alliance for water stewardship (aws) audit report...must be scheduled within 13 months. hence, next...

ALLIANCE FOR WATER STEWARDSHIP (AWS)

AUDIT REPORT Based on AWS Standard Version 1.0

Nigerian Bottling Company Limited

Plot 732, Idu Industrial Estate, Jabi, Abuja Federal Capital Territory,

Nigeria.

Report Date: 10-01-2019

Report Version: 01.0

Prepared by: Control Union Certification Services Accra, Ghana.

Project No.: 864416AWS-2018-01

AWS Reference No.: AWS-010-INT-CU-00-03-0024-0058

Nigerian Bottling Company Limited AWS Audit Report

Project No.: 864416AWS-2018-01 AWS Reference No.: AWS-010-INT-CU-00-03-0024-0058 of 25

Contents 1. General Information ............................................................................................................................. 3

1.1. Client Details ................................................................................................................................. 3

1.2. Certification Details ....................................................................................................................... 3

2. Executive Summary ............................................................................................................................... 4

3. Scope of Assessment............................................................................................................................. 5

4. Description of the Catchment ............................................................................................................... 5

5. Summary on Stakeholder and shared Water Challenges ..................................................................... 6

6. Summary of the Assessment................................................................................................................. 7

6.1. Major Non-conformities ............................................................................................................... 7

6.2. Minor Non-conformities ............................................................................................................... 7

6.3. Observations ................................................................................................................................. 7

7. Schedule for Surveillance Audit ............................................................................................................ 7

8. Conclusion and Recommendation ........................................................................................................ 7

9. Audit Checklist ...................................................................................................................................... 9



1. General Information

1.1. Client Details

Company Name Nigerian Bottling Company Limited (Coca Cola Hellenic)

Business address: Nigerian Bottling Company, Iddo house, Iddo, Ebute Metta, Lagos

Auditing Site Address: Plot 732, Idu Industrial Estate Jabi, Abuja FCT

Activities / Processes: Beverage Manufacturing

Principle contact person: Olushola Owoye

Office telephone: 08155999358

Fax:

E-mail: [email protected]

Web site: www.nigerianbottlingcompany.com

1.2. Certification Details

Audit Date(s): 20/12/2018 and 21/12/2018

Auditor Team: Bunny Azmi and Olalekan Emmanuel Akinwekomi

Certification Date: 10-01-2019

Proposed date for next audit: 20-12-2019

Audit Report completed by: Olalekan Emmanuel Akinwekomi

Project No.: 864416AWS-2018-01

AWS Reference No.: AWS-010-INT-CU-00-03-0024-0058



2. Executive Summary

The site is one of the 8 Nigerian Bottling Company (NBC), which is a member of Coca-Cola Hellenic

group. It is in Abuja north central Nigeria. The company pride herself in the following products; Coca-

Cola, Fanta, Sprite, Schweppers bitter lemon, Limca, Coca-Cola Zero and Eva bottle water. The

production capacity of the plant is 125,000 crates of beverages per day.

The certification audit announcement was published 30 days before the audit, as required by AWS

standard, in the following media; Control Union website (on 05-11-2018), AWS website and Daily Trust

Newspaper (on 08-11-2018, local newspaper). The audit was conducted for 2 days i.e. on 20th and 21st

December 2018 by the audit team lead by Bunny Azmi and Olalekan Emmanuel Akinwekomi at the plant

site in Abuja.

The audit team was comprised of following auditors;

Name of Auditor Role in Audit

Bunny Azmi Lead Auditor

Olalekan Emmanuel Akinwekomi Auditor

The audit findings showed that the site meet up with all the core level criteria. All the Non-Conformities

identified were at the level of advance requirements of the standard. Since the advance requirements are

not mandatory requirements this time, therefore there was no any timeline for closing of the Non-

Conformities.

The site meets up with all the requirements and criteria for Core level certification. Therefore, it is

recommended to be awarded Core Level of AWS certificate.



3. Scope of Assessment

Audit Standard AWS Standard V1.0

Initial Audit Yes

Surveillance Audit No

Type of Certification Single Site Multi-site Group

X

Location of Audit NBC Plant, Idu Industrial Estate, Jabi Abuja FCT

Scope of Certification

The plant water catchment which is Usman dam, the relevant stakeholders in the catchment area, all the production lines and other related areas utilizing water on the site

Assessment on-site activities includes Document review, management interview, employee interview, onsite implementation review

4. Description of the Catchment

The catchment water source is from Usuman dam which was constructed and managed by the Federal

Capital Territory (FCT) Administration Water Board. The dam is in the Bwari Area council of the FCT in a

village called Usuman (which the dam is named after) about 10 kilometers away from Abuja city. The dam

derives its water inflow from Gurara river flowing from Kaduna state. NBC (Coca-Cola Abuja) get her

water supply from this dam through Federal Capital Territory (FCT) Administration water board and pay

for every water supply. About 5 million FCT residence depend on this dam for living either for drinking

water, domestic use, industrial use and fishing by neighboring villages (Usman and Mpape).

Map Showing Water Catchment of NBC Abuja Plant, Nigeria



Map Showing Usman Dam

Map Showing NBC Site Location in Abuja

5. Summary on Stakeholder and shared Water Challenges

The list of water related stakeholders for NBC Abuja plant include host communities; Karimojiji, Mpape,

Usuman village. Others include FCT Administration water board, FCT Environmental Protection Board

and National Environmental Standards and Regulations Enforcement Agency (NESRA).

There was a stakeholder meeting involving FCT water board and host communities (Usman and Mpape)

around the Usuman dam to identified common water challenges. One of the water related challenge that

was raised was the infiltration of plastics waste on the water source dam. Some of the suggested

solutions to the plastic waste concerns are; NBC to organize annual clean up awareness and event at the

dam. Collaborate with FCT water board on development of technical solution for a foreign material trap

along the intake of the Usuman dam.



6. Summary of the Assessment

6.1. Major Non-conformities

Sr. No.

AWS Criteria

Description of NC Response from Client

(explanation & documents) Closure

Nil

6.2. Minor Non-conformities

Sr. No.

AWS Criteria

Description of NC Response from Client


Nil

6.3. Observations

Sr. No.

AWS Criteria

Description Response from Client


1 1.1 It is an appreciable point that plant has a dedicated Water Stewardship Policy. But as per AWS standard, policy and commitment are two separate documents. Request NBC to please demonstrate this practice.

[09-01-2019] NBC integrated most of the documents. The signed commitment is available at the plant reception. One photo shared by NBC towards commitment that is put on wall at Abuja Plant reception as public document and it is treated as commitment. Also few commitment over water is available on Coca-Cola website- (1) https://www.coca-colacompany.com/stories/collaborating-to-replenish-the-water-we-use (2) https://coca-colahellenic.com/media/3217/2025_1.pdf

[09-01-2019] Response accepted

7. Schedule for Surveillance Audit

As this initial audit was conducted on 20/12/2018, as per the requirement of standard surveillance audit

must be scheduled within 13 months. Hence, next surveillance audit will be conducted on 20-12-2019.

This date even includes any request for re-assessment for certification level upgradation.

8. Conclusion and Recommendation

Coca-cola being a brand name in market has evolved their vision and policies by adopting sustainability

practices. One of the sustainability approach that they are working in is Water Stewardship and hence



applied for AWS certification for their Abuja Plant at Nigeria (NBC). This summary is for the certification

review done on the audit findings under AWS standard.

Observations and Recommendations:

1. NBC has involved many stakeholders in their conduct for water stewardship - employees, consultant,

government agencies, suppliers, educational institute.

2. All the work done by CC is compiled in two report namely - Source Vulnerability Assessment (SVA)

and Source Water Protection Plan (SWPP).

3. NBC needs to describe their sphere of influence more clearly

4. Though NBC has read the paper but they need to draw references or comments and include it

towards development of future water stewardship strategies

5. Though the document referred in criteria 3.3 has water-related incident / emergency response plan

but it is suggested that more water specific aspects & impacts should be considered so that this plan

could be upgraded for better resilience.

6. Towards criteria 4.16, NBC has to document the engagement level / role (advisor, instructor, etc) for

each supplier and quantify water consumption improvement.

7. Towards criteria 6.1, NBC has to disclose all the water-related challenges that they have identified in

year 2018 publicly along with summary of actions taken to engage stakeholders

8. It was difficult to realise the linkage that water stewardship related plans and strategies are developed

& adopted based on water related data collection - implementation based on set plans & strategies -

achievements - evaluation - disclosure. This could have been made easy if CC could have share few

required documents



9. Audit Checklist

Step 1: COMMIT – Commit to being a responsible water steward

AWS Criteria Indicators Level Auditor’s Findings Certifier’s Response

1.1 Establish a leadership commitment on water stewardship

1.1.1 Signed and publicly disclosed statement that explicitly covers all requirements

Core Commitment is embedded in the plant AWS policy, signed by Plant manager Olushola Owoyemi on 18th October 2018

[08-Jan-2019] NBC integrated most of the documents The signed commitment is available at the plant reception. Request auditor to please get a photograph if possible. [09-Jan-2019] One photo shared by NBC towards commitment that is put on wall at Abuja Plant reception as public document and it is treated as commitment. Also few commitment over water is available on Coca-Cola website- (1) https://www.coca-colacompany.com/stories/collaborating-to-replenish-the-water-we-use (2) https://coca-colahellenic.com/media/3217/2025_1.pdf

1.2 Develop a water stewardship policy

1.2.1 Publicly available policy that meets all requirements

Core Group AWS policy available on the group website and signed by the Group CEO

[08-Jan-2019] Link for Global level Policy- https://ng.coca-colahellenic.com/en/about-us/policies/water-stewardship-policy/ For site specific policy NBC has shared a photo of policy that is hanging at reception at Abuja Plant Finding accepted

1.3 Further the Alliance for Water Stewardship

1.3.1 Official registration with AWS

Advance The site was registered with registration number AWS-010-INT-CU-00-0024-0058 on AWS website. The site carries Lagos address on AWS website but a clarification email dated August 1st, 2018 from Mona Karraoui (AWS staff) to acknowledge the error.

[05-Jan-2019] Finding accepted

1.4 Commit to other initiatives that advance effective water stewardship

1.4.1 Formal commitment to qualifying initiative(s), including a timeline for completion

Advance Cleaning of Karimojiji river as part of CSR initiative. Support and Participated in UN Word water day 2018 organized by FCT water board, Federal Ministry of water resources in partnership with UN. Other corporate level initiative are in GRI report and Source Vulnerability Assessment report March 2016

[08-Jan-2019] NBC has not shared the report but auditor has checked the said report "Source Vulnerability Assessment (SVA) report March 2016" and found the voluntary commitments with specified target / timeline. Finding accepted



AWS Criteria Indicators Level Auditor’s Findings Certifier’s Response and review every 5 years (The next review will be 2021 but each year progress report is captured in SWPP-mitigation plan and monitored).

1.5 Secure a water stewardship commitment from the organization’s senior-most executive or the organization’s governance body

1.5.1 Appropriately signed and publicly available statement that explicitly covers all requirements

Advance Plant manager (which is one of the organization's senior-most executive) signed SWPP plan

[05-Jan-2019] This finding is not acceptable

1.6 Commit to directly assisting with community water needs in times of stress

1.6.1 Signed and publicly disclosed statement that explicitly covers all requirements

Advance Group commitment tagged 'Mission Sustainability 2025 Commitment' available on the group website, approved by Micheal Dickson - Group Sustainability and Community Director.

[09-Jan-2019] NBC has shared copy of this commitment (#6) which is part of Mission Sustainability 2025 commitments - https://coca-colahellenic.com/media/3217/2025_1.pdf Finding accepted

Step 2: GATHER & UNDERSTAND – Gather data to understand shared water challenges and water-related risks, impacts and

opportunities


2.1 Define the physical scope

2.1.1 Documentation or map of the site’s boundaries 2.1.2 Names and location of water sources, including both water service provider (if applicable) and ultimate source water 2.1.3 Names and location of effluent discharge points, including both water service provider (if applicable) and ultimate receiving water body 2.1.4 Geographical

Core Map showing TV-Camera views of NBC Abuja plant August 20th, 2017. NBC (CC Abuja) get her water supply from Federal Capital Territory (FCT) water board through her Usuma dam supply water to the entire territory. There are three major pipes that are connected to the plant from the dam; 1 running, 1 for spare and 1 for future expansion. There are 2 flow meter used to calculate volume of water supply from water board in order to pay for water supply. Effluent is through WWTP.

[05-Jan-2019] Based on the findings, the same is crossed checked on Google Maps and found ok. Finding accepted




description or map of the catchment(s)

2.2 Identify stakeholders, their water-related challenges and the site’s sphere of influence

2.2.1 List of stakeholders, descriptions of prior engagements and summaries of their water-related challenges 2.2.2 Description of the site’s sphere of influence

Core There was a stakeholder meeting with FCT water board on November 21st, 2018 and also with FCT water board and communities (Usman and Mpape) around the Usman dam on December 6th, 2018. Though no meeting attendance list was provided but from the minutes of the meetings, one of the water related challenges that was raised is the infiltration of plastics waste on the water source dam. Some of the suggested solutions to the plastic waste concerns are; CC to organize annual clean up awareness and event at the dam. Collaborate with FCT water board on development of technical solution for a foreign material trap along the intake of the Usuman dam

[08-Jan-2019] List of stakeholder includes FCT, Usuman & Mpape community (direct) National Environmental Regulatory Agency (NERA), AEPCB, staff and vendors, Karimojiji community where effluent is discharged. Finding accepted

2.3 Gather water-related data for the catchment: Gather credible and temporally relevant data on the site’s catchment: x Water governance x Water balance x Water quality x Important Water-Related Areas x Infrastructure’s current status

2.3.1 List of relevant aspects of catchment plan(s), significant publicly led initiatives and/or relevant water related public policy goals for the site 2.3.2 List, and description of relevance, of all applicable water-related legal and regulatory requirements, including legally defined and customary water rights and water-use rights 2.3.3 Catchment water balance by temporally relevant time unit and commentary on future supply and demand

Core An external document on ‘impact of the Gurara River interbasin water transfer scheme on Kaduna River at the Shiroro dam’ explains the water balance of Usuma dam and others. The FCT board is yet to embark on comprehensive assessment of the water balance of its primary water sources namely; Usuma/Gurara dams. Letter signed by General Manager FCT Water board Mrs. Okobi O.Y (Letter dated 14th November, 2018). But the FCT water board has a master plan previously developed.

[08-Jan-2019] Water is supplied by FCT from Usma Dam. Dam is depended on Gurara River and Kaduna States which is rainfed. Study is done over these catchments by Engr. Kashim A. Alli. Water balance is not available yet as FCT is planning to do it. This report has identified important water related areas and FCT has the Water Master Plan for water conservation. Finding Accepted




trends 2.3.4 Appropriate and credibly measured data to represent the physical, chemical and biological status of the site’s water source(s) by temporally relevant time unit, and commentary on any anticipated future changes in water quality 2.3.5 Documentation identifying Important Water Related Areas, including a description of their current status and commentary on future trends 2.3.6 Existing, publicly available reports or plans that assess water-related infrastructure, preferably with content exploring current and projected sufficiency to meet the needs of water uses in the catchment, and exposure to extreme events

2.4 Gather water-related data for the site: Gather credible and temporally relevant data on the site’s: x Governance x Water balance x Water quality

2.4.1 Copies of existing water stewardship and incident response plans 2.4.2 Site water balance (in Mm3 or m3) by temporally relevant time unit and water-use intensity metric (Mm3 or m3 per unit of production or service)

Core Daily water monitoring efficiency showing water ratio. ETP Daily Data Log available is showing the physical, chemical and biological status of the effluent. Inventory of chemicals are available. Chemicals were stored (Because storage is a 40 feet temporary container.

[08-Jan-2019] NBC had shown during audit their Water specific incident response plan. There is no important water related areas inside plant. They have separate water cost documentation and planned actions. Findings accepted




x Important Water-Related Areas x Water-related costs

2.4.3 Appropriate and credibly measured data to represent the physical, chemical and biological status of the site’s direct and outsourced water effluent by temporally relevant time unit, and possible pollution sources (if noted) 2.4.4 Inventory of all material water-related chemicals used or stored on-site that are possible causes of water pollution 2.4.5 Documentation identifying existing, or historic, onsite Important Water-Related Areas, including a description of their status 2.4.6 List of annual water-related costs, revenues and description/quantification of social, environmental or economic value generated by the site to the catchment

2.5 Improve the site’s understanding of its indirect water use

2.5.1 List of primary inputs with their associated embedded annual (or better) water use and (where known) their country/region/or catchment of origin with its level of water stress

Core Available list of primary input suppliers (Sugar-Dangote, C02-Contour Global, Water-FCT board, Crown-Frigoglas, Avon; Preform-Idorama, Somex, Prima and Lotus; Closure Plastic-Idorama, Prime and Sonnex; Glas-Frigoglass. No available estimated annual water use but global water footprint available in document CCHB Environmental

[08-Jan-2019] There is a global water footprint report prepared by CC corporate. All the primary inputs are not procured independently from Abuja but sourced from corporate. Hence, corporate has all the data related to water and respective allocation is also done for Abuja plant on CCHB Environmental Performance 2017. This report has been referred by Auditor during audit and found satisfactory. Finding accepted




2.5.2 List of outsourced services that consume water or affect water quality and both (A) estimated annual (or better) water withdrawals listed by outsourced services (Mm3 or m3) and (B) appropriate and credibly measured data to represent the physical, chemical and biological status of the outsourced annual (or better) water effluent

Performance 2017 contain annual water footprint for the Abuja plant

2.6 Understand shared water-related challenges in the catchment

2.6.1 Prioritized and justified list of shared water challenges that also considers drivers and notes related to public-sector agency efforts

Core One of the water related challenges that was raised is the infiltration of plastics waste on the water source dam. Some of the suggested solutions to the plastic waste concerns are; CC to organize annual clean up awareness and event at the dam. Collaborate with FCT water board on development of technical solution for a foreign material trap along the intake of the Usuma dam

[08-Jan-2019] Auditor has shared the photographs of the MoM and attendance list. Finding accepted

2.7 Understand and prioritize the site’s water risks and opportunities

2.7.1 Prioritized list of water risks facing the site, noting severity of impact and likelihood within a given time frame 2.7.2 Prioritized list of water-related opportunities for the site 2.7.3 Estimate of potential savings/value creation

Core Available at SWPP and the mitigation plan of June 27, 2018.

[09-Jan-2019] SWPP is a confidential document for NBC. Auditor has seen this document on site and satisfied with the level of information available on it. Finding accepted

2.8 Support and undertake joint

2.8.1 Evidence of water-related data that was

Advance No water related data jointly gather

[09-Jan-2019] Finding accepted. It is non-conformity instead of non-applicable.




water-related data collection

jointly gathered

2.9 Gather additional, detailed water-related data

2.9.1 Water-related data sets that go beyond core requirements – See Guidance for details

Advance SWPP AND SVA document. SWPP and SVA 5 years water plan report June 27, 2018

[09-Jan-2019] SWPP and SVA are the existing report that CC use for water stewardship planning and implementation even before AWS standard is adopted at CC or any plants of CC like NBC. These documents have more detailed information on water-related areas. Auditor has seen these documents during audit and found satisfactory. Finding accepted

2.10 Review a formal study on future water resources scenarios

2.10.1 Copy of a study that details projected future state conditions relative to current quantity and quality parameters and a comment on potential impacts upon the site’s growth strategy

Advance A copy of External document titled 'Development of Water Supply Infrastructure in Nigeria: Challenges and Prospects by Engr. Kashim A.Alli paper presented at 2012 Nigerian Society of Engineers Lecture, was provided. There was no review commentary by NBC on the document.

[05-Jan-2019] Based on the finding it is clear that though NBC has collected an appropriate study paper but they have not analyzed it towards risk or opportunity that NBC might get in future. Based on this finding this criteria is scored 1. Finding accepted (http://isqilnajim.blogspot.com/2012/09/development-of-water-resources-in.html)

2.11 Conduct a detailed, indirect water use evaluation

2.11.1 Detailed description of the site’s water-related supply chain with indirect water use amounts (for water quantity and quality) and the site’s engagement efforts to date for each

Advance Not available [05-Jan-2019] Finding accepted

2.12 Understand groundwater status or environmental flows and the site’s potential contributions

2.12.1 Conclusions about the site’s potential contributions to groundwater recharge or environmental flows restoration

Advance Abuja Plant Hydrological Assessment July 2015. No recharge to ground water from the site

[09-Jan-2019] Referring to AWS guideline and description provided by auditor the Abuja plant Hydrological Assessment Report Jul 2015 can be considered under this criteria. Finding accepted

2.13 Complete a voluntary Social Impact Assessment

2.13.1 Social impact assessment report

Advance Available in the Environmental Impact Assessment report 2008 but the report of the recently conducted EIA January 10th, 2018 not yet available.

[09-Jan-2019] During audit it was seen that the old EIA report of 2008 has a separate chapter for Social Impact Assessment. And in the same line NBC has conducted recent assessment in Jan 2018. But this report is not available and last report is about 10 years old and could not be accepted. Hence, this



AWS Criteria Indicators Level Auditor’s Findings Certifier’s Response finding is not accepted.

Step 3: PLAN – Develop a water stewardship plan


3.1 Develop a system that promotes and evaluates water-related legal compliance

3.1.1 Documented description of system, including the processes to evaluate compliance and the names of those responsible and accountable for legal compliance

Core Legislative register complaint first issued February 10, 2017 and revised November 11, 2018

[09-Jan-2019] During audit, Auditor has seen all the relevant documentation and updates and found satisfactory. Finding accepted

3.2 Create a site water stewardship strategy and plan: Develop an internally available water stewardship strategy and plan for the site that addresses its shared water challenges, risks and opportunities identified in Step 2

3.2.1 Available water stewardship strategy 3.2.2 Available plan that meets all component requirements and addresses site risks, opportunities and stakeholder shared water challenges

Core CCH-SWPP-SVA-EWS-AWS-Questionnaire developed October 15, 2018.

[09-Jan-2019] Abbreviation: CCH - Coca-Cola Hellenic SWPP - Source Water Protection Plan SVA - Source Vulnerability Assessment EWS - European Water Stewardship Standard AWS - Alliance for Water Stewardship Name of Reports: (1) SWPP (2) SVA and (3) EWS-AWS Questionnaire - developed to gather data & information for planning. These reports from NBC have all the stewardship strategies and plans that met all the commitments announced by NBC towards water stewardship. Finding accepted

3.3 Demonstrate responsiveness and resilience to water-related risks into the site’s incident response plan

3.3.1 A description of the site’s efforts to be responsive and resilient to water-related issues and/or risks in an appropriate plan

Core Available in the SWPP

[09-Jan-2019] The SWPP is the comprehensive document for NBC and has all strategies & plan towards each aspect of water stewardship. It also has incident response plan in it. Auditor has seen a specific case for oil spillage incident reporting and preventive action taken. Finding accepted

3.4 Notify the relevant (catchment) authority of the site’s water stewardship

3.4.1 Documented evidence of communicating the site’s plan to the

Core Available in one of the letter dated December 18, 2018 signed by the plant manager (Oulshola Owoye) communicated to the authority Upper River Niger Basin Authority.

[09-Jan-2019] Upper Niger River Basin authority is the federal govt. water agency that oversees all catchments like Guara dam, Shiroro dam, Usma Dam, etc. The copy of shared letter was seen during audit.




plans relevant catchment authority/agency

Finding accepted

3.5 Gain stakeholder consensus on the site’s water stewardship targets

3.5.1 A list that indicates which targets achieved consensus along with a list of stakeholders involved

Advance Available in the SWPP

[09-Jan-2019] There is no specific evidence found as the referred document is not shared and there is specific clarification from Auditor. Hence the finding is not accepted.

3.6 Develop a formal plan for climate change adaptation

3.6.1 A set of plans that speak to the site’s risk mitigation with respect to projected climate change impacts including for shared water infrastructure

Advance CCH-SWPP-SVA-EWS-AWS-Questionnaire developed October 15, 2018.

[09-Jan-2019] As explained in 3.2 findings these reports have all the strategies but could not share it as its confidential. These documents were seen on site during audit and found satisfactory. Finding accepted

Step 4: IMPLEMENT – Implement the site’s stewardship plan and improve impacts


4.1 Comply with water-related legal and regulatory requirements and respect water rights

4.1.1 Documentation demonstrating compliance 4.1.2 (Catchments with stakeholders who have an unmet human right to safe drinking water and sanitation) Documentation of efforts to work with relevant public sector agencies to fulfil human right to safe drinking water and sanitation.

Core AEPB, NESREA, NAFDAC and SON. Available NESREA Permits to expire Feb.28, 2019; NESREA environmental audit certificate expire April 7th, 2021. Letter of approval AEPB expires Feb.27, 2019. Independent certificate of compliance with SON requirement.

[09-Jan-2019] AEPB - Abuja Environmental Protection Board NESREA - Nigerian Environmental Standard Regulatory Agency NAFDAC - National Agency for Food & Drug Administration and Control SON - Standard Organization of Nigeria These are the regulatory agencies and permits from all of them is mandatory. Relevant approvals are seen on site during audit. Findings accepted

4.2 Maintain or improve site water balance

4.2.1 Measurement-based evidence showing that targets have been met 4.2.2 (Water scarce catchments only) Evidence of continual

Core Targets are met up to date. Available in the weekly water use ratio report.

[09-Jan-2019] Daily water usage is displayed on the factory board. NBC also has monthly achievement displayed on factory board. And also available on WUR report. Photographic evidence of monthly summary shows target has been met. It was also evident during audit that there is decrease in water consumption.




decrease or best practice 4.2.3 (Sites wishing to increase withdrawals in water scarce catchments only) Evidence of no net increase in water scarcity

NBC is not drawing water from water scarce catchment. Findings accepted.

4.3 Maintain or improve site water quality

4.3.1 Measurement-based evidence showing that targets have been met 4.3.2 (Water quality-stressed catchments only) Evidence of continual improvement or best practice 4.3.3 (Sites wishing to increase effluent levels of water quality parameters of concern in water quality-stressed catchments only) Evidence of no net degradation in water quality in the catchment

Core Water quality targets were met up till date. Evident in the document Raw Water Treatment program July 2018

[09-Jan-2019] NBC has Raw Water treatment report and effluent water treatment report. These are seen during audit and found satisfactory. Findings accepted

4.4 Maintain or improve the status of the site’s Important Water-Related Areas

4.4.1 Documented evidence showing that targets have been met 4.4.2 (Degraded Important Water-Related Area catchments only) Evidence of continual improvement or best practice

Core Best Management Practise (BMP) Top 10 water saving initiative October 15th, 2018

[09-Jan-2019] During site audit these documents are referred and found satisfactory. Findings accepted

4.5 Participate 4.5.1 Documented Core There was a stakeholder meeting with FCT [09-Jan-2019] During audit all the relevant




positively in catchment governance

evidence of the site’s ongoing efforts to contribute to good catchment governance 4.5.2 (Weak water governance catchments only) Evidence of continual improvement or best practice

water board on November 21st, 2018 and also with FCT water board and communities (Usman and Mpape) around the Usman dam on December 6th, 2018. Though no meeting attendance list was provided but from the minutes of the meetings, one of the issue discussed was water catchment governance.

evidences were shown and found satisfactory. Findings accepted

4.6 Maintain or improve indirect water use within the catchment

4.6.1 List of suppliers and service providers, along with the actions they have taken as a result of the site’s engagement relating to indirect water use

Core Available hand writing list of primary input suppliers (Sugar-Dangote, C02-Contour Global, Water-FCT board, Crown-Frigoglas, Avon; Preform-Idorama, Somex, Prima and Lotus; Closure Plastic-Idorama, Prime and Sonnex; Glas-Frigoglass. Indorama stopped using water chillers and installed new aircooled chiller on her line that reduced water usage by 17% less.

[09-Jan-2019] During site audit these documents are referred and found satisfactory. One snap for "Supplier Water Management Evaluation" is shared. Findings accepted

4.7 Provide access to safe drinking water, adequate sanitation and hygiene awareness (WASH) for workers on-site

4.7.1 List of actions taken to provide workers access to safe water, effective sanitation and protective hygiene (WASH) on-site

Core Provision of hand wash stations, which include; hand dryers, hand sanitizer, washing soap dispenser. Provision of WASH self-assessment tool for staffs evaluation as contains in the document 'Abuja WBCSD WASH self-assessment tool'. But there is need for improvement in the conditions junior staffs wash room because water closet, taps and urine points are not in good conditions

[05-Jan-2019] Auditor has submitted photographic evidences. Finding accepted

4.8 Notify the owners of shared water-related infrastructure of any concerns

4.8.1 List of individuals contacted and key messages relayed

Core No shared water-related infrastructure

[09-Jan-2019] NBC do not have any shared infrastructure at Abuja plant as described by Auditor. Findings accepted

4.9 Achieve best practice results on site water balance

4.9.1 Quantified improvement in water balance from site-set baseline date 4.9.2 Evidence showing that actions meet best practice

Advance No benchmarking from industry specific stakeholders





expectations

4.10 Achieve best practice results on site water quality

4.10.1 Quantified improvement in water balance from site-set baseline date 4.10.2 Evidence showing that actions meet best practice expectations

Advance By monitoring the effluent and reporting quarterly to AEPB

[09-Jan-2019] All monitoring reports are submitted to AEPB for regular permits. AEPB send benchmark to individual industries for compliance and permit. This benchmark is not sector specific (its common). Against this NBC set target and achieved it. Hence no reference of best practice achieved. Finding closed

4.11 Achieve best practice results on Important Water-Related Areas through restoration

4.11.1 Evidence of completed restoration of non-functioning or severely degraded Important Water-Related Areas 4.11.2 Evidence showing that actions meet best practice expectations

Advance No evidence


4.12 Achieve best practice results and strengthen capacity in water governance

4.12.1 List of efforts to positively engage and strengthen water governance capacity from a site-set baseline date 4.12.2 Evidence showing that actions meet best practice expectations

Advance IRP waste water recovery tank

[09-Jan-2019] Iron Remover Plant (IRP) is a facility to recover all the waste water from plant and reuse it. This practice is one of the general practices used at plants. Criteria is talking about best water governance that is achieved hence this finding is not accepted.

4.13 Advance regionally specific industrial water-related benchmarking

4.13.1 List of efforts to contribute to regionally specific benchmarking and spread best practices

Advance No benchmarking from industry specific stakeholders


4.14 Re-allocate saved water for social or environmental needs

4.14.1 Total volume of water officially re-allocated for social and environmental needs (in m3 or Mm3)

Advance No water re-allocated for social needs





4.14.2 Documentation of legal contracts for the reallocation of water to social or environmental needs

4.15 Engage in collective action to address shared water challenges

4.15.1 List of collective action efforts, including a description of the role played by the site 4.15.2 Quantified improvement in outcome(s) or shared water challenge(s) from site-set baseline date 4.15.3 (For extra points only) Stakeholder-based evidence recognizing that the site played a material role in the improvement

Advance No list of collective action efforts with other interested entities in the catchment


4.16 Drive reduced indirect water use throughout the site’s supply chain and outsourced water-related service providers

4.16.1 List of suppliers with details on engagement efforts 4.16.2 Quantified improvement by the supplier as a result of this engagement 4.16.3 (For extra points only) Supplier-based evidence recognizing that the site played a material role in prompting the change

Advance List of suppliers with engagement effort at corporate level

[09-Jan-2019] Audit findings refer to the same document for "Form- Supplier Water Management Evaluation". This document shows that NBC has initiated the effort towards indirect water stewardship but now in maiden stage. And it is not evident that improvement for two suppliers is due to NBC engagement. Hence for better effort in future findings toward these criteria are not accepted. Feedback: NBC has to document the engagement level / role (advisor, instructor, etc) for each supplier and quantify water consumption improvement.

4.17 Complete implementation of water-related initiatives

4.17.1 Appropriate documentation or evidence of completion of initiative

Advance NBC CSR initiative

[09-Jan-2019] Though NBC has adopted AWS standard recently but they are doing water related initiative for a long time. As per Section 1.4. - the initiatives that are listed there are completed based on briefing from Auditor. Hence, findings against these criteria



AWS Criteria Indicators Level Auditor’s Findings Certifier’s Response are accepted.

4.18 Provide access to safe drinking water, adequate sanitation and hygiene awareness offsite

4.18.1 List of actions taken to provide catchment stakeholders with access to off-site access to safe drinking water, adequate sanitation and hygiene awareness.

Advance Kushigoro Community request for a Motorized Borehole on 5th June, 2018. It was commissioned in 2018. (Picture evidence)

[09-Jan-2019] During audit evidence shown toward accessible safe water drinking for community. There are records which reflect NBC has conducted awareness session for communities along with FCT. Finding accepted

Step 5: EVALUATE – Evaluate the site’s performance


5.1 Evaluate the site’s water stewardship performance, risks and benefits in the catchment context

5.1.1 Post-implementation data and narrative discussion of performance and context (including water risk) 5.1.2 Total amount of water-related costs, cost savings and value creation for the site based upon the actions outlined in 3.2 (drawn from data gathered in 2.4.6) 5.1.3 Updated data for indicator 2.4.7 on catchment shared value creation based upon the actions outlined in 3.2

Core Available in the document 'NBC Water cost 2017 Abuja plant'. Available document name 'Water 2016 Region' Proposed Installation of Automatic valve to prevent tank overflow was proposed in July 2016 and implemented in 2017 with these water valves sited during site tour.

[09-Jan-2019] These documents are control document and were referred to auditor during audit. Auditor has seen these documents and satisfactorily concluded that it fulfills requirement as per indicators. Auditor is request to collect result page copy as evidence. Findings accepted

5.2 Evaluate water-related emergency incidents and extreme events

5.2.1 Documented evidence (e.g., annual review and proposed measures)

Core Report on Assessment of Strom Water Recipient Environment of Abuja Plant July 2017

[09-Jan-2019] Report referred in findings is for Oil Spil on-site. NBC also track, monitor and draw prevention plans for leakage of water - SWPP. Findings accepted




5.3 Consult stakeholders on water-related performance

5.3.1 Commentary by the identified stakeholders

Core Input from stakeholders including FCT water board, Kuchigoro and Karamajiji communities in the stakeholders meeting held on December 6, 2018 for site water stewardship. Minutes of the meeting and attendance list.

[09-Jan-2019] It is evident that NBC has taken step for stakeholder consultation over their water-related performance. As the consultation was held on Dec-2018, NBC could not show utilization of this commentary for updation of plan. Findings accepted

5.4 Update water stewardship and incident response plans

5.4.1 Modifications to water stewardship and incident response plans incorporating relevant information

Core Water incidence reponse plan especially for the oil spill was conducted in the Follow-up Incidence Management and Crisis Resolution (IMCR) meeting June 29, 2017

[09-Jan-2019] As this is the first iteration / round for NBC for implementation of AWS standard, hence this criteria is granted acceptance. Feedback - NBC need to develop emergency response plan as referred in feedback for 5.2 above.

5.5 Conduct an executive or governance body-level review of water stewardship efforts

5.5.1 Agenda and minutes of executive team or governance body meeting noting water stewardship discussion

Advance EMS management review minute Abuja March 2018. Water issue was one of the topic treated.

[09-Jan-2019] Though NBC is conducting a regular review in presence of top most authority at plant level but requirement for this criteria is that NBC need to conduct the similar review at organization or group level. Hence finding is not accepted

5.6 Conduct a formal stakeholder evaluation

5.6.1 Documentation of formal stakeholder evaluation with recommendations for updated Criterion 3.5

Advance There was a stakeholder meeting with FCT water board on November 21st, 2018 and also with FCT water board and communities (Usman and Mpape) around the Usman dam where issue of shared water challenge (plastic waste on the dam) was evaluated and recommendations were made

[09-Jan-2019] As this the first round for NBC, they have identified the water related challenges and preparing plans for reducing this challenge, hence this criteria is not applicable for this audit cycle. Finding is not accepted.

Step 6: COMMUNICATE & DISCLOSE – Communicate about water stewardship and disclose the site’s stewardship efforts


6.1 Disclose water-related internal governance

6.1.1 Disclosed and publicly available summary of governance at the site, including those accountable for compliance with water-related laws and regulations

Core Available environmental Audit report August 2016 containing the water related governance structure. This report submitted to AEPB and NESREA

[09-Jan-2019] As per the Auditor's findings "Environmental Audit Report 2016" has an organogram which reflects sites governance system with reference to water. NBC has submitted this report to govt. agencies and public institutions and have considered these submissions as public disclosure as anyone can approach these bodies for this report. Finding accepted with a forward action request. FAR - NBC is request to disclose the water-



related governance publically with reference to AWS Standard Version 1.0 (page 159)

6.2 Disclose annual site water stewardship performance

6.2.1 Disclosed summary of site’s water stewardship results

Core Available environmental Audit report August 2016 containing the water related governance structure. This report submitted to AEPB and NESREA

[09-Jan-2019] As per the Auditor's findings "Environmental Audit Report 2016" has an organogram which reflects sites governance system with reference to water. NBC has submitted this report to govt. agencies and public institutions and have considered this submissions as public disclosure as anyone can approach these bodies for this report. Finding accepted with a forward action request.

6.3 Disclose efforts to address shared water challenges

6.3.1 Disclosed and publicly available description of shared challenges and summary of actions taken to engage stakeholders (including public-sector agencies)

Core No publicly disclose shared water challenge

[09-Jan-2019] As this is the first year for AWS implementation for NBC hence they have not disclosed the shared water challenges that are identified this year. But yes as NBC is working with & for community for years over water-related issues they have disclosed on their CSR report (publically) about the challenge that they have worked upon for Karamanji River. Hence the auditors finding after discussion with him is changed as accepted as conformity. Feedback - NBC has to disclose all the water-related challenges that they have identified in year 2018 publically along with summary of actions taken to engage stakeholders

6.4 Drive transparency in water-related compliance

6.4.1 Available list of water-related compliance violations with corresponding corrective actions

Core 2017 GRI Contex index Coca-Cola Hellenic Bottling company

[09-Jan-2019] NBC's GRI report for 2017 is a publically available report and during audit it was observed that the required indicator is also available on report and found satisfactory. Findings accepted. https://coca-colahellenic.com/Campaigns/AnnualReport2017/assets/pdf/Coca-Cola-HBC-2017-GRI-Content-Index.pdf

6.5 Increase awareness of water issues within the site: Strive to raise the understanding

6.5.1 Record of awareness efforts (dates and communication) and, if possible, level of

Core Available training records on water conservation (22/11/2018) Near loss awarenes (05/12/2018), Environmetal management system (01/02/2018), Top 10 water saving initiative, SWPP e.t.c

[09-Jan-2019] Based on all the training and awareness session records that was referred to Auditor during audit and found satisfactory. Findings accepted



of the importance of water issues at the site through active communications.

awareness

6.6 Disclose water risks to owners (in alignment with recognized disclosure frameworks)

6.6.1 Written evidence of site-based material water risk information conveyed to owners 6.6.2 (For extra points only) Disclosure to owners in a format that is consistent with the requirements of a recognized disclosure framework

Advance No [09-Jan-2019] Findings accepted

6.7 Implement a programme for water education

6.7.1 Description of water-related education program


6.8 Discuss site-level water stewardship in the organization’s annual report

6.8.1 Page number of annual report containing site based AWS reference


alliance for water stewardship (aws) audit report...must be scheduled within 13 months. hence, next...

Documents