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
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 7 – Indigenous Peoples
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category A project according to IFC’s Policy on Environmental and Social Sustainability. The Company proposes to invest in a large-scale pulp and board mill, with associated forestry plantations to provide fiber supply for the mill. These operations entail potential significant adverse social or environmental impacts that may be diverse, irreversible or unprecedented.

Risks and issues related to the Project are quite different for the plantation operations and the P&B mill project components. For the plantation operations, the key risks relate to the process of acquisition of land use rights for plantations in a rapidly changing regulatory environment and ensuring that this process is, and is seen to be fair, through an ongoing process of engagement with project-affected communities. Environmental risks associated with plantation operations include potential adverse impacts to biodiversity and ecosystem services associated with plantation developments, potential for soil erosion and surface water pollution resulting from road building and site preparation and the attendant use of fertilizers and herbicides in plantation establishment, and effects of plantations on water resources. Other issues relate to management of and provision of fair and safe working conditions to the largely subcontract forestry workforce, avoidance of adverse impacts on ethnic minorities who may have contact with the project and avoidance of damage to items of cultural heritage which may be present in the plantations.

For the P&B Mill operations, issues include the completeness of Stora Enso’s social and environmental assessment commensurate with risks and impacts likely during both construction and operations phases; Stora Enso’s management of the social, environmental, and health and safety performance of its contractors and employees during construction and operation of the Project; consultation and engagement with project-affected communities in accordance with local requirements and IFC Performance Standards; ensuring that project-related land acquisition and involuntary resettlement of affected persons fulfill IFC performance standard requirements, including the development and implementation, in full consultation with project stakeholders, of a program to help project affected persons restore their livelihoods to pre-project levels in a sustainable manner; minimization of resource consumption of industrial activities, waste water treatment and disposal in a manner avoiding adverse impact on the marine environment; control of emissions to air of combustion products and reduced sulfur compounds in a manner that avoids nuisance due to odor; and risk of adverse impact to health.

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.

Policy

Stora Enso attaches considerable importance to environmental and social sustainability (“Responsibility”). This commitment to sustainable development is summarized in the Stora Enso Sustainability Policy and supporting principles and position papers. These policies, principle and implementation actions are fully aligned with IFC’s E&S requirements defined in the Performance Standards, and are published on Stora Enso’s web site at:

http://www.storaenso.com/responsibility/our-approach/policies/Pages/Policies%20and%20principles.aspx

Identification of Risks and Impact

Plantation Operations
SEGX commenced development of its plantation assets in 2002. At that time, development was based upon acquisition of existing eucalyptus, pine or acacia plantation, or land that had been used for marginally productive agricultural crops such as sugar cane or fruit trees, though defined as forest land. These early developments largely entailed change of ownership or management control of existing plantation assets, and the environmental or social impact of these changes was considered to be limited.
Due to the extensive length of this PS 1 section, this content has copied and can be found under the attachment section

Employment Overview.

SEGX currently has a workforce of 824 employees in its forestry operations including 249 blue collar and 575 white collar employees. 500 employees are allocated to the 4 regions (Beihai, Yulin, Nanning and Qinlian) and the balance of 324 employees is counted under head quarter functions (including the nursery). The 4 regions are mainly responsible for contractor management including planning of operations. All employees are full-time direct hires and SEGX does not use any labor intermediaries nor does it expect to do so in future. The peak capacity of workforce of more than 1000 employees is expected to be reached during the ramp-up phase in 2014 and 2015 after which the workforce is expected to gradually decrease below the current level.



SEGX currently uses about 116 contractors in the plantations with a workforce of about 1,500 workers for land preparation, planting, cultivation, harvesting work and forest protection. Most contractors employ between 10-50 workers although around a quarter of the contractors employ more than 50 workers. About 80% of all workers are from the four local regions, and the rest are from neighboring provinces i.e. Yunnan and Guizhou, with a quarter of these being of ethnic minority origin e.g. Miao. The total number of contractors is expected to be about 90 with a total work force of about 4400 workers for manual harvesting, manual planting and mechanized planting when forestry operations reach full scale.



At full capacity, the P&B Mill will have a workforce of about 820 full time direct employees of which 10% will be Beihai local staff; 60% will be from within Guangxi, with the remainder coming from other parts of China or from out of country. Migrant workers and ethnic minorities will make up about 10% of the workforce. No use of seasonal or temporary workers is expected.



During the mill construction phase, a headcount of up to 4,000 contractor workers is expected. About 80% of this group will come from outside of Guangxi. It is expected that migrant workers and ethnic minorities will make up 10% or more of the contractor workforce.



Human Resources Policy

Stora Enso Oyj has a global human resource (HR) policy and relevant procedures defining such key principles as non-discrimination, equal opportunity, and protection of the workforce. In addition the Stora Enso Code of Conduct states, amongst other things, that Stora Enso obeys local laws and regulations and respects and promotes international human and labor rights. Key aspects of the global HR policy include recruitment, setting salary and benefit levels, performance evaluation, working hours, occupational health and safety, security, grievance procedures and retrenchment.



Stora Enso China has prepared an Employee Handbook which defines human-resources related right and responsibilities of the employer and employees, and is based upon Stora Enso Oyj’s global policy framework described above, and incorporates China-specifi
c factors. Employee Handbooks will similarly be developed for the three joint venture companies which will implement the Project.



Working Conditions and Terms of Employment:

Terms of employment are specified in employment contracts signed between SEGX and employees, which follow national requirements on such aspects as working hours and overtime. IFC’s review of the plantation operations found SEGX working conditions such as wages paid, and benefits including annual leave to be reasonable.



Stora Enso makes no distinction in employment between local and migrant workers. Some plantations work teams are comprised of ethnic minority groups, which can provide communication challenges with Mandarin-speaking supervisory staff. As indicated in the ESAP, Stora Enso will monitor its contractors’ compliance with contractual provisions, including the provisions of Chinese labor law relating to non-discrimination and ethnic minority workers, especially in mitigation of potential risks connected to language barriers.



Worker Accommodation

There have been past instances of sub-optimal living conditions at plantation contractor work camps. SEGX has taken actions to rectify this by developing and executing a set of sustainability criteria applicable to all contractors (refer to PS1). The Company regularly spot checks contractor sites for sustainability compliance. SEGX will continue to monitor working conditions at all contractor sites as part of its contractor sustainability performance monitoring program (refer to PS1). Similar standards will be applied to construction of temporary accommodation to house the P&B Mill construction contractors.



Workers’ Organizations

SEGX adopts principles of non-discrimination and equal opportunity in its HR practices, and this extends to trades unions. All workers can choose at free will to join or not join the labor union.



Non-discrimination and Equal Opportunity

One of the key principles of Stora Enso’s Human Resources policy is that of non-discrimination and equal opportunity. IFC’s supervision of SEGX’s plantation operations has seen no evidence that this principle is not observed. Employment relationships for the P&B Mill will also observe this principle.



Retrenchment

No large scale retrenchment is expected as plantation operations will be expanding. While SEGX only leases parts of each SFF and therefore has incomplete management control over SFF labor practices, the JV setup process may impact SFF workers through potential workforce reduction. The Company will seek to work with SFFs to monitor and mitigate such potential impacts, to the extent that SFFs are willing to share retrenchment related information.



The P&B Mill is a greenfield project, about to start construction. Although it is anticipated that mill staffing will be undertaken in a manner that avoids retrenchment, the IJV will ensure its HR policies include procedures on retrenchment and mitigation against any adverse impa
cts on retrenched workers should unexpected major workforce reductions occur in the future.



Grievance Mechanisms

Among methods used to communicate with employees, SEGX uses regular staff meetings and the same 24/7 hotline and electronic communication system available as the community grievance channel as described earlier.



Protecting the Workforce:

IFC’s supervision of the plantation operations has revealed no evidence of the use of forced labor or child labor. Social insurance coverage (medical, accident, unemployment, maternity) as mandated by law is provided for all employees. Accident insurance is required for all contractor workers according to SEGX sustainability requirements, as are signed contracts.



Occupational Health & Safety (OHS)



OHS statistics for plantation operations for the period 2009-2013 and operational training logs confirm ongoing monitoring and corrective training by SEGX. There has been employee involvement in safety committees in defining occupational hazards and participation in establishing incident prevention systems, and records for compliance are retained and entered into the management information system (MIS) by the sustainability team. SEGX management regularly reviews OHS performance statistics, and follow up actions are undertaken by the EHS department to address any issues identified during internal monitoring.



The Lost Time Accident (LTA) frequency in both 2011 and 2012, of 3.5LTAs per million work hours at SEGX falls below the 2010 U.S. OHSA benchmark level (Forestry and logging) of 9 LTA/million hours and no fatalities had occurred from January 2009 to October 2013. SEGX attained verified conformity for its operations (including contractors) to the OHSAS 18001 standard in May 2011 and planned annual external audit in September 2013. SEGX’s procedures include OHS aspects of its contractors.



The IJV will develop construction-phase and operational-phase OHS policies and consistent with SEO global OHS policies, national safety requirements in China, and IFC PS2 requirements and work to certify the mill operations according to OHSAS 18001 (ref PS1).



Stora Enso will ensure that all employees undergo regular health check-ups and are covered by adequate occupational accident and medical insurance. The Company will monitor the health status of workers to identify work-related health trends if any.



Contractor Management

Stora Enso will ensure that primary plantation and mill contractors and their subcontractors adopt and implement provisions related to working conditions and worker relationships, worker accommodation, occupational health and safety and provisions for ethnic minority worker protection that are aligned with the requirements of national and provincial law, applicable Stora Enso’s policies and procedures and Performance Standard 2. Methodologies will be developed by Stora Enso to monitor compliance by contractors and subcontractors.

Process Overview

Pulp mill design will be very similar to designs adopted in the kraft pulp mills recently constructed or under development by leading companies in the sector, including the Fray Bentos mill in Uruguay, the Veracel Celulose mill (a Stora Enso joint venture) in Brazil (both operating mills) and the Montes del Plata Stora Enso joint venture currently under construction in Uruguay. Both the Fray Bentos mill and Veracel publish environmental data which demonstrates performance that would meet IFC requirements, and performance of at least these standards is expected from this mill.



The main technical design features that have been adopted for this P & B Mill follow Best Available Techniques (BAT) for the Pulp and Paper Industry as defined by the European Union’s Integrated Pollution Prevention and Control (IPPC) Reference Document on BAT in the Pulp and Paper Industry (“the IPPC BREF”). These and other features that reduce environmental impacts of processing operations will be described in the sections that follow.



As noted earlier in this review summary, mill construction will be in two phases. Phase I will include the CTMP and Board mills, with essential utilities, while Phase II will add the Kraft mill recovery boiler and additional utility systems. The resource efficiency and pollution mitigation measures described in the sections that follow refer to the completion of Phase II. During Phase I operation, pollutant mass flows will be reduced, and Stora Enso fully expects to meet all local regulatory requirement and applicable World Bank Group EHS Guideline emissions values.



Resource Efficiency

Process and utility systems design and controls are expected to minimize consumption of wood, energy and water.



Specific consumption of heat, power and water for the pulping processes and board machine are below or in the lower range of BAT as defined in the IPPC BREF.



Heat and power for the project will be supplied by a co-generation based utility system. In Phase I, high pressure superheated steam will be generated by a Power Boiler which will burn biomass (rejected wood, bark, primary and tertiary waste water treatment plant sludge and fiber rejects) arising from production processes and coal. During Phase I, the project will have generation capacity of approximately 50 MW of electricity and will typically import around 30 MW from the grid. In Phase II, a Recovery Boiler, fueled by black liquor, but also burning non-condensable gases will be added and power generation capacity expanded. Under design conditions at the conclusion of Phase II, coal would provide around 30% of the energy supplied to the utility system with the remainder derived from the renewable sources described. Coal is expected to provide around 20% of energy supplied during normal operating conditions.



The power boiler will adopt circulating fluidized bed technology. Overall efficiency of the cogeneration system (expressed as heat and electr
ical energy used in processes divided by the heat content of all fuels used in all boilers) is expected to be 82% in normal operations.



Greenhouse Gases

The mill will use heavy fuel oil in the lime kiln and as support fuels in the power and recovery boilers, while light fuel oil will be used in the auxiliary boiler, as start-up fuel for the power boiler and as a back-up support fuel for destruction of non-condensable gases. Coal will be the main fuel used in the power boiler.



Stora Enso did consider alternatives to coal for the power boiler. Gaseous fuels (LNG or LPG) are not available in southern Guangxi in sufficient volume for the project. Use of heavy fuel oil was ruled out because of regulatory limitations of use of oil for power generation and cost. Biomass options are also limited. Eucalyptus bark will be removed from logs at the harvesting sites and used for soil protection and improvement in the plantations, in accordance with best practice. Land acquisition for wood production has been challenging, and Stora Enso’s review did not identify competitive sources of biomass fuel for the mill.



Stora Enso has estimated greenhouse gas emissions arising from use of all fuels in the P&B mill at the completion of Phase II at around 450,000 tonnes per annum carbon dioxide equivalent. (tpa CO2 eq), of which coal contributes approximately 350,000 tpa CO2 eq. The heat content of steam produced by the recovery boiler and from process heat recovery exceeds process needs by around 20%: combustion of coal in the power boiler is needed to generate the additional steam needed in the mill’s power generation turbines. If instead of generating its own electricity the mill were to import electricity from the Chinese grid, then IFC estimates that associated Scope 2 emissions would be approximately double the 350,000 tpa CO2 eq incremental GHG footprint associated with the mill’s electricity generation.



IFC estimates that improved silviculture of the plantation assets will result in net sequestration in the order of 200,000 tpa CO2 eq. These estimates include only activities and sequestration and emission associated with plantation rehabilitation and include wood removals as an “off-project” loss.



The Company will work with IFC in its annual accounting and reporting of the Project’s GHG footprint.



Water Consumption

Water supply for the entire Tieshangang industrial area, including the P&B Mill will be taken from the Hepu reservoir system, and after 2015 will be supplemented by abstraction from the Nanliu river. This issue is described in the EIA and in the 2007 study “Water Resources Assessment Report for Tieshangang Industry Park.” This report concluded that the water demand of the entire industry area would be 230,000 m3/day by 2010, increasing to 447,000 m3/day by 2020. These estimates include 220,000 m3/day for the pulp and board mill, whereas Stora Enso expects mill water consumption to average 81,500 m3/day with a daily ma
ximum demand of 105,000 m3 for Phases I and II of the P&B mill.



Most of the area available for forestry in Guangxi is located on side slopes and hilltops which have been in forestry for at least 30-40 years. However, some recent survey data indicate a growing perception that plantations may have impacts on surface water availability. Preliminary evidence indicates that mature eucalypts do intercept and transpire more precipitation than pines or natural forests. This effect may reduce peak surface water flow rates during the rainy season and extend shallow aquifer recharge during the dry seasons in Guangxi. These effects could be more pronounced during droughts or abnormally high rainfall years. The exact impacts on surface water availability of the forest management cycle are inconclusive. As described in the ESAP, the forestry JVs will establish a long-term strategy for assessing potential impacts of plantations to surface water, continue the own surface water monitoring trials, study results from comparable trials elsewhere and will update work instructions for plantation management as necessary.





Pollution Prevention



Plantation Operations

Construction of roads, harvesting of forests, and replanting activities are a significant source of erosion which can result in sediment discharge to surface water. Limitations of road grades and use of contour planting are specified in the BMS and IOSP requirements. The use of low quantities of fertilizers, which can lead to localized pollution, in plantation establishment, is also prescribed and supervised at the site level. While overall attention to water quality concerns was observed, several cases of contractor non-compliance were noted. As described in the ESAP, the forestry JVs will ensure ongoing soil loss and soil fertility management monitoring and will adapt operating principles accordingly. Recent public surveys conducted by SEGX have identified concerns over localized water pollution.



Mill – Effluents

The P&B Mill has many design features that correspond to BAT as defined by the IPPC BREF and that reduce water consumption and effluent contamination at source. These include:



Dry debarking,

Modified cooking concept and two stage oxygen delignification

Counter current brown stock pulp washing

Closed cycle pressure screening of brown stock pulp

ECF bleaching, using a type R8 chlorine dioxide generation which has very low residual chlorine concentration in the bleach solution

Partial countercurrent washing in bleach plant for reduced water consumption

Reuse of drying machine white water in bleach plant washing

Stripping and reuse of evaporator condensates

Use of clean condensates for washing of brownstock pulp and also lime mud washing

Sufficient storage volume in brown stock washing and black liquor handling systems to manage variations in operational conditions and avoid overflow to drain.

Spill recovery system in the brown stock line, evaporation area and c
austizising area.

Collection and reuse of cooling water and clean sealing waters

Optimized white water system recirculation of the board machine, effluent <15m3/t of board.

Separation of drainage areas and sewer system in the mill according to potential for contamination of storm waters, from process areas, potentially contaminated to storm water basin and clean waters.

Emergency basin in the effluent treatment plant to manage accidental spills.



In addition to these process design features, the mill will feature primary, secondary and also tertiary treatment of liquid effluents. Tertiary treatment, which is considered beyond BAT is required in order to meet the local regulatory requirement that the concentration of COD in liquid effluents is less than 90 milligrams per litre (mg/l) for the integrated pulp and board mill.



Wash filtrates from the BCTMP process will be treated by evaporation followed by burning in a CTMP recovery boiler and including recausticizing of the sodium carbonate to sodium hydroxide for reuse in the CTMP process. Evaporation condensates will be used for pulp washing. This technology is installed at other mills producing CTMP in China and should ensure that the limit of 90 mg/l of COD is reached for the treated effluents.



The comparison in Table 2 shows that the quality of treated effluent from the kraft pulp production will be better than standards considered BAT and will more than satisfy World Bank Group (WBG) EHS Guideline values for the parameters shown.

References refer to production of bleached kraft pulp.



Dioxin emissions in effluent are regulated by the Chinese standard GB3544-2008 at <30 pg TEQ/l before effluent treatment. The mill EIA states that dioxin content of treated effluents will be <6.2 pg TEQ/l, but actual levels are expected to be comparable with other modern mills, such as the Fray Bentos and Veracel mills that both report <1 pgTEQ/l.



The effect of the mill’s routine effluent discharge, as well as a much more extreme case assuming complete failure of effluent treatment systems, on receiving water quality was analysed in the mill’s 2008 EIA. The most comprehensive modeling was of COD, which baseline studies showed was around 1.5 mg/l. The EIA concluded that while the most extreme case would elevate COD by 2 mg/l over a wide area, impacts of an accidental release would not be experienced in sensitive marine areas (dugong reserve, mangrove reserve and mariculture area) in the vicinity of the discharge point. Routine releases would elevate COD by more than 2 mg/l for a limited area of less than 15,000 m2 or a radius of less than 70m from the discharge point. The EIA conclud
ed that the impact of the mill’s routine and accidental COD release would be to slightly elevate COD in the mangrove reserve and dugong reserve but that the Class 1 seawater standard would be maintained in both areas, even in the event of the accidental discharge modeled.



P&B Mill – Emissions to Air



Air emissions of concern relate to emissions of combustion products from the power boiler, recovery boiler and lime kiln, emissions of dust from the lime kiln, VOCs arising from the BCTMP refiner and emissions of non condensable gases (NCGs) arising from the pulping process. NCGs contain several reduced sulfur compounds, which are the source of the unpleasant odors associated with kraft pulp mills. Control of each is now discussed.



Power Boiler Design

The power boiler is designed for steam conditions of 94 bar(g) and 475°C. Fuel input is approximately 200 MWth at design conditions, of which around 90% derived from coal and the remainder from various biomass sources The design adopted is a circulating fluidized bed, with addition of lime for control of SOx emissions. The boiler will also be equipped with selective non catalytic reduction (SNCR) for NOx control, and an electrostatic precipitator (ESP) for particulate (PM) emissions control. Point source emissions, of SO2, NOx and PM are expected to average below 200, 200 and 30 mg/Nm3 respectively, in all cases meeting local regulatory and WBG EHS Guideline values.



Recovery Boiler

The recovery boiler is designed for steam conditions of 94 bar(g) and 495°C. In accordance with BAT, black liquor is concentrated to 80% solids before entry to the recovery boiler, and the boiler itself has four levels of air feed for optimum combustion control and will be equipped with an ESP. Point source emissions, of SO2, NOx and PM are expected to average below 30, 200 and 30 mg/Nm3 respectively, in all cases meeting local regulatory and WBG EHS Guideline values.



Lime Kiln

The lime kiln, which will burn heavy fuel oil of up to 3% sulfur, will be equipped with low NOx burners and an ESP. Point source emissions, of SO2, NOx and PM are expected to be below 300, 400 and 50 mg/Nm3 respectively, in all cases meeting local regulatory and WBG EHS Guideline values.



BCTMP Refiner

Steam arising from the BCTMP refiner is directed to the heat recovery unit, and condenser, and passes through a scrubber before venting to atmosphere.



Non Condensable Gases Control

Odorous non-condensable gases include hydrogen sulfide (H2S), dimethyl mercaptan, and dimethyl sulfide, are collectively referred to as Total Reduced Sulfur (TRS) compounds and can be considered in the following categories:



Concentrated non-condensable gases (CNCGs), are low volume high concentration gases, also referred to as LVHC gases;

Dilute non-condensable gases,(DNCGs), typically high volume low concentration (HVLC) gases;

Dissolving tank vent gases (DTVGs), emitted from the recovery boiler dissolving tank vent, and with intermediat
e concentration;

TRS within recovery boiler and lime kiln flue gases,

Diffuse source.



CNCGs will be collected from relevant sources, i.e.: the heavy black liquor storage tank, methanol production system, evaporation vacuum system, foul condensate tank. These CNCGs are then transported to the main destruction system, which is a dedicated CNCG burner within the recovery boiler. If this CNCG destruction system is unavailable, the CNCGs will instead be routed without venting to the first backup system, a nozzle in the power boiler, and if both are unavailable CNCGs would be routed without venting to a second backup system, a flare on the recovery boiler roof. In the unlikely event that none of these three CNCG destruction systems is available, CNCGs would be vented to atmosphere, from the recovery boiler building roof, at a height of greater than 65m above ground. This design, with a main and two backup CNCG destruction systems meets BAT.



DNCGs will be collected from the chip digester, several vents in the fiber line, the recovery boiler vent tank, evaporation plant vents and causticizing plant vents. After pre-treatment such as washing and/or cooling, gases are reheated and sent to the DNCG destruction system. The primary DNCG destruction system is the recovery boiler, where DNCGs are mixed with dissolving tank vent gases and air and supplied as secondary combustion air to the recovery boiler. There is a single back up destruction system, the power boiler, while if both systems are unavailable, DNCGs would be vented to the stack on the recovery boiler building roof.



Flue gases from the recovery boiler and lime kiln will be discharged approximately 120 m above ground. Only limited unburnt TRS in the recovery boiler stack is expected due to the boiler design which overtly requires NCG destruction and combustion control which will include continuous monitoring of TRS, among other compounds, in the flue gas. Lime kiln emissions will be limited by appropriate system design, high quality lime-mud washing, and continuous monitoring and adjustment of combustion conditions.



Diffuse TRS emissions sources are controlled in several ways. Process systems are sized to avoid spills due to upset conditions, while collection sumps are connected to the NCG collection system. Potential emissions from the effluent treatment plant will be controlled by control of the pH of neutralization basins ahead of the effluent treatment system.



P&B Mill - Ambient Air Quality



Combustion Products

The EIA reports analysis of dispersion of combustion products from the mill P&B project, and assesses the impact of the P&B Mill on the overall objective to maintain Chinese Class II air quality objectives, as defined by GB3095-1996. The EIA’s review is summarized in the sections that follow; however it should be noted that Stora Enso expects the project’s emissions to air to be less than the values used in the EIA. One reason for this is that in the time
since the EIA was completed the decision has been taken to add SNCR to the power boiler, in order to reduce expected NOx emission from 300 to 200 mg/Nm3, in response to the updated Chinese standard GB13233-2011.



Analysis was based upon a 200 x 200 m grid centered on the mill chimney, and also considered the impact of the project at seven sensitive points up to 10 km distant from the mill site. Maximum daily concentrations of SO2, NO2 and PM10 attributable to the mill were calculated to be 19.6%, 13.8% and 3.2% of the air quality objective respectively. At the seven points of concern, project impact plus pre-project baseline will cause the following proportion of the air quality standard to be observed: SO2 18% of the standard at Bingchi Village, of which the project contributes up to 3% of the standard: NO2, 16% of the standard at Yanduncun district of Tieshan Port, of which the project contributes 3% of the standard, and PM10, 57% of the standard at Xingang, of which the project contributes 1% of the standard, reflecting high PM10 in the baseline. It is concluded that the project will not have major impact on ambient concentration of combustion products, and that air quality objectives will be met.

Odor
The expected odor impact of the project was assessed by preparation of a model of H2S dispersion from the lime kiln and recovery boiler flues. The model assumed continuous emissions of 6 kg/hour of H2S which exceeds expected emissions, given the state of NCG controls described in the earlier section. Modeling showed a maximum H2S concentration of 6.5 µg/m3 at the Yandunchun area. This is within the Chinese air quality objective. However, modeling is believed to overstate the impacts. Modeling also shows H2S concentrations at five settlements, Beimu, Pokoutang, Xinwupo, Yaxi and Haishanba that exceed the Chinese air quality standard. These areas are scheduled for future conversion to industrial areas, for other users of the Tieshangang Industrial Zone.

Solid and Hazardous Waste Management
The project will seek to minimize waste production. Plant-based wastes, such as bark, wood residues and water treatment plant sludge will be burnt in the power boiler. Ash arising from the power boiler will be supplied to a cement company for use in blending cement. Other solid and hazardous wastes will be transported by a licensed contractor to a landfill built as part of the Tieshangang development.

Hazardous Materials Management
Stora Enso will develop appropriate controls for the safe management of hazardous material at the mill site before such materials are in use, and shall oversee the performance of construction contractors in this regard. A dual language (English and Chinese) safety manual, and safety standards for the project have already been developed.

In plantation operations, hazardous materials used are fuels and lubricants associated with the Company’s vehicle fleet operations and plantation equipment and agrochemicals used for site preparation and out-planting. The Company has established procedures for the operation and maintenance of its own equipment and provides written procedures for fuel storage and dispensing to contactors which are regularly reviewed in the field. Review of contractor compliance with the sustainability criteria indicates steady improvement in fueling practices, recovery of used oils, and safe storage at fuel depots.

The Company purchases and uses agrochemicals. Glyphosate (a herbicide) is used after harvest and before replanting to reduce understory growth and prevent fire. Herbicide is applied using backpack sprayers and is reapplied during the first two years until canopies close and reduce weed growth. Contractors are trained in proper application of herbicides and direct observation and review of contractor performance records indicate that appropriate personal protective equipment (PPE) is routinely available and used. Proper maintenance and calibration of spraying equipment remains an area for improvement to reduce exposure to overspray and unnecessary costs. Concentrated Glyphosate is mixed with water at field sites and empty containers are routinely collected and removed.

General soil surveys are conducted on a network of 160 permanent sample points to determine broad fertility and limiting factors. Mechanical pitting may be exacerbating soil fertility limitations on degraded sites and improved soil analysis will help reduce over fertilizing. A general prescription of manual liming (CaCO3) (for the planting of the first rotation) during pitting followed by application of a granulated composite (NPK) fertilizer during out planting is followed. Polymer gels are often included in the pits to extend available water.

A review of pesticides, herbicides and fertilizers stores and application equipment at each plantation and the central nursery indicated reasonable control of inventories management but the ability to control access in field operations is challenging. All fertilizers, pesticides and herbicides comply with IFC and FSC requirements and meet Chinese laws and internationally-recognized practices for proper storage, ventilation and availability of proper emergency information. MSDSs for each agrochemical used was available at the Beihai office but not at all regional offices or planting sites which should be corrected.

Plantation and mill operations are expected to create up to 30,000 direct and indirect jobs some of which will arise from supply chain and other ancillary operations (e.g. catering, wood transportation etc.), of which up to 4,500 will be contractor workers undertaking wood production and harvesting work at plantation sites. Of the indirect jobs, many will be taken up by local residents but a large number of non-locals are also expected to come into local areas looking for work. Mill construction is expected to need up to 4,000 contractor workers, at the time of peak activity in the construction work about one year from the commencement of the project implementation. The Project therefore may contribute to potential in-migration into the Tieshangang Industrial Zone. There will also be some influx into forestry areas although this is not expected to have substantial impacts given that forestry areas are widely spread out.



Potential project-induced adverse community health and safety impacts include: (i)road congestion and risks of traffic related incidents arising from transport of construction materials, timber and other raw materials and final product; (ii) increased incidence of communicable diseases, arising from in-migration; (iii) security: incident such as theft and confrontations which may arise between contractors and local communities; (iv) resource impacts: influx will place greater demands on local housing, schools, transportation and basic services; and (v) environmental hygiene: increased potential pollutants (e.g. sewage and sanitary wastes) may result from the influx.



As described in the ESAP, Stora Enso will develop plans to mitigate potential adverse impacts of project-induced influx, with separate consideration given to influx to the P&B Mill during both construction and operation, and control of potential influx to plantation operations.

Plantation operations

The plantation component of the project relates to the establishment and development of eucalyptus plantations in the central and southern parts of the Guangxi Zhuang Autonomous Region in Southern China. At present, SEGX has about 90,000ha under lease contract, of which 57,000ha is state forest land (i.e. land use rights originally held by State Forest Farms or SFF) and 33,000 ha social forest land (i.e. land use rights originally held by local village communities or individual farmers). The Project has an opportunity to extend state forest land to 90,000 ha and may also acquire additional social land. Plantations are managed in small mosaics of 5 to 50 hectares distributed across a very large rural landscape of predominantly heavily modified habitat.



In January 2009 the Company commissioned an external consultant to undertake an FSC gap analysis to identify areas where the Company needed to implement corrective actions in order to render its forest operations ready for FSC certification. In late 2011 SEGX attained FSC Chain of Custody and FSC Controlled Wood certification applicable to procurement of third party wood logs and chips. Chinese Forest Certification Council Forest Management and Chain of Custody certification were achieved in November 2012, and FSC certification of Sustainable Forest Management was achieved in December 2012.



Over the past year SEGX has undertaken important new initiatives to improve its practical planning and conformity with international forestry practices and FSC requirements. The Company has entered a 7 year contract with Flora and Fauna International to assess the distribution and frequency of bird populations in plantations and native forests in Guangxi which will be an important part of the company’s High Conservation Value Forest (HCVF) delineation and protection required for FSC certification. HCVF identification and mapping is undertaken by the Guangxi Forest Research Institute.



Additionally, SEGX has initiated long-term studies with two local universities to better assess and document the impacts of plantations on soil erosion and surface water balance. Results from these operational research studies will provide important information that will assist in forest management planning and mitigation of E&S impacts and progress will be assessed and reported annually within the AMR and FSC auditing process.

Guangxi has a large ethnic minority population comprising more than 10 ethnic groups, with Zhuang being the largest minority group. Of the four prefectures where SEGX plantations are located, Beihai and Yulin have predominantly Han Chinese populations. In parts of Qinlian, Nanning and Chongzuo where SFF plantations are located, there are communities of Zhuang and possibly other ethnic groups such as Yao. While many Zhuang persons speak their own distinct language different from Mandarin Chinese, over the years they have assimilated into Han Chinese culture to a large extent. Given this, and the fact that SEGX’s plantation activities do not pose a significant livelihood impact on local communities (refer to PS5), this Project is considered not to have adverse impacts on local Indigenous Peoples communities.



However, SEGX plantation plots are many and scattered, and it is possible that there are communities of Zhuang and other ethnic groups located nearby. It is therefore important for SEGX to ascertain this in its Nanning, Qinlian and Chongzuo operational areas. To this end, and as part of FSC certification requirements, in 2012 SEGX commissioned the Institute of Ethnic Economy Studies, Guangxi Academy of Social Sciences (GASS) to undertake a study aimed at gaining a better understanding of the whereabouts, livelihoods and traditional cultural practices of ethnic groups in those three locations. As described in the ESAP, based on the study results, the Company will, as needed, update its Stakeholder Engagement Plan specifically to engage local ethnic groups in a culturally appropriate manner. Where adverse impacts are identified, the engagement sub-plan will include an ongoing communication process which will ensure free, prior, and informed consultation with identified ethnic communities, so as to facilitate their informed participation in Project related issues affecting them directly.



As described under PS2, some workers employed by plantation contractors (and possibly P&B Mill contractors in future) are ethnic minority persons from Yunnan, Guizhou and other provinces. As described in the ESAP, provisions for ethnic minority worker protection, will be adopted by plantation and mill contractors and sub-contractors.

At SEGX plantations and the mill site, there is no known critical cultural heritage in existence, nor cultural properties with known archaeological value. There are a number of ancestral graves at the sites, and the Project has taken care in protecting them (e.g. by planting trees around them) or moving them in full consultation with descendants’ families. At the mill site, a total of 1,400 graves were relocated in a respectful manner which was satisfactory to descendants. Two larger graves which date back several centuries remained just within the border of the planned mill site. They have not been moved, and Stora Enso has agreed with the authorities that this land will not be part of the mill site.

SEGX’s community engagement has evolved as the Company’s operations have grown in Guangxi. Its earliest community engagement, which dates from 2002, was around acquisition of land. When acquiring usage rights for village collective land (now classified as social land), SEGX negotiated land use agreements with the collectives’ representatives, and contracts for land use transfer would be signed by a two thirds (66%) majority of collective members. Similar arrangements would take place around state forest farm land, with collective expressions of agreement of members of the forest farm to the transfer being required.

As SEGX’s operations developed, its community engagement efforts became more formalized. Field work for the 2005 UNDP ESIA of the forestry operations involved extensive household surveys and focus group discussions with 9 main stakeholder groups. Tele-centers, to facilitate communicate between SEGX and rural communities in areas close to SEGX’s operations were established after the ESIA was concluded, but these were not widely used, and were discontinued. UNDP was subsequently retained in 2009 to conduct follow-up ESIA work involving further consultation with local communities.

From 2005 to 2009, SEGX staff interacted with local communities mainly to find and lease available village collective social land; and afterwards to discuss operational issues (e.g. fire prevention) from time to time, usually with local forest patrols or with village committee members. In 2009 the company expanded its team of social engagement officers to more regularly interact with communities and other local stakeholders. It also set up a 24/7 telephone grievance hotline, and started distributing a quarterly community newsletter in local townships and villages to enhance local stakeholder communication.

In October 2010 the U.S. based NGO Rights and Resources Initiative (RRI) published a report developed together with the Rural Development Institute (RDI) (now known as Landesa) titled “A Case Study on Large-Scale Forestland Acquisition in China – The Stora Enso Plantation Project in Hepu County, Guangxi Province” which questioned land acquisition practices associated with the plantation operations. In response, SEGX engaged in discussions with RDI and took actions to address points raised in the report. It further increased resources into stakeholder engagement activities, and highlighted sustainability and stakeholder engagement as a key operational objective across the organization. RRI and Landesa undertook a follow-up review in early 2013; Stora Enso co-operated with this review.

In late 2011, SEGX reviewed all local engagement activities undertaken to date and accordingly developed a Stakeholder Engagement Plan (SEP) which identifies key stakeholders and describes a systematic approach by which engagement work was to be regularly carried out. Visits by IFC in September 2011 and in 2012 confirmed that SEP implementation was starting at the local district level with field staff visiting designated communities.

Another important part of SEGX’s overall stakeholder engagement efforts is the Company’s Community Development Program (CDP). Since entering Guangxi SEGX has implemented the CDP including a Community Development Fund which has invested in 264 projects supporting local communities’ initiatives in education, infrastructure, cultural facilities, sanitation and health. In October 2011, SEGX revised the CDP to better address evolving local conditions and to synergize with the SEP developed around the same time. The revised CDP proposed to undertake various local activities such as supply chain development, agro-forestry demonstration and forestry skill-transfer schemes. CDP activities were planned and implemented using a participatory approach after consultation with local communities. The social baseline study by the Guangxi University team in 2011 (refer to the PS5 discussion) served to provide crucial baseline information for subsequent progress monitoring and for selecting communities for CDP pilot schemes. Currently at an early phase of implementation, the CDP will be an important part of SEGX’s overall stakeholder engagement efforts going forward. Further revision and implementation of the CDP remains an ongoing process in order to build strong consensus among involved parties.

Other SEGX work processes to date which form part of its engagement efforts are:i) Ongoing social contract correction which involves consultation with communities and middlemen to reach agreed solutions on contract disputes. In-depth and regular interactions to this effect have been ongoing since mid 2009; ii) Conflict and dispute management mechanisms (CDMM); iii) A number of socio-economic studies conducted since 2009 (refer to PS5); iv) Engaging in regular communication with about 100 designated community liaison persons - from villages close to SEGX plantations in the 4 prefectures; and v) Preparatory work for the FSC and CFCC sustainable forestry certification awarded in late 2012 involved community consultations; the process leading up to OHSAS18001 certification similarly involved engagement with contractor and migrant worker stakeholder groups.

In view of the above, IFC concludes that in the past four years SEGX has increased resources and emphasis on proactive engagement, and as a result has built the foundation of a systematic approach to stakeholder engagement. Further work described in the ESAP will build on this.

For more details on the project, contact:

Ms. Terhi Koipijarvi
SVP, Global Responsibility, Renewable Packaging
Stora Enso Oyj
FI-00101 Helsinki
Finland
mailto:terhi.koipijarvi@storaenso.com
Phone: + 358 50 598 9958
Cell Phone: + 358 50 598 9958

or:

Mr. Phillip Berry
Sustainability Director
Stora Enso Guangxi Integrate
No 23, Jilin Road
General Service Building, 4th Floor
Beitou (Beihai ) Science Park
Beihai Industrial Zone
Beihai City, Guangxi
China 536000

Stora Enso will place a local language advertisement in a major newspaper in Hepu county, in Beihai City, and in Nanning City to inform the public that results from IFC’s environmental and social review are available for access. It will post the local language version of the ESRS and ESAP at its Hepu office for staff to see; at the mill resettlement site, the Xinggang township public bulletin board, and in an upcoming edition of its community stakeholder communication newsletter.

Please note that IFC is in the process of assessing broad community support for the project under consideration. The information on broad community support will be disclosed as soon as it becomes available.

Title	Anticipated completion Date	Status	Comments	Completion Date
1. Demonstrate that each contractor in relation to the forestry operations is in material compliance with the Stora Enso Group sustainability requirements, as defined in the work instructions, standard operating procedures and Integrated Operational Site Planning Documents (IOSP), through the following actions: (i) reviewing the inclusion of sustainability criteria in road construction, harvesting and replanting work instructions and the IOSP and other operational documents	02/28/2014 12:00:00 AM	Completed	Completed	02/28/2014 12:00:00 AM
1. Demonstrate that each contractor in relation to the forestry operations is in material compliance with the Stora Enso Group sustainability requirements, as defined in the work instructions, standard operating procedures and Integrated Operational Site Planning Documents (IOSP), through the following actions: (ii) including ongoing monitoring results in the contractor performance and selection system;	09/30/2015	In Progress	In Progress
1. Demonstrate that each contractor in relation to the forestry operations is in material compliance with the Stora Enso Group sustainability requirements, as defined in the work instructions, standard operating procedures and Integrated Operational Site Planning Documents (IOSP), through the following actions: (iii) regular contractor compliance trends monitoring reviewed semi-annually	09/30/2015	In Progress	In Progress
1. Demonstrate that each contractor in relation to the forestry operations is in material compliance with the Stora Enso Group sustainability requirements, as defined in the work instructions, standard operating procedures and Integrated Operational Site Planning Documents (IOSP), through the following actions: (iv) addressing contractor deficiencies through contractor development and training plan	09/30/2015	In Progress	In Progress
1. Demonstrate that each contractor in relation to the forestry operations is in material compliance with the Stora Enso Group sustainability requirements, as defined in the work instructions, standard operating procedures and Integrated Operational Site Planning Documents (IOSP), through the following actions: (v) reviewing and revising performance-based clauses in the contractor agreements as needed.	09/30/2015	In Progress	In Progress
Maintain ISO9001 / ISO14001 / OHSAS18001 and FSC Sustainable Forest Management certifications for the forestry operation, and traceability systems verifying legal origin of wood	09/30/2015	In Progress	In Progress
Develop and implement a program of environmental and social (E&S) impact monitoring and regular public reporting of key sustainability parameters related to both the forestry and the mill operations. Undertake regular public reporting of the agreed key parameters to local stakeholders, using project sustainability newsletters and other locally appropriate means	09/30/2015	In Progress	In Progress
Undertake a review of the mill project’s community grievance mechanisms, and reinforce as needed based on review results. Publicly disclose the formal grievance mechanisms to project affected communities	01/31/2014 12:00:00 AM	Completed	Completed	12/30/2013 12:00:00 AM
Annual reporting to local affected stakeholders of the status of the implementation of the items listed in this ESAP which address risks or impacts or are issues of concern to affected stakeholders. (i) Identify an appropriate means for communicating the reporting and align this with what is otherwise defined for the respective item in this ESAP	02/28/2014 12:00:00 AM	In Progress	Under discussion with IFC client
Annual reporting to local affected stakeholders of the status of the implementation of the items listed in this ESAP which address risks or impacts or are issues of concern to affected stakeholders. (ii) Annual reporting on relevant ESAP items implemented	09/30/2015	In Progress	In Progress
1. Review implementation of forestry Stakeholder Engagement Plan (SEP), Community Development Plan (CDP), and conflict & dispute management mechanisms (CDMM). Incorporate stakeholder feedback into E&S monitoring/management and IOSP (forestry and mill). (i) Revised, gender differentiated, SEP and CDP (with elements of integration as appropriate) - submitted to IFC for review	03/31/2014 12:00:00 AM	Completed	Completed	03/31/2014 12:00:00 AM
1. Review implementation of forestry Stakeholder Engagement Plan (SEP), Community Development Plan (CDP), and conflict & dispute management mechanisms (CDMM). Incorporate stakeholder feedback into E&S monitoring/management and IOSP (forestry and mill). (ii) System level assessment of SEP, CDP, and CDMM implementation (in relation to Social Land and State Forest Farm Land) by a Stora Enso Oyj social development expert; thereafter annual internal review by the Project Companies; and further assessment by an external expert as needed based on Stora Enso findings	09/30/2014 12:00:00 AM	In Progress	Under discussion with IFC client
1. Review implementation of forestry Stakeholder Engagement Plan (SEP), Community Development Plan (CDP), and conflict & dispute management mechanisms (CDMM). Incorporate stakeholder feedback into E&S monitoring/management and IOSP (forestry and mill). (iii) Reinforce consultation with Affected Local Stakeholders (forestry and mill operations), and include mechanisms for incorporating their feedback into the ongoing E&S monitoring/management program (as referred to in Action 3) and as input for the continuous improvement of the IOSP and other operational documents. This process of seeking local feedback will ensure direct interaction with different groups of affected persons, especially households and individuals more vulnerable to E&S impacts	12/31/2014 12:00:00 AM	In Progress	Under discussion with IFC client
The Project Companies shall contractually require plantation and mill contractors and their subcontractors to employ workers on terms compliant with the law, applicable Stora Enso policies and procedures and applicable requirements of PS2. These provisions (including those related to the protection of ethnic minority workers) shall be incorporated into any future or renewed contracts and such provisions will be adopted by Project contractors. (i) Develop appropriate procedures for monitoring compliance and incorporate such procedures into the relevant management plans.	02/28/2014 12:00:00 AM	Completed	Completed	02/28/2014 12:00:00 AM
1. The Project Companies shall contractually require plantation and mill contractors and their subcontractors to employ workers on terms compliant with the law, applicable Stora Enso policies and procedures and applicable requirements of PS2. These provisions (including those related to the protection of ethnic minority workers) shall be incorporated into any future or renewed contracts and such provisions will be adopted by Project contractors. (ii) Report monitoring results of contractor compliance in each AMR for (a) the forestry operations and wood transport, (b) the mill construction; (c) the mill operations; and (d) contractor accommodation.	09/30/2015	In Progress	In Progress
OHSAS18001 certification for the mill operations. (i) Attain OHSAS18001 certification for the mill operations	09/30/2016	In Progress	In Progress
1. OHSAS18001 certification for the mill operations. (ii) Monitor and report on OHS statistics based on the standardized common Stora Enso corporate procedures and definitions.	09/30/2015	In Progress	In Progress
HR policies for the mill construction to be made available	09/30/2014	In Progress	In Progress
Project HR policies for the Mill operations phase to be developed on the basis of Stora Enso’s global HR policies	09/30/2015	In Progress	In Progress
1. Develop the capability to assess and incorporate into operations the risks and impacts of the forestry operations on water quality and quantity, through the following measures: (i) review and develop a strategy for assessing potential impacts of the forestry operations on surface water	12/31/2014 12:00:00 AM	In Progress	Under discussion with IFC client
1. Develop the capability to assess and incorporate into operations the risks and impacts of the forestry operations on water quality and quantity, through the following measures: (ii) incorporate results from the Forestry Companies’ own surface water monitoring trials and/or surface water monitoring trials elsewhere in comparable conditions into the forestry management work instructions / standard operating procedures and into IOSP. Provide IFC with updated guidelines	09/30/2015	Pending	In Progress
1. For the forestry operations, ensure ongoing monitoring of soil loss and fertility management and adapt the IOSP on the basis of the monitoring results: (i) monitoring plan for calibration of forest management practices with soil loss finalized and submitted to IFC for review and comment	12/31/2014 12:00:00 AM	Over Due	Under discussion with IFC client
For the forestry operations, ensure ongoing monitoring of soil loss and fertility management and adapt the IOSP on the basis of the monitoring results: (ii) periodic review of soil erosion monitoring results provided	09/30/2015	Pending	In Progress
1. For the forestry operations, ensure ongoing monitoring of soil loss and fertility management and adapt the IOSP on the basis of the monitoring results: (iii) Implement a process to evaluate what is learned from the ongoing monitoring of soil loss and incorporate those learnings into revised sustainability requirements in IOSP and road building, wood harvest and silviculture guidelines	09/30/2015	Pending	In Progress
Public health information program applicable to mill construction and operations: Develop and implement a local affected community and worker health information program with a focus on preventing communicable diseases). Program details will be communicated with local affected communities and workers including contractor and sub-contractor workers. Program key content and communication plan delivered before first disbursement. Verification through communication records semi-annually related to construction period activities	02/28/2014 12:00:00 AM	Over Due	Under discussion with IFC client
Management of Safety Risk in Road Transport: Each Project Company, will in relation to the mill and forest operations, plan and implement management procedures to ensure that its own transport services and any contracted transport services, including wood transport, to and from locations in Guangxi connected with the Project are performed in a safe way by its own employees and any contractor employees (including their sub-contractors). (i) Define safety requirements and guidelines for transport. (ii) Include the developed safety requirements into new transport services contracts. (iii) Establish a program to monitor safety in road transport which is reported in AMR	02/28/2014 12:00:00 AM	Over Due	Under discussion with IFC client
Social Land Monitoring: (i) Use an internal system of the Forestry Companies to track, investigate Existing Social Land and Additional Social Land (as needed) address the following: (a) the involvement of intermediate social land lease parties; (b) the difference between the rent paid by the Forestry Companies and the rent received by the primary land use right holders for the contracted land	09/30/2015	Pending	In Progress
1. Social Land Monitoring; (ii) Assessment by a qualified external expert of the system level implementation on Existing Social Land of the internal tracking system and related procedures, standards, and policies as referred to in clause (i) above.	09/30/2014 12:00:00 AM	Over Due	Under discussion with IFC client
In the case of acquisition of Additional Social Land: (i) Submit the current version of the SEGX Land Acquisition and Risk Management Manual to IFC; (ii) Ensure that relevant policies, clauses and annexes are included in any agreement outlining grounds for cooperation between Social Land EJV and the Beihai Company or any other intermediary party involved in Additional Social Land acquisition, and submit signed agreements to IFC	09/30/2015	Pending	In Progress
In the case of acquisition of Additional Social Land: (iii) Implementation of SEGX Land Acquisition and Risk Management Manual is confirmed by review findings of a qualified external expert, and the review findings are submitted to IFC	09/30/2016	Pending	In Progress
Social Land contract correction: (i) Report to IFC: (a) progress in Social Land contract correction, and (b) details on the application of the SEGX Land Acquisition and Risk Management Manual to the case of new land (or land involving new land use right holders) offered to SEGX arising from land-swaps, replacement, or adjustment of land area related to the Social Land contract correction process	09/30/2014	Pending	In Progress
1. Social Land contract correction: (ii) IFC and the Forestry Companies agree on sets of criteria based on current screening criteria, which shall be used to determine which contracts are to be regarded as “contracts considered potentially irreconcilable”	09/30/2014	Pending	In Progress
Social Land contract correction: (iii) Provide a list of “contracts considered potentially irreconcilable” to IFC	09/30/2015	Pending	In Progress
1. Social Land contract correction: (iii) Provide list of contracts of which termination is deemed not feasible for legal reasons, or because termination would disproportionately advantage middlemen or carry a high risk of triggering substantive local conflict.	9/30/2016	Pending	In Progress
Social Land contract correction: (v) Legal proceedings will be brought by the Forestry Companies to terminate those contracts included in the last-presented list in (iii) above but which are not listed in (iv) above.	10/31/2016	Pending	In Progress
Mill Site Resettlement (i) Monitor the progress of the resettlement action plan against the intermediate milestone objectives and indicators. This shall be verified by semi-annual internal reports. Adapt the resettlement action plan, in agreement with affected communities, as this monitoring shows necessary, to maximize the plan’s effectiveness in delivering its agreed objectives	06/30/2014	Over Due	Under discussion with IFC client
Mill Site Resettlement: (ii) The resettlement action plan objectives within the Project Company’s control are substantially reached. Whether such resettlement action plan objectives have been substantially reached will be verified by results of a completion audit conducted by a qualified external social consultant appointed by the Project Companies.	3/31/2016	Pending	In Progress
Mill Site – Resettlement action plan implementation The Project Companies will ensure the availability of financial and human resources to implement the resettlement action plan (RAP), these resources shall be commensurate with Stora Enso’s best efforts to meet RAP objectives that are within Stora Enso’s control	09/30/2015	Pending	In Progress
High Conservation Value Forest (HCVF) HCVF is included I Definitions and substantially refers to approaches and guidelines included in “Assessment, Management and Monitoring of High Conservation Value Forest, A Practical Guide for Forest Managers” (2008, HCVNet.org). identified and managed accordingly. Effective conservation and management of HCVF will be assessed through internal management systems and the annual FSC review process.	09/30/2015	Pending	In Progress
As needed based on “Guangxi Stora Enso Forestry Project – Forest Area Ethnic Minorities Livelihood and Rights Protection Research Report” findings. (i) Perform an internal review and update of the Stakeholder Engagement Plan (SEP) to include provisions to engage local ethnic groups (including ethnic minority contractor and sub-contractor workers) in a culturally appropriate manner	03/31/2014 12:00:00 AM	Over Due	Under discussion with IFC client
As needed based on “Guangxi Stora Enso Forestry Project – Forest Area Ethnic Minorities Livelihood and Rights Protection Research Report” findings: (ii) Where adverse impacts are identified, ensure ongoing free, prior, and informed consultation (FPIC) with identified ethnic minority groups. This shall be verified through review by a qualified external expert	09/30/2015	Pending	In Progress