Environmental and social safeguards

The standard we apply

Which framework governs a piece of work depends on who finances it. We do not run one in-house standard and hope it satisfies everybody. We apply the client's framework, hold our own baseline underneath it, and where the two differ the stricter applies. We do not treat the absence of a donor as the absence of a standard.

Over all of them we apply Good International Industry Practice in the sense the financiers use it: the skill, diligence and judgement reasonably expected of a competent professional doing the same work in the same place. Where national law is less demanding than the applicable framework, the framework governs; where national law is more demanding, national law governs.

Screening before mobilisation

Every assignment and every works contract is screened before anyone mobilises. Screening asks whether the work involves or affects:

• land take, or any restriction of access to land, water or grazing;
• livelihoods, including seasonal and informal ones;
• labour, particularly where contractors or casual workers are engaged;
• water abstraction, discharge, or effluent;
• agro-chemicals, their storage, application or disposal;
• waste, including obsolete stock and containers;
• the presence of children, people with disabilities, or other groups at risk of exclusion or harm.

The screening is written down and signed by the Director of Legal, Compliance and Data Protection. Anything screened as more than low risk requires a written management plan, with named responsibilities, before work begins.

Land, access and livelihoods

We do not take part in work requiring physical or economic displacement unless the client has prepared a resettlement instrument to the applicable standard. Where we believe displacement is likely and no instrument exists, we say so in writing at proposal stage rather than after award.

Labour and working conditions

• No child labour and no forced labour in our operations or in any contractor we supervise, applying ILO C138 and C182 on child labour and C029 and C105 on forced labour. The minimum age on any HAGRO site or field team is 18, and age is verified against a document rather than assumed.
• No discrimination in recruitment, pay or promotion on any ground protected by ILO C100 and C111 or by Kenyan law, and no restriction on a worker's freedom of association.
• Written terms for every worker including casuals, wages at or above the applicable statutory minimum, and hours recorded.
• Personal protective equipment provided and required on works sites and wherever agro-chemicals are handled. Incidents are recorded and reported.
• Every worker, including a subcontractor's worker, may use the speaking up route in our safeguarding and ethics policy without going through their supervisor.

Community health, safety and security

Communities are informed before works begin, not after. Sites are secured against casual entry, traffic and dust are managed, and we do not engage armed security on any assignment.

Environment

• Agro-chemicals are handled in line with the FAO International Code of Conduct on Pesticide Management. We do not recommend, supply or apply any product banned or restricted for the use in question in Kenya, or listed under the Rotterdam or Stockholm Conventions.
• Water is abstracted only under the applicable permit, and we do not discharge untreated effluent to any watercourse.
• Waste, including obsolete chemicals and empty containers, goes to a licensed handler. Containers are not reused for water, food or feed, and we tell farmers why.
• We do not knowingly work in a way that clears natural habitat or drains a wetland, and we flag it where a design would.

Inclusion

Consultation is designed so that women, young people and people with disabilities can actually take part: timing that fits their day, locations they can reach, separate sessions where a mixed session would silence them, and the language they use at home. Data we collect is disaggregated by sex and age as standard, not on request.

If our work affects you

Anyone affected by work we deliver can raise a complaint without going through our field team, and in their own language. Write to speakup@hagrotrading.com, call +254 714 11 88 55, or use the county or community structure named in the assignment. A complaint may be made in Kiswahili or in the local language of the assignment.

Complaints are acknowledged within 5 working days and resolved or escalated within 30 calendar days. Every complaint is entered in a register, and on client financed work that register is shared with the client at the reporting frequency the contract sets.

The mechanism is designed against the effectiveness criteria in Principle 31 of the UN Guiding Principles on Business and Human Rights: it must be legitimate, accessible, predictable, equitable, transparent, compatible with rights, and a source of learning rather than a complaints drawer. Using it never removes anyone's right to go to a court, a regulator, or the financier's own grievance service, including the World Bank Grievance Redress Service and Inspection Panel, IFAD's complaints procedure, or the African Development Bank's Independent Recourse Mechanism.

Reporting and review

Environmental and social performance is reported to the board quarterly, and to the client at whatever frequency the contract requires. Significant incidents, meaning any fatality, serious injury, or material environmental or social harm, are reported to the client within 48 hours of our becoming aware, in line with the incident reporting requirements of the frameworks above.

This policy is reviewed annually, and immediately after any significant incident.