedure
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 5 of 8
Date:
In addition to the above, the following policies and procedures have been developed in
support of the ESMS;
• ESMS00 ESMS Framework (this document)
• ESMS01 Environmental, Social and Governance Policy Statement
• ESMS02 ESMS Risk/Impact Identification Procedure
• ESMS04 ESG Reporting Requirements
• ESMS05 Stakeholder Engagement Plan
• ESMS06 External Grievance Mechanism and Procedure
• ESMS07 Emergency Preparedness and Response
3. Elements of the ESMS
3.1 Policy
Marginpar has developed a Health, Safety and Environment Policy (ESMS01
Environmental, Social and Governance Policy Statement) ensuring that it is appropriate to
the nature and scale of the risks and impacts of its activities. The policy expresses
Marginpar’s commitment to compliance with relevant national legislation and international
standards, and to continual improvement of its Environmental, Social and Governance
(“ESG”) performance.
3.2 Identification of Risks and Impacts
Marginpar 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 (ESMS02 Risk/Impact Identification Procedure).
Risks and impacts are recorded and evaluated in the existing Risk/Impact Register
(Hygiene, Health and Risk safety analysis ) 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
services or products and/or changes in Marginpar’s operational activities.
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 6 of 8
Date:
3.3 Management Programmes
Where applicable, Management Programs (procedures and action plans) have been
established, implemented and maintained to give effect to the implementation of the
management actions required to address the significant ESG risks/impacts associated
with Marginpar’s operations. The Management Programs document the procedures to be
followed to avoid or minimize the significant ESG risks/impacts of our activities and ensure
compliance with our ESG Policy (ESMS01 Environmental, Social and Governance Policy
Statement).
The following elements of the Environmental and Social Management Programmes have
been addressed in the above system:
• Labour and working conditions
• Internal and external communications
• Internal audit
• Waste management
• Pest Control
• Hazardous Substance management
• Sewerage and Sanitation
• Resource Efficiency
• Health and Safety
• Training
• Emergency Preparedness
The need for additional management programs may be identified through the ongoing
identification of risks and impacts as described in Section 3.2 above. Identifying the need
for and developing additional management programs is the responsibility of Marginpar’s
ESG Manager.
Management programs are reviewed and, if necessary, updated on a regular basis, as
provided for in each management programme document.
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 7 of 8
Date:
3.4 Roles and Responsibilities
Ultimate responsibility for the ESG performance of Marginpar lies with the senior
management team and, specifically, the Chief Executive Officer (CEO). However, all of
Marginpar’s employees are required to be aware of and comply with our ESG Policy
(ESMS01 Environmental, Social and Governance Policy Statement) as well as with the
provisions of all relevant Management Programmes (see Section 3.3) and our Emergency
Preparedness and Response procedures (see Section 3.5 below). A key facet to
showcase the commitment of management is by the provision of resources for
implementation of this ESMS including training.
All human resources related matters are the responsibility of the Human Resources
Manager while external communication is managed by the Marketing Department.
Implementation and maintenance of the ESMS is the responsibility of Marginpar’s ESG
Manager. The ESG Manager reports to, and receives the support of, Marginpar’s senior
management on the performance of the ESMS. The ESMS implementation will integrate
the KAIZEN-HAMUKA model in the implementation approach.
3.5 Awareness and Training
Marginpar will ensure that all relevant management staff and suppliers are aware of
Marginpar’s ESG Policy (ESMS01 Environmental, Social and Governance Policy
Statement) as well as:
• The importance of confirming with the Policy and the relevant procedures and
requirements of the ESMS;
• The significant risks/impacts associated with their activities and potential
consequences of not implementing the relevant Management Programs; and
• Their relevant roles and responsibilities with regards to ESG matters.
Marginpar will ensure that all new employees, as well as relevant service providers and
customers, are provided with the necessary training to ensure that they are competent to
manage the ESG risks/impacts of activities conducted on behalf of Marginpar. Training
documents are found in the Training Policy and Procedures.
3.6 Stakeholder Engagement
Marginpar’s stakeholder engagement process is managed through Marginpar’s senior
management. The procedure for stakeholder engagement is covered in the Stakeholder
Engagement Plan ESMS05. The procedure for handling external grievances is provided in
the (External Grievances Mechanism and Procedure ESMS06) and supported by the
Customer Complaints procedure. Employees grievances are catered for in Human
Resource manual under the Company disciplinary and grievance handling procedure.
MARGINPAR ESM
Doc No: ESMS00
Subject: Environmental and Social Management System
Framework
Authorised By: Top Management
Signature:
Rev No: 01
Page 8 of 8
Date:
3.7 Emergency Preparedness Procedure
Marginpar’s emergency preparedness process is managed through Marginpar’s senior
management with support from the Health and Safety Team. The required emergency
drills are performed in accordance with the procedure as can be found in Emergency
Prepardness and Response Procedure (ESMS07).
3.8 Ongoing Reporting
The management will report to Marginpar board on the implementation of the ESMS
annually. In addition, the management will provide ESG reports to key lender and
investors as required in the signed covenants and agreements. ESG performance will be
reported to the relevant Board Committee on a quarterly basis.
An ESG committee will be established comprising at least one individual on each farm.
This individual will be designated as the ESG contact person on the farm. The ESG
committee will meet quarterly and report on the ESG performance on each farm. The
meeting will be chaired by the ESG Manager. The Board will designate a member who will
attend the ESG committee meetings.
Major incidents which result in loss of life or serious injury, material effect on the
environment, human rights or material breach of law and any corrective actions are to be
reported to Marginpar board within 3 (three) days of Marginpar’s knowledge thereof. The
reporting requirements can be found in ESMS04 Marginpar ESG Reporting Requirements.
3.9 Monitoring and Review
Monitoring the implementation and effectiveness of the ESMS is the responsibility of the
ESG Manager.
The ESMS Framework will be reviewed and any system changes implemented on an
annual basis. The various ESMS Documents and Management Programs will be reviewed
and updated on a regular basis, as provided for in each document. Any system changes
must be approved by the CEO before implementation.