CORRECTIVE ACTION PLAN
    
 
ACTION ITEM
 
REQUIRED COMPLETION DATE
  
1) Prepare Corporate Policy Statement. Write a Ruchi policy statement for the food manufacturing elements of the organization (edible oils, Vanaspati, and extractions) that clearly defines Ruchi's position (e.g. vision and mission and consumer relations) regarding production and product quality, environmental management, and occupational health and safety.
 
Condition of first disbursement
  
 
2) Management Endorsement of Corporate Policy. Obtain senior management endorsement of the policy statement; announce the existence of the management approved corporate policy and distribute the corporate policy to all employees and management staff and contractors. Conduct briefings at all food manufacturing plants in all divisions explaining the quality, environment and occupational health and safety policy and how it will be implemented and integrated through the creation of an integrated management system addressing production and product quality, environmental management and occupational health and safety.
   
Condition of first disbursement
  
 
3) Conduct management system (e.g. ISO 9001) needs assessment. With external assistance conduct an audit of existing operations at Chennai, Mangalore, Indore and planned operations at Mumbai (Patalganga) and Nagpur. Prepare an implementation Action Plan and a detailed schedule to integrate and to implement the corporate policy through the use of an internationally recognized integrated management system such as (e.g. ISO 9001-2000) that will facilitate systematic management of production and product quality, environmental management and occupational health and safety.
 
Identify Specialized Firm and Sign Contract to Conduct the Needs Assessment
Within six (6) months of the first disbursement
    
4). Implement Management Systems   In accordance with schedule below.
  
" Implement integrated management system at Indore
" No later than 18 months after first disbursement
  
" Implement integrated management system at Patalganga and Chennai (all edible oils and vanaspati operations)
" No later than 24 months after first disbursement
  
" Implement integrated management system at Nagpur (all edible oils and vanaspati operations)
" No later than 24 months after first disbursement
  
" Implement integrated management system at Mangalore (all edible oils and vanaspati operations)
" No later than 24 months after first disbursement
  
5) Management System Certifications. Obtain internationally recognized certification (e.g. ISO 9001-2000) of Ruchi production and product quality, environmental management and occupational health and safety management system for all Ruchi edible oil operations.
 
No later than 36 months after first disbursement. Certification to be provided by an agency licensed to provide ISO certification.
  
 
6) Occupational Health and Safety Programs Audit. With external assistance conduct an audit of occupational health and safety practices and programs in existing operations at Chennai, Mangalore, and Indore and planned operations at Mumbai (Patalganga) and Butibori (Nagpur). The audit shall include an assessment of hazardous materials management practices. The audit shall define the gaps between existing operations and systematic management of occupational health and safety and hazardous materials management for operations as required by IFC Occupational Health and Safety and Hazardous Materials Management guidelines. The audit report shall incorporate facility specific Corrective Action Plans detailing specific tasks required to close the gaps between existing operations and practices and IFC guideline requirements that were defined in the occupational health and safety and hazardous materials management audits. Completion dates for all corrective action items shall not exceed the following.
 
No later than six (6) months after first disbursement
  
" Occupational Health and Safety and Hazardous Materials Corrective Actions
" No later than six (6) months after first disbursement.
  
" Complete all occupational health and safety and hazardous materials management programs action items defined in the audit described in Item No. 6 above at Mangalore (all edible oils and vanaspati operations).
" No later than twelve (12) months after commencement of operations.
  
" Complete all occupational health and safety and hazardous materials management action items defined in the audit described in Item No. 6 above at Chennai (all edible oils and vanaspati operations).
" No later than eight (8) months after first disbursement
  
" Complete all occupational health and safety and hazardous materials management action items defined in the audit described in Item No. 6 above at Indore (all crushing and edible oils and vanaspati operations).
" No later than twelve (12) months after first disbursement
  
7) Energy Monitoring and Benchmarking Program. Prepare an Energy Plan for each refinery and crushing plant (IFC will provide the format and the description of the requirements for Plans and committees). Create required energy committees in each plant and establish baseline use quantities. Assign corporate management sponsorship. Benchmark energy consumption with other Ruchi operations on a monthly, quarterly and annual basis. Promote competitions to reduce energy consumption per unit of product production.
 
No later than three (3) months after the first disbursement
  
 
8) HACCP Audits and Certification. With external assistance conduct an audit of existing consumer packaging operations at Chennai, Mangalore, Indore and planned operations at Mumbai (Patalganga) and Nagpur. Prepare an implementation Action Plan and a detailed schedule to achieve HACCP certification of all consumer product packaging operations.
 
No later than six (6) months after the first disbursement
  
" Achieve HACCP Certification
In accordance with schedules below.
  
" Patalganga [Mumbai] and Nagpur
" No later than twelve (12) months after commencement of operations.
  
" Mangalore
" No later than eighteen (18) months after first disbursement.
  
" Chennai
" No later than eighteen (18) months after first disbursement.
  
" Indore
" No later than eighteen (18) months after first disbursement.
  
9) Facility Cleaning. Institute continuous cleaning programs for Ruchi food manufacturing, packaging and storage activities. Provide adequate facilities, equipment and training for assigned employees. Clean oil, dust, and raw materials residues from floors, stairs and handrails, doors, walls, ceilings, etc. Modify employee training and service contract specifications to mandate clean-as-you-go practices in each shift in all operations. Maintain cleanliness consistent with food manufacturing facilities at all times.
 
No later than six (6) months after first disbursement.
  
 
10) Solid Waste Management. Provide collection containers for accumulation and removal of solid wastes at the point of generation in all food manufacturing operations. Train employees and require contract employees to immediately clean up spills and to place wastes in collection containers. After each shift remove collected solid wastes to facility specific, assigned accumulation points for subsequent sale, off-site disposal or on-site management. Continuously manage solid waste in accordance with permitting requirements mandated by Pollution Control Boards.
 
No later than three (3) months after first disbursement.
  
" Bring food manufacturing facilities into compliance with solid waste management requirements.
In accordance with schedules below.
  
" Chennai
" No later than three (3) months from the date of the first disbursement
  
" Indore
" No later than six (6) months from the date of the first disbursement
  
" Manglore
" No later than six (6) months from the date of the first disbursement
  
" Mumbai (Patalganga) and Nagpur
" No later than six (6) months from the date of the first disbursement
  
11) Acquisition Due Diligence. With external assistance audit management practices in quality, occupational health and safety, HACCP in food product packaging, facility cleaning, and waste management and discharges to the environment (air, water, storm water) for target acquisitions. Define required improvements in proposed acquisition; establish completion date for all corrective measures to comply with IFC policies and guidelines.
 
Prior to first proposed acquisition.
  
 
12) Annual Monitoring Report Format. Reach agreement with IFC Environmental and Social Development Department on format for annual environmental performance report required by IFC investment contract. Provide formats to food manufacturing operations managers. Obtain agreement on format, content. Ensure that facility managers collect adequate data throughout the operating year to complete the annual reports for IFC.
 
Condition of first disbursement.
    
  BACK