|
|  |
| OEA/Foz |
|
| Environmental & Social Review Summary |
This Environmental and Social Review Summary is prepared and distributed in advance of the IFC Board of Directors’ consideration of the proposed transaction. Its purpose is to enhance the transparency of IFC’s activities, and this document should not be construed as presuming the outcome of the Board of Director’s decision. Board dates are estimates only.
Any documentation which is attached to this Environmental and Social Review Summary has been prepared by the project sponsor and authorization has been given for public release. IFC has reviewed this documentation and considers that it is of adequate quality to be released to the public but does not endorse the content. |
| Project number | 27787 |
| Country | Brazil |
| Sector | Utilities |
| Department | Infrastructure |
| Company name | Foz do Brasil S.A. |
| Environmental category | B |
| Status | Pend PDS-IR |
|
| Date ESRS disclosed | July 6, 2009 |
 | |
|
| View Summary of Proposed Investment (SPI), click here |
|
| Overview | Category & Applicable Standards | Key Issues & Mitigation | Community Engagements | Client's Documentation |
| Overview of IFC's scope of review |
| IFC’s review included visits to Odebrecht Engenharia Ambiental (“OEA”, or the “Company”) offices in Sao Paulo, Brazil, where meetings and interviews with key staff (management, technical, human resources) were conducted, and numerous, relevant internal documents and records surrounding the Company’s environmental and social (E&S) performance were analyzed. Among others, these included environmental health and safety policies; integrated health, safety and environmental management program and procedures manual; environmental licenses; risk management audit framework; environmental, health and safety monitoring indicators; and presentation materials about the Company business activities. IFC staff conducted inspections of representative operating facilities – water treatment and wastewater treatment plants serving the cities of Rio Claro and Limeiras in the State of Sao Paulo; a wastewater treatment plant under construction in the city of Rio Claro; a new construction and demolition waste disposal facility located in the outskirts of the City of Sao Paulo; a wastewater ocean outfall project under construction in the City of Salvador, State of Bahia; and a contaminated soil incineration facility located near the City of Mosoro in the State of Rio Grande do Norte. Finally, the E&S appraisal also relied on the relevant findings of an independent technical and management review of Odebrecht Engenharia Ambiental conducted by the consulting firm Encibra on behalf of IFC (May 2009). |
| Project description |
| The Project involves the financing of equity investments in municipal and industrial water and sanitation projects developed by Odebrecht Engenharia Ambiental (“OEA”, or the “Company”), Odebrecht S.A. (“ODB” or the “Sponsor”) environmental engineering subsidiary formed to own and manage the Odebrecht group’s water supply, sewage treatment and industrial waste management investments. OEA already has a substantial portfolio (9 projects as of May 2009). These investments may include (i) investments in existing water and sanitation assets in Brazil under public-private partnerships (“PPP”) and traditional concession structures; (ii) the expansion of activities by acquisitions and/or associations/partnerships; and (iii) the development of greenfield projects. |
|
| Identified applicable performance standards |
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
Because this is an investment in a corporate entity to support its further expansion into operating future, but as of yet, undefined utilities and waste management facilities, the principal Performance Standards to be applied are:
-PS1: Social and Environmental Assessment and Management Systems;
-PS2: Labor and Working Conditions;
-PS3: Pollution Prevention and Abatement;
-PS4: Community Health and Safety
-PS5: Land Acquisition and Involuntary Resettlement
-PS6: Biodiversity Conservation and Natural Resource Management
OEA’s activities have the principal objective of reducing water pollution and contributing to improved water quality and enhanced public health in the communities it serves. As most of OEA’s activities take place in urban areas, their activities are not expected to result in adverse impacts to indigenous people (PS7); or cultural heritage (PS8). |
| Environmental and social categorization and rationale |
| This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. OEA’s core business activities in water and wastewater treatment and waste management provide essential environmental services to the public. OEA is presently demonstrating the ability to effectively manage potential environmental and social risks from its business activities through the application of international accepted practices to protect soil, water and air resources. |
|
| Key environmental and social issues and mitigation |
OEA has demonstrated that, upon implementation of the specific measures detailed below, their activities will meet the requirements under the IFC Performance Standards.
PS1: Social and Environmental Assessment And Management Systems
- Environmental and Social Assessment - OEA’s business model includes the development of greenfield projects as well as well as investments in existing assets (mainly in the water and sanitation area). The development of greenfield projects is conducted under the Brazilian environmental licensing process which requires the preparation of detailed environmental and social impact assessments of the aspects and impacts, both negative and positive, in the project’s zone of influence. The stepwise environmental licensing process applicable to all industrial activities entails the preparation of feasibility studies in order to obtain preliminary licenses. This is normally followed by more detailed environmental and social impact assessments required to obtain first, a construction license (based on the regulator’s review of project impacts and mitigation measures), followed by an operating license that is issued after regulatory inspection of the fully constructed project, just before initiation of operations. In cases where OEA becomes the concessionaire of an existing asset, OEA conducts an audit to help prepare the investment plan required under the concession. The audit includes a review of status of legal permits, including environmental licenses. Where environmental licenses are already in place, OEA ensures that facilities continue to operate according to permit requirements, otherwise, OEA addresses existing gaps in licensing to bring the facilities into compliance. As part of the initial evaluation of new water concessions, OEA reviews the status of technical losses in the distribution system to help prepare medium and long term investment plans to reduce them, along with other technical and commercial issues. OEA will update its assessment process for development of new projects or concessions so that through the assessment process it can identify potential gaps in environmental, health, safety, and social aspects covered under local regulations and applicable IFC Performance Standards.
- Management Program – As OEA is a member of the Odebrecht Group, OEA’s senior management group has a strong commitment to the principles enshrined in the Sustainability Policy of its parent company which include an integrated view about the importance of environmental and social development; environmental conservation; political participation; cultural diversity; and sustainability and profitability of the business enterprise. As a subsidiary of the Odebrecht Group, OEA is required, through a formal Internal Policy Instruction, to adopt and implement Odebrecht’s Integrated Health, Safety, and Environment Management Program (Programa Integrado de Saude, Seguranca e Meio Ambiente or SSTMA). The SSTMA defines roles and responsibilities as well as aspects associated with planning, implementing, verification, and the identification of corrective actions for continuous improvement. At the project or facility level, there is evidence that OEA currently relies on existing management programs such as those currently applied in the Limeiras and Rio Claro water and sanitation companies or the CETREL hazardous waste business. The Limeiras and Rio Claro operations manage environmental and occupational health and safety aspects based on operational plans and procedures that cover such diverse aspects as treatment processes to achieve drinking water quality and wastewater treatment objectives; source water protection; water distribution system loss prevention; and occupational health and safety (i.e. training, health monitoring, etc). The CETREL subsidiary operation visited in the State of Rio Grande do Norte is located within installations of the Brazilian National Petroleum Company (Petrobras) and must comply with well defined, strict, environmental and occupational health and safety management procedures. The greenfield ocean outfall construction project located in the City of Salvador, Bahia State, is under contract to the Odrebrecht Construction Company which, as a company also belonging to the Odebrecht Group, is applying the SSTMA.
OEA will develop and implement and environmental, health, safety and social management program based on the principles outlined in the parent company’s Sustainability Policy and SSTMA, as well as applicable IFC Performance Standards, supported by implementation plans and procedures specifically applicable to the risks and impacts of OEA’s business concerns.
- Organization – Responsibility for the management of environmental, health and safety (EHS) aspects is formally assigned to corporate level vice presidents, directors, contract managers, and those responsible for contract managers according to the Internal Policy Instruction. At the operational level in OEA, responsibility for implementation of the SSTMA is currently held by line managers and employees of individual operations. In each of the individual business interests reviewed as part of the appraisal, the Company is adequately staffed with professionals dedicated to such aspects as water and wastewater quality monitoring, waste management, and occupational health and safety. Coordination of operation’s compliance with Brazilian occupational health and safety requirements is currently conducted by the OEA’s Corporate Human Resources department which monitors and internally reports on the implementation of occupational health and safety programs and accident rates. OEA will designate specific in-house personnel, including management representatives, with clear lines of responsibility and authority for additional social and environmental issues at the corporate and operational levels. At the corporate level, a qualified professional will have overall responsibility for the preparation and implementation of a corporate environmental, health, safety and social management program.
- Training – OEA’s individual operations currently plan and implement training programs according to the technical requirements of their business area. Through adaptation of the SSTMA to its own operations, OEA will requires that all employees and subcontractors have formal education and experience appropriate for the assigned functions, ensuring that each of the operations plan and implement training programs consistent with the environmental, health, safety, and social risks of the business line activities. For the water and sanitation business this will include applicable occupational health and safety issues such as adequate use and care of personal protective equipment (PPE); hazardous materials management; and internal accident prevention training. Company employees providing environmental services for major clients (such as Petrobras) also undergo training under those clients’ EHS requirements.
OEA is currently in the process of developing an internal communications program whose objective is to disseminate corporate policies and practices starting with a standardized induction program and supported by publication of an OEA newsletter and the future development of a Company intranet site. Consistent with a strong educational culture of its parent company Odebrecht, OEA employees are eligible to participate in various professional development programs oriented to develop professional and leadership skills at all levels.
- Monitoring – According to the SSTMA, all Odebrecht subsidiaries, including OEA, are required to monitor a series of environmental, health and safety performance indicators. Monitoring requirements include such aspects as environmental licenses and authorizations; operation of environmental control systems for effluents, oily material storage, atmospheric emissions, solid waste, etc; occupational health and safety. The SSTMA includes monitoring and internal audit requirements for compliance with social management aspects such as policy on aids; cultural heritage; indigenous peoples and involuntary resettlement. Environmental monitoring activities in the water and sanitation business include such aspects as raw and treated drinking water quality, treated wastewater quality, drinking water distribution system losses, and waste generation. This information is compiled by OEA’s Corporate Engineering Department. Water and sanitation operations are also independently monitored by the state environmental regulators who collect and analyze raw and treated drinking water and wastewater samples to verify compliance with environmental licensing requirements.
Occupational health and safety (OHS) monitoring activities include workplace exposures to noise, elevated temperature and chemical agents consistent with Brazilian Regulatory Norms. OEA’s operations apply government required joint health and safety committees (CIPA) with representatives from the workers and management who supervise and report on health and safety issues encountered during work. CIPA committees are also responsible for investigating and analyzing occupational accidents, incidents, and health issues.
As part of its development and implementation of a corporate environmental, health, safety and social management program, OEA will identify a set of representative standard indicators of performance applicable to the operations of each business line.
- Reporting – The SSTMA defines the reporting requirements for results of environmental, health, and safety monitoring activities. Environmental monitoring data is compiled into reports at the facility level for submittal to the State Regulatory Agency in compliance with operating license requirements. For the water and sanitation business, individual operations are required to report on drinking water quality and treated effluent testing results to municipal and state agencies. Drinking water distribution companies in Brazil are also required to disclose the results of water quality testing to their customers normally including this information in the water bills.
OEA requires all of its operating entities to report on occupational accidents and incident rates. The results of OHS monitoring activities are compiled into internal reports that are reviewed by the human resources department and OEA senior management.
Some of OEA’s operations maintain external websites which provide information about the environmental impacts and mitigation measures of its operations as well as access to monitoring data. An example of this type of disclosure is the CETREL operations located in the State of Bahia which provide up to date information about such aspects and air quality monitoring data as well as wastewater treatment standards (http://www.cetrel.com.br/). OEA will prepare and publicly disclose Corporate monitoring reports of its operations on the company’s external website against the selected environmental, health, safety and social performance indicators as is currently done by other subsidiaries of the Odebrecht Group.
Odebrecht Group’s Annual Report includes a summary of corporate social responsibility programs implemented by Odebrecht and its subsidiaries. Odebrecht has also been publishing for over a decade the Odebrecht Informa Maganize which contains information about corporate activities, including Odebrecht’s corporate social responsibility projects, and the development of new projects across its subsidiaries, including OEA.
Going forward and within the above described existing set of E&S management system policies and practices, OEA will adopt IFC’s Performance Standards as part of legal and other requirements that apply to future operations. OEA’s environmental, health, safety and social management program will reflect the adoption of these standards with specific procedures designed to cover each of environmental and social requirements. OEA will amend the internal procedure covering the identification of applicable legal requirements to make specific reference to IFC’s Performance Standards.
PS2 - Labor and Working Conditions
- Human Resource Policy and Management – The Company has a total of 992 direct employees, 731 of which are dedicated to operational activities within the water and sanitation business, 213 dedicated to the industrial waste management business, and the remainder (48) dedicated to corporate management and administrative functions (i.e. accounting, legal, etc). Of the 944 operational level employees, approximately 60% are dedicated to technical and operational activities while the remainder work on administrative support. The Company currently communicates employee rights and responsibilities through employment contracts and through a Odebrecht Code of Ethics. The Code of Ethics principally covers aspects of company policy regarding relations between employees and various parties in order to avoid conflicts of interest as well as the principles of equal opportunity and harassment policy. OEA has a Human Resources Policy applicable to professional level employees which addresses such aspects as: compensation; occupational accident prevention; recruitment policy; training; and pension policy. OEA will develop a formal Human Resource Policy applicable to operational workers consistent with local labor law and IFC’s Performance Standard 2 to complement the information provided to employees through the labor contracts and Code of Conduct.
Strong support for equal opportunity and non-discrimination in employment is demonstrated through formal programs organized by Odebrecht such as one targeting the employment of persons with disabilities, a formal HIV/AIDS policy, and diversity targets reflected in Company metrics on gender, race, age, and level of education. OEA is also committed to maximize local economic development impact by maximizing the hiring of local labor throughout its operations.
- Worker’s Organizations – IFC found no evidence that OEA restricts freedom of associations of its employees. In Brazil, workers normally affiliate with local or regional labor unions organized to cover their specific industry activities. Operational employees in the assets currently held by the company are affiliated to the following labor unions: Sindicato dos Trabalhadores nas Indústrias de Cerâmica, Refratários, Construção, Montagem Industrial, Pavimentação, Obras e do Mobiliário de Limeira e Região in the water and wastewater operations in Limeira and Rio Claro, State of Sao Paulo (http://www.siticecom.com.br/); Sindicato dos Trabalhadores em Água, Esgoto, e Meio Ambiente do Estado de São Paulo in water and wastewater operations in Maua, State of Sao Paulo (http://www.sintaema.com.br/); Sindicato dos Trabalhadores em Água, Esgoto, e Meio Ambiente no Estado do Espírito Santo for water and wastewater operations in the State of Espirito Santo; Sindicato da Cosntrução Pesada for waste management operations in the State of Sao Paulo (http://www.sinicesp.com.br/); and Sindicato dos Trabalhadores em Água e Esgoto da Bahia for the waste management operations located in the State of Bahia (http://www.sindae-ba.org.br/). Each of these labor unions has collective agreements with the employers of the workers they represent. Depending on the labor union, the collective agreements may cover such aspects as: medical, childcare and other fringe benefits; overtime payment rates; notification requirement in case of termination or layoff; etc.
Retrenchment – The Company is projecting that the number of direct employees will grow significantly over the next three years primarily due to growth in the concession business. Some of the concession businesses will experience periods of growth and decline, primarily in the use of the use of temporary contracted labor for projected construction activities, mainly in some of its water and sanitation concessions. However, as part of its concession business, the Company typically encounters the need to reduce the number of employees as the concession is transferred from government to private entities. In these situations, responsibility for the retrenchment process is retained by the municipal governments and is typically phased in over a period two years after OEA takes over a concession, time during which the public employees remain as part of the Company while continuing to receive compensation from the government entity. At the end of the two year period, the municipalities exercise the option to provide early retirement or lay off some workers, a process which may typically affect about 15% of the workforce in a given concession. In future concessions, if OEA becomes responsible for retrenchment activities it will conduct them in a manner which complies with IFC requirements including development of retrenchment plans which are based on the principle of non-discrimination, reflecting consultation with employees, their organizations and, where appropriate, the government.
- Grievance Mechanism – The Company actively encourages employees and managers to openly discuss and resolve conflicts. Employees are currently able to lodge complaints internally through the Human Resources department and Company management, although there are no written procedures or formal mechanisms, and externally through the public Labor Rights system (Justica de Trabalho). OEA will create and implement a formal internal grievance process which allows grievances by individuals or groups (including anonymous complaints) to be presented verbally or in writing, without the risk of reprisals and according to other requirements consistent with IFC’s Performance Standard 2. The grievance procedure will be made available to all existing and new employees at the time of hire (as part of its Human Resource Policy or other document).
- Protecting the Work Force – The Company complies with legal minimum age of work requirements by requesting valid documentation of age in the employee contracting process.
- Occupational Health and Safety – As part of the SSTMA, the Company has an occupational health and safety (OHS) management program which includes a set of operating objectives based on the identification and quantification of workplace risks coupled with applicable legal and other requirements. To prevent workplace accidents and promote the health of its employees, OEA implements Brazilian Regulatory Norms (NR) applicable to its operations including those related to the identification and monitoring of chemical and physical hazards through a Workplace Environmental Risk Prevention Program or PPRA (“Programa de Prevenção de Riscos Ambientais”), use of personal protective equipment (PPE), emergency preparedness and response, and medical surveillance (PCMSO or “Programa deControle Médico de Saúde Ocupacional”).
PS3: Pollution Prevention and Abatement
OEA’s water, wastewater, and waste management operations provide a valuable environmental service whose environmental objectives are to improve environmental quality and protect public health. The following sections describe in additional detail how these activities are managed by OEA in order to meet these objectives.
Water and Sanitation Operations - Effluent discharges from wastewater treatment plants operated by OEA generally meet the standards specified in permits issued by State and Federal environmental authorities in Brazil. Brazilian wastewater discharge standards are consistent with IFC’s PS3 requirements as the permits limit discharges of indicator parameters at levels that take into account receiving water use, as well as its assimilative capacity. As part of the internal review of new and existing plant operations, OEA will identify any instances of non-compliance with applicable wastewater discharge standards and prepare a time-bound corrective action plan to come into regulatory compliance.
Water distribution networks typically experience significant water loss in the transmission system depending on their age, type of piping material, and maintenance history. OEA’s water concessions are instituting leak reduction programs by ensuring new construction meets applicable standards and industry practices; conducting regular inspection and maintenance; implementing leak detection and repair programs; and replacing mains with a history of leaks.
Municipal wastewater systems with industrial users/discharges can pose performance problems for wastewater treatment plants where these dischargers aren’t properly managed. Although municipalities may regulate the quality and strength of industrial wastewaters discharged to their sewerage systems, the absence of effective monitoring and enforcement can cause treatment process upsets which may lead to breach of effluent discharge standards. Brazilian law defines industrial wastewater pre-treatment standards for industrial facilities discharging into municipal sewer systems. In addition, some of OEA’s water and sanitation operations (such as Limeira) collaborate with industrial facilities to implement effective industrial discharge (to public sewerage systems) source control programs through individual contracts and, in some cases, real time volume and conductance metering. Through Brazilian concessions laws, centralized wastewater treatment plant operators are allowed to notify regulatory agencies when they identify instances of non-compliance by discharges of industrial wastewater. .
The principal waste generated by OEA’s activities are wastewater treatment plant sludge. Consistent with the SSTMA and Brazilian regulations, the Company periodically tests wastewater treatment plant sludge to establish its correct waste classification and disposal method. According to the regulatory classification, after processing in centrifuges, sludge from operating facilities located in the State of Sao Paulo is currently disposed by third parties in properly permitted sanitary landfills.
- Hazardous Waste Management Operations – OEA’s hazardous waste management businesses are centered on the in-situ and ex-situ treatment of hydrocarbon contaminated soils, typically through the use of incineration, as well as blending of hazardous wastes for subsequent incineration. Contaminated soils which are classified as a hazardous waste are thermally treated, reducing hydrocarbon levels to a point which render the soil non-hazardous and apt for disposal at solid waste landfills. These processes generate atmospheric emissions which comply with local permit conditions, applicable regulations and IFC’s emissions guidelines applicable to hazardous waste incineration.
- Solid Waste Landfill Operations – The Company is in the process of developing a business in solid waste management, including current development of a landfill for disposal of construction and demolition waste. In this and any other future developments, OEA will ensure that disposal facilities meet all Brazilian requirements and international technical standards for environmentally sound reception and disposal of waste materials.
PS4: Community Health, Safety and Security
-Infrastructure and Equipment Safety - Access to OEA’s operating facilities is restricted only to authorized persons or accompanied visitors under strict supervision and safety procedures. During construction activities for expansion of water distribution and sewage collection networks OEA will apply the management actions consistent with its SSTMA to prevent and mitigate impacts associated with construction in public roads such as providing safety signage and barriers to orient and separate vehicles and pedestrians, providing safe temporary walkways and road crossings for pedestrians, educating the affected community about the hazards associated with construction projects and in the importance of maintaining the integrity of safety devices.
-Community Exposure to Disease - The drinking water treatment plants and distribution systems OEA operates produce finished water that meets applicable host country standards. In certain systems there have been occasional exceedances of aesthetic parameters, such as iron (with the associated color and turbidity), due, in part, to corrosion of distribution piping. These minor violations are limited, and have no adverse impact on public health.
The Company also tracks trends in infant mortality rates across concession areas to demonstrate how improvements in expansion of water and sewerage service are favorably linked to improvements in public health.
Company operations involved in drinking water treatment and distribution continually monitor source water quality and quantity according to applicable legal requirements. At-risk intake areas may be subject to source water protection programs in collaboration with local or regional regulatory agencies. Water company operators are required to notify environmental regulatory agencies if a problem, such as the presence of hazardous constituents, is identified during source water quality monitoring activities. Water withdrawals take into account actual and projected capacity of the river systems used as water sources.
-Hazardous Materials Safety - Facilities using and storing hazardous chemicals, particularly gaseous chlorine at drinking water treatment plants, pose risks associated with accidental releases. OEA subsidiaries adequately handle these materials to minimize the impact of such a release. Appropriate emergency prevention and control plans are in place, and include provision of appropriate response equipment and materials, and a detailed set of procedures to be followed to minimize the harm of any potential accident. OEA operations purchase these materials only from licensed providers and follow the regulatory procedures for notification of local fire departments ahead of transport and delivery events.
PS5: Land Acquisition and Involuntary Resettlement
As documented in Odebrecht’s Guidelines for Involuntary Relocation, OEA’s initial approach during every project design is to avoid the need for physical or economic displacement. Where displacement can not be avoided, OEA’s policy is to acquire properties or establish right-of-ways through direct negotiations with the landowners. OEA will update the guidelines to include principles applicable to land acquisition process and OEA’s policy regarding the use of judicial expropriation, ensuring OEA’s Involuntary Relocation Guidelines are consistent with PS5 requirements.
OEA’s Lumina landfill facility in the City of Sao Paulo required the purchase of land which the Company has conducted based on mutual agreements with the landowners. Land values used in the negotiations have been based on market value for the location and use of the land. Development of this landfill site, have included the displacement of at least one family who lived as tenants and/or employees of former landowners. The Company will review the negotiation and compensation processes applied to these former tenant(s) to ensure compliance with PS5.
PS6: Biodiversity Conservation and Sustainable Natural Resource Management
Brazilian environmental regulations include requirements for the assessment of potential impacts to biodiversity and implementation of preventive and corrective actions as evidenced in the construction of an ocean outfall project by OEA in the City of Bahia, State of Salvador. OEA is supported by external experts to implement biodiversity conservation programs which may include rescue of fauna and flora from potentially impacted areas and offsetting or conservation mechanisms required by Brazilian law. OEA will ensure that environmental impact assessments where potential impacts to biodiversity are identified include identification of the presence of IUCN Red-listed critically-endangered or endangered species, concentrations of nationally listed threatened species, endemic or restricted-range species, migratory or congregatory species; description of whether the site is located in an rare, threatened or endangered ecosystem; and other information necessary to evaluate the presence and potential impacts to biodiversity resources of critical importance to biodiversity or local communities in compliance with IFC’s PS6 requirements. |
|
| Client's community engagement |
Community engagement activities are mainly organized and managed through individual business operations, although OEA’s parent company, Odebrecht, has an internationally recognized corporate social responsibility program applied in Odebrecht’s projects’ areas of influence and which cover numerous aspects in education, health, environment, agriculture and social inclusion (additional information on these programs is available at: http://www.odebrecht.com/), and additional programs managed by its non-profit foundation (Odebrecht Foundation; additional information is available at: http://www.fundacaoodebrecht.org.br/).
In the construction of greenfield projects, OEA’s subsidiaries comply with Brazilian environmental licensing requirements which include a comprehensive public consultation process beginning with the publication of a summary of the environmental and social impact studies in the local government offices, such as municipal offices, for a period of public review, together with an announcement soliciting comments from the public. This publication and announcement are followed by dissemination of project information to residents of potentially affected communities and invitation for a public audience held before the environmental regulatory agency responsible for the issue of environmental license. Records of the consultation and permitting processes are kept by the relevant regulatory agency and are available to public inquiries.
In its water and sanitary sewerage concessions, the communities potentially affected by the Company’s operations are also its costumers and OEA’s subsidiaries devote a proportion of their operating efforts toward effective communications with the communities they serve and where company infrastructure is located. The principal means of communication is through widely publicized call centers designed to attend costumer service related issues and, less frequently, reporting of emergencies. The call centers track the speed and effectiveness in the resolution of complaints with a target toward continuous improvement in client and community satisfaction. Subsidiary communication and marketing departments provide avenues of information disclosure and dialog with the rest of the general public. These departments also develop and implement social programs with organizations such as schools and other social institutions.
The Company further prepares and distributes educational materials to the public it serves covering such aspects as the proper cleaning of household water storage tanks to prevent contamination of drinking water as well as information on issues of frequent concern such as taste and appearance of water drinking water; and proper use of the sewage system to avoid blockage from accumulation of improperly handled solid waste or liquid wastes. |
| Local access of project documentation |
Anna Lucia Horta
ahorta@odebrecht.com
+55 11 3096 8758
Daelcio De Freitas
daelcio@odebrecht.com
+55 11 3096 8772
Av. das Nações Unidas, 8501 – 32º andar
Edifício Eldorado Business Tower
05425-070, Pinheiros
São Paulo – SP, Brazil |
|
| Availability of Full Documentation |
|
|
| Information Disclosed |
|
|
|
|
|