IFC requires that this document is made available through the World Bank InfoShop and to the locally affected community no less than 30 days prior to project consideration by the IFC Board of Directors. The Summary of Project Information (SPI) also provides details of where the ERS has been made available to the locally affected community. The SPI must be sent to World Bank InfoShop no less than 30 days prior to project consideration by the IFC Board of Directors.

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. The review of this project consisted of appraising technical and environmental/social information submitted by the project sponsor. The following potential environment, health and safety, and social impacts of the projects were analyzed. - community development; - wildlife management and natural habitats; - waste disposal and treatment; - water and power supply; - energy efficiency; - guest and staff safety; - fire safety; and - staff training.

The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. The five properties that form the project are as follows: The Norfolk Hotel is a 75 plus year old hotel located in central Nairobi. The Aberdare Country Club is a 50 plus year old bungalow style hotel that sits on a 1300 acre conservation area, there are no known land use conflicts as and the property used to be a private farm. The Mt. Kenya Safari Club sits on a 100 acre site and has no known land use conflict as it is also a 50 plus year old property. The Ark - a 35 year old property, is located in the Aberdare National Park and management issues are coordinated with and determined by the Kenya Wildlife Service (KWS). The number of beds/rooms at The Ark will not be increased without prior IFC and KWS approval. The Mara Safari Club built 15 years ago, is located on the Ol Choro Oirowua Group Ranch Conservation Area. It should be noted that the Mara Safari Club was built prior to the self imposed moratorium on development called for in the Greater Mara area by various industry associations, as well as several NGOs. No expansion of this property is planned by KHI. It should be noted that KHI and Fairmont have shown a strong openness and willingness to address community and conservation issues and to be eco-friendly on the waste/water/energy front (solar, wetlands etc.) and have requested IFC to assist with addressing the issues. In order to identify the range of issues associated with each specific property, action plans for each property are being developed together with additional studies on specific properties. Independent Environmental Audits, focusing also on labor and social issues, for all five properties are currently being conducted based on TOR and consultants the sponsor identified in coordination with IFC. These audits will also incorporate resource efficiency (solar, recycling) and wetland effluent treatment (for some properties) into rehabilitation plans. The Audits will include establishment of corrective action plans (CAP) for all properties. A table summary of the CAP will be made public at the local level and through the World Bank Infoshop. Independent Fire Safety Audits for the Norfolk Hotel and the Mt. Kenya Safari Club are necessary given the physical structure of these properties. The Aberdare Country Club is located on a 1300 ha conservation area, the sponsor will develop a Management Plan for this conservancy and coordinate all wildlife related issues with the Kenya Wildlife Service (KWS). The Mara Safari Club is located on the Ol Choro Oirowua Group Ranch Conservation Area. With the community KHI will seek to improve management of the conservation area. Ol Choro Oirowua has a trust which was established in order to ensure revenue earned from tourism in the Ol Choro Oirowua Conservation Area is used for community benefit. To effectively monitor and manage the range of issues associated with the Lonrho properties, KHI should develop an integrated corporate Environmental Management System that defines roles and responsibilities and formalizes tasks to address all key issues discussed above.

Accordingly, IFC concludes that the proposed project will meet the applicable World Bank/IFC environment and social policies and the environmental, health and safety guidelines upon successful implementation of the agreed mitigation measures. This ERS will be translated into Swahili and made available locally through the five properties, and the respective local municipal offices of Nairobi, Nanyuki, Ol Choro Oirowua and Nyeri; availability of the document at these locations will be advertised in a national newspaper and notices of it's availability should be posted at the local municipal offices. In addition oral presentations of the ERS in Maa will be made at Ol Choro Oirowua.

IFC will evaluate the project's compliance with the applicable environmental and social requirements during the lifetime of the project through the following methods: - Review of the annual monitoring reports (AMRs) prepared for the project. - Ongoing performance of project-specific environmental, health and safety activities; and - Periodic site supervision visits will also be conducted, if necessary.