SOCOCIM Low Carbon Cement

In November 2022, IFC approved a €120 million IFC A-loan to SOCOCIM Low Carbon Cement to construct a “highly fuel-efficient plant” to replace SOCOCIM’s two legacy plants. In December 2024, IFC approved a re-committable A-loan of up to €75 million, SOCOCIM Low Carbon Cement II, to support working capital and additional capital expenditures related to the same project.

The project is classified as Category B Limited, with key environmental and social risks including air emissions, noise and vibrations, transport-related community safety impacts, occupational health and safety concerns, and the need for effective stakeholder engagement and grievance mechanisms. The project also presents supply chain health risks  related to coal and petcoke sourcing, and potential child labor, forced labor, and labor safety issues. Mitigation measures include an Environmental and Social Action Plan (ESAP), supplier CSR clauses on labor, health, and safety, and planned supply chain risk assessments. However, the project’s location in a densely populated industrial area could exacerbate pollution-related health risks and increase risks of child labor and child sexual exploitation, abuse and harassment (SEA/H) linked to labor influx and supply chains. 

In October 2025, BIC partnered with Lumière Synergie Développement (LSD) to examine the project’s design and implementation, focusing on: (a) the inclusion or exclusion of measures to prevent child labor, including in supply chains; (b) gender-based violence (GBV) and child SEA/H prevention, mitigation, and response measures; (c) labor conditions and occupational health and safety; and (d) response and mitigation measures for environmental risks and associated health impacts. 

ESIA review: Child Protection and GBV Measures

The 2022 Environmental and Social Impact Assessment (ESIA) identifies significant risks of gender-based violence during construction and operations, including sexual abuse, verbal harassment, discrimination against women, workplace GBV, and physical violence.

To mitigate these risks, the ESIA recommends:

• Establishment of GBV grievance mechanisms and complaint committees;
• Coordination with security actors;
• Staff training and awareness on GBV prevention;
• Gender-equitable recruitment practices;
• Prohibition of child labor.

While these measures provide an initial framework, the ESIA does not include child-specific safeguarding measures, child SEA/H risk assessments, survivor-centered response protocols, referral pathways, confidentiality procedures, or child-sensitive grievance mechanisms. Significant gaps remain in the project’s ability to identify, prevent, and respond to risks affecting children.

Although the ESIA recognizes SEA/H and GBV as significant project risks, these issues are not reflected in the ESIA Summary or the Environmental and Social Action Plan (ESAP). As a result, no corresponding mitigation, response, monitoring, or accountability measures were incorporated into the ESAP to address these risks, limiting the project’s ability to systematically prevent, monitor, and respond to SEA/H and GBV risks in the community and supply chains.

BIC, and our partner, LSD, identified the following concerns:

1. High risk of child SEA/H. No cases of project-related child SEA/H were reported during monitoring. However, community members consistently identified children as highly vulnerable due to poverty, labor influx, transport activity, and the project’s location within a densely populated industrial area. Stakeholders emphasized that no independent assessment has been conducted to evaluate child-related risks, especially SEA/H risks associated with operations, labor influx, and supply chains. Additionally, children are frequently engaged in informal economic activities, including food vending, restaurant work, and roadside commerce along truck routes. Community members noted that these conditions increase exposure to risks of SEA/H exploitation, abuse, and trafficking. 
2. Lack of child SEA/H protection and response measures. Community members reported that ESIA consultations focused primarily on environmental concerns and did not address risks to child protection or safeguarding measures. Local child protection committees, schools, women’s groups, and youth representatives reported they were unaware of any child SEA/H prevention or response measures linked to the project. No child-focused SEA/H awareness materials, reporting channels, or referral systems were identified. 
3. Weak grievance and reporting systems. Community members expressed limited trust in existing reporting structures. The Gouye Mourid Local Development Collective (CODEL), which serves as a key community interface, is reportedly led by a company employee, raising serious concerns about the confidentiality and independence of complaint handling, given the potential conflict of interest. Community members were largely unaware of project grievance mechanisms, complaint procedures, or IFC’s independent accountability mechanism. No publicly available information was identified regarding community grievances received, complaint outcomes, or management procedures.
4. Child labor concerns. Community members reported indirect child labor, including children collecting cement residues for resale and working in roadside food stalls serving truck drivers. These activities are occurring without adequate child protection measures in place, and increase exposure to exploitation, school dropout, and unsafe working conditions. On March 21, 2019, a teenager without a national ID card was killed in a tragic accident at the cement plant while working as an apprentice welder for a SOCOCIM subcontractor. Aside from the construction of two rooms, the widow, who is the head of the household, has received no other form of compensation. Monitoring teams were unable to access mining sites due to delayed approval from SOCOCIM management, limiting the independent assessment of child labor prevention measures in quarry operations and related supply chains. 
5. Community health and environmental impacts. Community members, health professionals, and teachers consistently reported respiratory illnesses among children, including asthma, chronic coughs, allergies, and recurrent respiratory infections. Residents attributed these health concerns to dust emissions and air pollution from cement production activities. Schools and homes are located in close proximity to industrial facilities, increasing children’s exposure to pollutants. Additional concerns include:
   • Dust accumulation in homes and schools;
   • Lack of publicly available air quality monitoring data;
   • Potential soil contamination affecting agriculture and food security;
   • Structural damage to homes linked to blasting vibrations; and 
   • Environmental pressures contributing to household relocation
6. Traffic and community safety risks. Heavy truck traffic associated with cement transport continues to pose community safety concerns. Community members reported roadside truck parking, traffic congestion, blocked access routes, and increased risks to pedestrians, particularly children. Although a Traffic Management Plan reportedly exists, it was not publicly accessible during monitoring.
7. Transparency and information disclosure. Several environmental and social studies and management plans, including air quality, traffic, and dust management plans, have reportedly been developed. However, these documents are not publicly available on IFC or SOCOCIM websites, limiting community oversight and informed stakeholder engagement.

In November 2022, IFC approved a €120 million IFC A-loan to SOCOCIM Low Carbon Cement. In December 2024, IFC approved a re-committable A-loan of up to €75 million, for SOCOCIM Low Carbon Cement II.

Our recommendations to IFC are outlined as follows:

1. Require an independent child safeguarding risk assessment: Require SOCOCIM to conduct a comprehensive assessment of project-related risks to children, including environmental health impacts, labor influx risks, supply chain vulnerabilities, child labor, and SEA/H risks.
2. Integrate child safeguarding into the ESAP and monitoring framework: Require SOCOCIM to develop child-specific mitigation measures, indicators, and monitoring requirements. These measures should be aligned with IFC’s new Good Practice Note, Addressing Child Safeguarding in the Private Sector, which provides clear guidelines for child SEA/H prevention, mitigation, and response measures that companies should adopt.
3. Establish child-sensitive grievance mechanisms: Support SOCOCIM in creating safe, accessible, confidential, and child-friendly reporting channels linked to referral services, child protection authorities, and community-based support systems.
4. Strengthen supply chain due diligence: Require SOCOCIM to expand monitoring of suppliers and contractors to identify and address child SEA/H, child labor, exploitation, and safeguarding risks across the supply chains.
5. Enhance stakeholder engagement: Require SOCOCIM to engage more systematically with community child protection committees, schools, youth groups, women’s organizations, and community leaders to identify and mitigate child-related risks, including child SEA/H.
6. Address environmental health risks: Require SOCOCIM to install community-level air quality monitoring systems, publicly disclose monitoring results, conduct independent health impact assessments, and strengthen dust mitigation measures.
7. Strengthen traffic safety measures: Require SOCOCIM to update and enforce the Traffic Management Plan, address informal truck parking, improve contractor compliance, and strengthen community awareness of mitigation measures and complaint channels.
8. Improve transparency and information disclosure: Both IFC and SOCOCIM should publicly disclose all relevant environmental and social studies, management plans, monitoring reports, and action plans to strengthen accountability and community oversight.