While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
Because this is an equity investment in a corporate entity to support future development of major Greenfield gas infrastructure - the detailed physical aspects of which have yet to be defined- to allow for fuel conversion of existing power generation assets, the principal Performance Standards to be applied at the corporate level are:
PS1: Social and Environmental Assessment and Management Systems; and
PS2: Labor and Working Conditions.
The processes for how IEH will address Performance Standards 3 through 8 for these future developments are described within the detailed PS1 narrative below.

This is a Category A investment because of the potentially significant and diverse environmental and social impacts and risks associated with IEH’s CAPEX program: a Greenfield LNG marine terminal and an associated 30-40 km gas pipeline to connect the LNG terminal to its various power generation assets; a power transmission line to interconnect the DR with Haiti; and potential additional solar and wind generation projects, among others.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives. Key risks and issues related to this investment include the Company’s capacity to: i) undertake adequate social and environmental assessment commensurate with the impacts of the Company’s projects during both construction and operations phases including the assessment of potential cumulative impacts; ii) manage the social, environmental, health and safety performance of its contractors in accordance with good international practice; iii) ensure fair, safe and healthy working conditions during construction and operations for direct employees as well as for the contract workers; iv) ensure proper handling of hazardous materials, and management of air emissions, wastewater, solid and hazardous waste during construction and operations; and v) ensure appropriate management of the impacts of construction and operations on local ambient air quality, community health, safety and security and consult and engage with potentially project-affected communities in accordance with local requirements and IFC Performance Standards.
IEH’s subsidiaries have been operating energy generation facilities and distribution and transmission lines in the Dominican Republic for over 20 years, and have demonstrated capacity to manage such facilities in compliance with applicable ESHS standards and aligned with good international industry practices (GIIP). Furthermore, some of the existing assets, such as CESPM and CEPM were financed by international financial institutions (IFIs), such as the IADB, FMO and/or the IFC, and have thus been required to comply with these institutions environmental and social performance requirements.
Environmental, social, health and safety issues that require ameliorative measures are included in the Environmental and Social Action Plan (ESAP).
E&S issues relating to the investment are summarized below along with specific information on how potential impacts and risks will be addressed by the Company. Upon implementation of the featured mitigation measures described below and in the attached ESAP, the project will comply with environmental and social requirements, namely the laws and regulations of the Dominican Republic, recognized good international industry practice, and IFC’s Performance Standards on Social and Environmental Sustainability.

Because IEH is a recently constituted entity, environmental, social, and occupational health and safety (ESHS) performance is currently managed at the company/individual site/facility level. All facilities currently hold their respective environmental licenses, and are operated in compliance with local legislation and any relevant IFI standards. All facilities share the same basic environmental management procedures which have been designed to be consistent with ISO 14001. These include (i) identification of environmental aspects and potential impacts, (ii) legal and regulatory requirements, (iii) operations pollution prevention and control, (iv) environmental monitoring, (v) communication and community relations, and (vi) emergency preparedness and response. Each facility has a site manager with the responsibility for assuring adequate environmental, social, and occupational health and safety (ESHS) performance. These ESHS site managers, typically rely on external consulting firms to perform emission, air quality, noise, industrial and waste water monitoring, implement and supervise social programs, and twice a year compile ESHS performance information and write the “Informes de Cumplimiento Ambiental” (ICA) to be presented every semester to the local environmental authority. In addition, EGE Haina, has a corporate ESHS Manager that provides quality assurance and consistency to EGE Haina’s overall environmental performance, including wind generation and transmission line assets.
Going forward, IEH will further develop and implement a corporate-wide environmental and social management system applicable to IEH Controlled Group’s business activities, containing, at a minimum, the following elements:
Policy
IEH will develop an overarching Policy statement of the ESHS objectives and principles guiding the organization’s ESHS performance. The policy will include specific objectives and aspirations for its ESHS performance, consistent and with direct reference to the IFC Performance Standards. In addition to the commitment of compliance with all applicable ESHS laws and regulations of the host countries in which IEH conducts its business activities, the policy should also include other major ESHS commitments such as compliance with good international pollution prevention and control practices as those described in the applicable IFC EHS Guidelines (e.g. Liquefied Natural Gas Facilities, Ports Harbors and Terminals, Thermal Power Generation, Petroleum Product Terminals, Electric Power Transmission and Distribution, Wind Energy).
Risks and Impacts Identification Process
The corporate ESMS will define IEH’s social and environmental risk and impact identification process consistent with good international industry practice (GIIP) to ensure that risks and impacts will be adequately identified when the physical elements, assets and facilities of future gas infrastructure developments are reasonably understood. That process will include all the necessary steps and methods that are required to screen, identify, analyze, measure, or assess, in quantitative terms to the extent possible, the potential risks and impacts (including environmental, social, health, and safety, and labor and security) associated with the activities to be developed. Depending on whether the future investment involves development of a Greenfield projects, expansion/conversion of existing facilities, or acquisition or decommissioning of an existing operating asset, the process will involve either: (i) full-scale Environmental and Social Impact Assessments (ESIAs); (ii) limited or focused environmental or and social assessments; or (iii) environmental and social audit.
Following principles of international best practice, the ESIAs will conform to the requirements of the host country’s laws and regulations, as well as those of IFC’s Performance Standards. Likewise, when considering acquisition of existing assets, the Company will conduct reviews or audits of prospective facilities benchmarked against IEH policies and standards to determine areas of concern and identify necessary mitigation measures to ensure compliance with relevant requirements. The scope of audits of potential acquisitions will also include consideration of IFC Performance Standards.
Management Programs
The findings of the project-specific ESIAs will detail a program of mitigation and performance improvement measures and actions necessary to effectively manage the E&S risks and impacts of each of its developments in line with IEH’s corporate Policy. Project-specific assessments, audits, and goals will be used to establish action plans and metrics for project construction and operation. EPC contracts for each project will incorporate the relevant project-specific mitigation measures and actions identified during the assessment process to ensure compliance with host country requirements, as well as IFC PS.
With regard to development of new projects by IEH, particularly natural gas processing and storage and transportation infrastructure and conversion of power generation assets (to burn natural gas), IEH’s project-specific mitigation measures will include management of the following impacts and risks addressed in PS3 through PS8:
• PS3 (Resource Efficiency and Pollution Prevention). As previously stated, all IEH facilities follow common operational procedures for resources efficiency, pollution prevention and control, environmental monitoring, and emergency preparedness and response. Operations are guided by an overarching environmental controls procedure that is divided into six general focus areas: air emission; hazardous and non-hazardous waste management; hazardous material management; monitoring/ reporting; spill prevention and control/emergency preparedness and response; and training. IEH companies follow an emission management and control procedure, which describes international industry practices, follows mitigation hierarchy principles, and proposes first preventive measures, then recycling and recirculation to reduce emissions, and lastly end-of-pipe pollution control solutions. Going forward, IEH will develop a tailored set of environmental, social, and occupational health and safety (ESHS) programs and procedures that will apply across all operations of the IEH’s Controlled Group. These procedures will build on those already existing and currently being applied, but will be adapted to apply across the new IEH. Appropriate and relevant recommendations of applicable World Bank Group EHS Guidelines (i.e. Liquefied Natural Gas Facilities, Ports Harbors and Terminals, Thermal Power Generation, Petroleum Product Terminals, Electric Power Transmission and Distribution, Wind Energy) will be applied. For all existing power generation facilities within IEH Controlled Group, this will include implementation of ambient air quality monitoring programs to confirm surrounding concentrations are within applicable ambient air quality standards. Should results show standards are being exceeded due to emissions from IEH facilities, the Company will implement the necessary emissions reductions within a reasonable time frame.
• PS4 (Community Health, Safety and Security). All IEH facilities have processes in place to address the hazards posed by storage and transportation of liquid fuel to neighboring communities. These will be updated upon conversion to gas fuel to reflect the risks of major events, such as a natural gas release, fire, or explosion associated with gas storage terminals and pipelines. IEH will also develop a corporate-wide framework that can be used to consistently update and tailor the Emergency Response Plans (ERP) for each facility and include the necessary emergency and response scenarios involving neighboring communities. This ERP will assure that quantitative risk assessments are updated for all IEH assets and determine potential risk to neighboring communities and that site specific community emergency preparedness and response plans are developed per the findings of these assessments.
• PS5 (Land Acquisition and Involuntary Resettlement) and PS7 (Indigenous Peoples). IEH will develop formal procedures to ensure compliance with requirements for the management of land acquisition, resettlement and rehabilitation of project-affected people, and conduct adequate engagement processes associated with the development of gas storage terminals, pipelines and new power generation assets. Where developments are likely to materially transform, degrade or impact lands and resources on which indigenous peoples (IP) are dependant, implement procedures to identify and mitigate all identified impacts on IPs and conduct adequate engagement processes.
• PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources). In the development of gas storage terminals and pipelines, IEH will avoid impacts on biodiversity and ecosystem services, and where avoidance is not possible implement measures to mitigate impacts and restore these.
• PS8 (Cultural Heritage). For any construction activities associated with the development of new facilities, IEH will develop and implement a chance find procedure including for archaeological, paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values; put in place procedures to protect and enhance sacred sites in consultation with community members.
Organization
IEH will designate an appropriately qualified individual supported by adequate financial and professional resources with overall EHSH corporate responsibilities. To ensure adequate support of the newly designated ESHS manager, IEH will clearly define his/her responsibilities and communicate these to the rest of the Company and site operating staff. The corporate ESHS department will also be provided with sufficient authority and resources to achieve effective and continuous ESHS performance at all IEH Controlled Group’s sites. This may include in-house staff, as well as external consultants.
Monitoring and Review
Responsible corporate, company, and facility staff will monitor E&S performance against ESIA-based action plans, as well as established monitoring protocols and metrics (e.g. air emissions, air quality). The results of routine monitoring and measurement activities carried out at the project level, as well as any environmental or safety incidents will be recorded.
In addition, IEH will implement a formal E&S audit program to further ensure environment and safety performance for all controlled projects under construction or in operation. The program will include detailed audit protocols for environmental and safety issues. Conducted by competent environmental and safety professionals from within the Company, audits will be undertaken for construction sites and operating installations. Non-conformances with established standards and metrics and the related corrective action recommendations will be recorded and tracked.
IEH’s environmental monitoring framework will build on the existing monitoring protocols and address: (i) stack emissions and ambient air quality, (ii) noise, (iii) wastewater and solid waste, and (iv) occupational health and safety performance indicators. It will identify the specific environmental monitoring measures to be implemented at each of the controlled sites - the parameters to be measured, sampling and analytical methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and the definition of thresholds that signal the need for corrective actions. Monitoring thresholds will be consistent with those referenced in the applicable IFC EHS Guidelines and DR ambient air quality standards.
Monthly, quarterly, and annual operations and environmental performance data will be consolidated into reports and made available to senior management, group leaders, and other interested stakeholders. Senior management will also be informed via email of significant EHS audit findings, and the audited activity, in turn, will provide progress reports on making corrective actions. The results of ESHS monitoring will be evaluated and documented at both the facility and corporate level. Periodic reporting of progress and monitoring results will be made to the IEH senior management. Reports will furnish the information and data needed to determine compliance with the ESMS. The format of these reports will include a summary of findings and recommendations.

Human Resources Policies and Management
IEH currently has only a four member team at the holding company level, but together IEH’s companies currently employ approximately 400 staff across its facilities and corporate offices. Neither the IEH Controlled Group nor EGE Haina have overarching Human Resources Policies, but as part of their respective Quality Management Systems, they do have many HHRR procedures related to hiring and promotion mechanisms, training, compensation, vacations, flexible work schedules, summer intern programs, loans, support for employees to further their education, and dependants education help, among others. Additionally the IEH Controlled Group have a Code of Ethics in development and are in the process of implementing a program called “Managing Diversity” to assure no discrimination based on cultural background, gender, age, handicap, etc. Even though there is a greater number of males when compared to females (75/25), there are many females performing management and leadership roles.
Even though IEH Controlled Group’s companies do not have a written HHRR Policy, they all are Dominican law-abiding companies. The Company does not discriminate in its employment practices, nor are there restrictions for employees to join unions and bargain collectively. IEH Controlled Group companies’ salaries and compensation packages are superior to basic minimum wages required by law, and therefore employees have no incentive or need to join or form labor unions.
As part of the development of the Corporate-level management system (see PS1), IEH will develop a Human Resources Policy aligned with PS2, clearly articulating (i) non-discrimination hiring and promotion policies, (ii) assure respect of the employee’s right to join unions and engage in collective bargain, and (iii) prohibition of any type of harmful or force child labor. This policy will be disclosed to all of IEH Controlled Group’s employees and include a clear internal Grievance Mechanism.
Occupational Health and Safety (OHS)
Currently, OHS is managed separately at each facility. None-the-less, these facilities share the same basic OHS management procedures and indicators which have been designed to be consistent with those required under OHSAS 18001. These include (i) policy and principles focused in safety first, no fatalities, and a culture of accident prevention, (ii) occupational risk identification process and management associated with each task/activity, (iii) training/ qualification and personal protection equipment (PPE) requirements and restrictions/limitations related to each task/activity, (iv) first aid guidelines, (v) crisis and emergency response procedures, and (vi) standard performance indicators.
IEH companies reported consolidated 1,131,303.7 and 977,138.5 man-hours worked for the years 2010 and 2011, respectively. Lost time injuries frequency rates per million workers (LTIFR) were 3.54 and 6.14 for the same two years. These values are well below Dominican Republic country 2009 averages of 74.72. Severity rates for the same two year were 34.5 and 12.33 lost days/ injury, respectively.
IEH will build on the existing occupational health and safety policies and procedures of its underlying companies, and include as part of the Corporate ESMS, occupational health and safety policies, procedures and indicators to be applied to all IEH Controlled Group’s assets and facilities. OHS performance will be reported for individual facilities, as well as for the holding as a whole.

At the Corporate Level, both the IEH Controlled Group and EGE Haina each have a community relations and corporate social responsibility departments with the main objectives of providing resources and know-how to support neighboring communities in the areas of education and sports. Regulatory reports include a section that provides an update of each individual facility’s community relations work for the reporting period. These activities include, community education events, economical support to update/repair local schools, school guided visits to the plants, sponsorship of sport teams, in-kind and monetary donations, to name a few.
Individual facilities follow a community engagement and external communication procedure. Communication with neighboring communities is managed directly by the site ESHS manager, who receives and responds to any grievance, complaint and/or request. Evidence of some complaints related to noise or questions about stack emission were reviewed, and the satisfactory resolutions were presented such as noise mitigation measure or external talks and seminar to explain process.
In general, most IEH’s facilities report good and positive relations with neighboring communities.
As part of its ESMS, IEH will develop a Community Engagement Framework (CEF) based on corporate policies and guidelines, local requirements, relevant experiences with existing assets, and IFC’s PSs. For Greenfield developments with potential impacts on local communities, IEH will develop and implement an appropriate Public Disclosure and Consultation Plan (PDCP) based on the CEF, to ensure that project-affected communities are provided with information and consulted on the risks, impacts and opportunities presented by each project and remain engaged on ongoing basis and provide a grievance redress mechanisms. For projects with potential significant E&S impact on local communities the PDCP will be designed to ensure their free, prior and informed consultation with regard to the risks and benefits of each project, and way in which those risks and benefits will be managed. The CEF will also include guidelines to ensure that the E&S audit process for the acquisition of existing assets also includes an assessment of community engagement activities and identification of gaps and corrective actions, if any.
IEH will also create a publicly available channel to receive communications and concerns from the employees, suppliers, customers, or the general public in relation to its operations.

Flavio da S. Pinheiro, Director
InterEnergy Holdings
c/o Consórcio Energético Punta Cana Macao S.A. (CEPM)
Ave. Winston Churchill. Edificio Acropolis. Piso 19.
Santo Domingo.
Distrito nacional.
Republica Dominicana

Broad Community Support is not applicable for this project