While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts that must be managed in a manner consistent with the following Performance Standards: PS1: Social and Environmental Assessment and Management Systems PS2: Labor and Working Conditions PS3: Pollution Prevention and Abatement PS4: Community Health, Safety and Security PS5: Land acquisition and Involuntary Resettlement PS6: Biodiversity and Natural Resource Management Performance Standards 1-4 apply to all the projects, while PS5: Land Acquisition and Involuntary Resettlement is only applicable to the site identified for the new 2-star Travelhouse hotel in Festaec, Lagos. The other site identified for the Ibis hotel is currently vacant. PS 6: Biodiversity and Natural Resource Management applies to the Epe Resort and Spa facility, whereas all of the other existing facilities and sites acquired for future developments are located within urban areas with the areas having been previously cleared of vegetation, or developed. Aside from the Epe Resort and Spa which is being constructed on uninhabited land on the outskirts of Epe, all the other existing and planned developments occur in urban areas; thus PS: 7 Indigenous Peoples, does not apply. PS: 8 Cultural Heritage may apply to future sites to be acquired and this will need to be confirmed in the respective Environmental Impact Assessments to be undertaken for the projects. Given the dynamic nature of the hospitality in Nigeria, it is acknowledged that further developments may be proposed by MPL outside of the current project scope as described in this document. Thus as defined in the Environmental and Social Action Plan (ESAP), MPL will develop a due diligence procedure to screen potential projects against the Performance Standards. The findings of the due diligence will then be submitted to IFC for review and confirmation as to how environmental and social issues are to be managed.

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects due to the limited number of site specific environmental and social impacts that may occur and which can be avoided or mitigated by adhering to generally recognized performance standards, programs, guidelines or design criteria. Aside from the hotels under the Travelhouse brand, MPL is only directly involved in the construction phase of projects. Thereafter, Accor assumes responsibility for operations and this company has extensive experience in the management of hotels and has defined environmental and social policies that are applied to operations. The review of MPL’s developments to date indicates that environmental and social issues are typically managed in general accordance with IFC’s Performance Standards during the construction and operational phases. Nonetheless, as defined in the attached ESAP, existing operations, including the facility under construction, are required to implement specific actions so as to ensure compliance with IFC Performance Standards. As it applies to the new developments, it will be necessary for MPL to demonstrate compliance with the Performance Standards prior to development proceeding.

The Company has presented plans to address the potential environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to MPL, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and applicable elements of IFC’s Environmental, Health and Safety (EHS) Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the ESAP which is disclosed with this document. Social and Environmental Assessment and Management Systems In terms of the Nigerian Environmental Impact Assessment (EIA) Decree of 58 of 1992, specific types of developments, including hotels, require an EIA. Thereafter, depending on the site location, re-zoning may be required, along with mandatory approval of building plans. To date, MPL have complied with this requirement and completed EIAs for all their developments. An EIA is required prior to any planning and building approvals and thereafter a Letter of Approval is issued by the relevant government authority. For future developments, the Company will be required to submit copies of all necessary approvals to IFC prior to the commencement of construction. During construction, MPL appoints a Project Manager who is responsible for the individual construction site, including ensuring compliance with occupational health and safety plans and applicable legislation. For new developments, as defined in the ESAP, an Environmental. Health and Safety (EHS) Plan will be required for tender documentation and the appointed contractor will be contractually bound to ensure compliance. Thereafter, MPL will undertake monitoring to ensure compliance and report thereon to IFC. Aside from hotels trading under the Travelhouse brand, all of the facilities in which MPL has invested are managed and operated by Accor which has a clear program (the “Environmental Charter”) for improving the environmental footprint of its hotels worldwide, including in Africa. The Environmental Charter includes guidelines covering eight areas: information and awareness, energy, water, waste water, waste, ozone layer, biodiversity, and ‘green’ purchases. This program applies to all new hotels, including the ones in this project. Further, Accor also has a program of audits and reviews for all of the hotels they own and manage, which include environmental audits. These audits are used to develop action plans for the hotels. Responsibility for implementing the environmental program and audits for individual hotels resides with the Hotel Manager. To a large extent the system is dependent upon the commitment of the individual manager. Thus, as per the ESAP, the Conditions of Agreement for all managerial appointments will be amended to require compliance with environmental and social management issues and thus this will be one of the variables upon which performance is evaluated. Accor has an “Accor Hotels Environmental Charter Practical Guide” (the “Guide”) that defines the general method of implementation for each of the guidelines and the stage at which each item is considered complete. Under the Travelhouse brand of hotels, the General Manager is responsible for environmental and social management. Equally, the Conditions of Agreement for this position will be amended to include compliance with environmental and social management issues as a basis for undertaking performance evaluation. To formalize management of environmental and social issues in the operational phases of all facilities, where these are not available through Accor, MPL will compile specific procedures for key issues such as the monitoring of potable and waste water, amongst other aspects. These procedures will then be applied to all the hotels, thereby standardizing implementation. Finally, MPL is required to compile an Action Plan so as to consolidate the requirements of the ESAP, along with any conditions of approval from authorizing government agencies for the individual projects, and report on compliance with the Plan. Labor and Working Conditions Accor has a human resources policy that applies to all its operations in Nigeria and is aligned with IFC’s PS2 requirements. Nigeria has ratified the International Labor Organization’s Core Labor standard and thus, by meeting applicable national law, the Company will also be meeting the requirements of PS 2. Accor has signed an agreement, dated 1995, with the International Union of Food, Agricultural, Hotel, Restaurant, Catering, Tobacco and Allied Workers' Associations (IUF) ensuring the rights of workers to collective bargaining and freedom of association. Employment under the Travelhouse hotel brand is limited to approximately eleven individuals per facility. The hotels have no kitchens, and functions such as cleaning are outsourced. Individuals are employed according to specific Conditions of Agreement and in accordance with national law. So as to ensure compliance with this Performance Standard, MPL will review their Conditions of Agreement against the Standard and amend these as deemed necessary. When future developments occur, MPL will be required to include the requirement for an occupational health and safety plan in tender documentation. Thereafter, the plan as compiled by the company to which the project is awarded will be submitted to IFC for review and agreement prior to construction commencing. In addition, MPL will appoint a Project Manager who will be responsible for ensuring implementation of the plan. Pollution Prevention and Abatement The provisions for wastewater treatment at existing operations, including the two Accor branded hotels and the Ibis hotel recently constructed were deemed to be adequate during the sites visits undertaken in 2009. All these facilities have packaged sewerage treatment facilities. The Travelhouse at Lekki and Ibapan currently use soakpits for sewerage disposal. This is considered inadequate given the elevated ground water table in the areas where the hotels are located. Thus, as defined in ESAP, MPL will investigate implementation of a package treatment facility at the hotels and the subsequent Travelhouse hotel will have a dedicated treatment facility. Septic tanks are to be used at the Epe Resort and Spa for the disposal of sewerage, although the long term plan is for a package treatment plant once the development plan for the site is fully realized. So as to ensure the short term measures i.e., septic tanks, are adequate, MPL will provide engineering drawings to IFC, along with confirmation from the appointed engineer that the method of disposal is considered adequate. The quality of water discharged from the package plants is regularly monitored. However, as defined previously, MPL will compile a monitoring plan and procedure that is compliant with the EHS Guidelines (2007). All the existing hotels use back-up diesel generators which vary in size from 250-1,000 kW, the latter size being used only at the Ibis hotel. All the generators are supplied with diesel from underground storage tanks (USTs) and these will be subject to pressure testing to confirm the integrity of the tanks and a schedule defined for ongoing testing. In addition, new developments will be required to either install double walled USTs, or locate the tanks within a sealed unit (e.g., cement tank enclosure), so as to minimize the potential for leaks. The annual average electricity consumption purchased from the grid is 3.8 million kWh for all the operations. In addition, 2.1 million liters of diesel are on used on average by the generators. Based on the usage of electricity and fuel, including that envisaged for the Epe Resort and Spa which will shortly be operational, the total annual estimated GHG emissions of the project are 9,900 tons CO2 equivalent. Accor is also committed to eliminating appliances that contain ozone depleting substances and as defined in the ESAP, the use of CFCs and other such substances will be avoided in all green field projects. Solid waste disposal at all the facilities is via the local municipal system. While the Accor Environmental Charter and Guide stipulates that hotel wastes should be sorted and recycled, off-site systems in Lagos, Epe and Ibapan are limited so as to accommodate such efforts. The Guide also provides guidance and targets for handling dangerous waste generated by hotels and their guests. The ESAP defines the need for a waste management procedure within the Travelhouse hotels to ensure waste is adequately managed. Periodically, all the properties are fumigated for pests and this is contracted out. As required in the ESAP, MPL are required to compile a Pest Management Plan for all the hotel operations that is consistent with IFC’s General EHS Guidelines. Community Health, Safety and Security During the operational phase, at all facilities the primary risk identified risk relates to Life and Fire Safety (LFS). All of the existing developments (operational and under construction) have LFS plans and infrastructure to manage and address such issues in the event of an emergency. These include fire detection (smoke sensors) in the individual rooms linked to an alarm system, fire hose reels and fire extinguishers on the individual levels, directional signs displayed throughout hotels and emergency response plans. Of the facilities reviewed in Lagos, all are in possession of the annual certificate indicating compliance with national regulations. Nonetheless, MPL will commission an independent review of all existing facilities (operational and under construction) to ensure LFS plans and procedures are compliant with international standards. In addition, MPL will be required to engage a qualified specialist to develop an engineering design that is responsive to IFC EHS Guidelines for all new facilities and undertake a post construction audit to confirm the facility was constructed in accordance with the original design. At all facilities water is sourced from boreholes and treated in packaged water treatment facilities that includes chlorination. Water quality is monitored on a daily basis and MPL will develop a common procedure for all facilities ensuring monitoring in undertaken in accordance with the EHS Guidelines. Security at all facilities is outsourced and provided on a 24 hour basis. There is no consistency in respect of the provision of firearms, with some facilities using armed guards, and other not; although assistance from armed guards is available when deemed necessary. As per the ESAP, a security protocol will be developed concerning the use of firearms, and the armed security will be trained according to the protocol. Land Acquisition and Involuntary Resettlement Currently this Performance Standard is only applicable to the site of the new Travelhouse hotel in Festaec, Lagos. Presently there are a number of informal traders (food vendors, mechanics, etc.) situated on a portion of the land. MPL will develop a compensation plan for these traders such that they may re-establish their businesses should they so wish. Further, the objective will be to relocate the individual businesses on sites with security of tenure in the vicinity of their current location. Prior to implementation of the compensation plan, MHL is to obtain confirmation from IFC that the plan is acceptable. In addition and as previously defined, MPL will develop a due diligence procedure against which all new projects will be reviewed to confirm the applicability of all the Performance Standards, including that related to land acquisition. Biodiversity and Natural Resource Management The Epe Resort and Spa occupies some 20 ha and is situated adjacent to a lagoon. Approximately 50% of the land cover consists of endemic vegetation and there are several non-perennial streams traversing the site. While the EIA for the project identified the need to limit the development footprint to that required for the project to minimize the destruction of vegetation, no specific recommendations have been provided. Thus, as defined the ESAP, MPL will compile a conservation plan for endemic on-site vegetation whereby the development footprint is limited to that required for the development. This plan is to define the extent to which riparian vegetation is to be conserved, including the swamp forest adjacent to the lagoon. In addition, a replanting program for endemic vegetation is to be defined in the plan. The extent to which this Performance Standard applies to new projects will be defined via the due diligence procedure to be applied to new project.

Whist EIA’s are undertaken for the project, a review of those undertaken to date indicates that the extent of stakeholder consultation varies, and can be limited. Thus, following completion of any EIA, MPL will make such documentation, including the Letter of Approval, available at agreed public places for 30 days prior to construction commencing. Accor currently posts the Environmental Charter for each hotel in a public place and this will apply to all future hotels. Additionally, all the hotels (including those under the Travelhouse brand) will post an annual environment and social action plan in each hotel describing actions to be taken to monitor such performance.

The ESRS and EAP along with any further information required about the developments in Nigeria may be obtained from the following MPL employees. Messrs Koye Edu and Gbolly Balogun, Directors Moorhouse Properties Limited, 3A Macpherson Avenue, Ikoyi, Lagos. Nigeria + 234 803 6662002 and + 234 8034030131