While all Performance Standards are applicable to this investment, IFC’s 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: PS1: Social and Environmental Assessment & Management Systems PS2: Labor and Working Conditions PS3: Pollution Prevention and Abatement PS4: Community Health, Safety and Security The two hotels will be located in the urban areas of Lagos and Benin City where land ownership is well defined and title deeds are available. The site for the hotel in Lagos is owned by Skye Bank PLC and has been transferred to the Special Purpose Vehicle (SPV), Skye Capic Limited. The site is currently being used by Skye Bank as vehicle parking space for staff as well as storage for the bank’s various materials. It is secured by a wall, which has prevented irregular occupation. The hotel in Benin City will be established on a site previously utilized for similar purposes i.e., the Emotan Hotel, which reportedly ceased operations in 2002. Existing structures on this site will be demolished to accommodate the new CAPIC Hexagon Limited hotel. In both instances land purchases are on a willing seller/willing buyer basis; thus PS5: Land Acquisition and Involuntary Resettlement does not apply. Equally PS6: Biodiversity Conservation & Sustainable Natural Resource Management is not applicable. There are no Indigenous Peoples, as defined for the purposes of PS 7, in the area. Finally, no Cultural Heritage issues are recorded so far, although this will be confirmed in the Environmental Impact Assessment undertaken for the individual projects. Thus PS8: Cultural Heritage does not apply. Environmental Health & Safety (EHS) Guidelines that are expected to be applicable to this investment include: The General EHS Guidelines (April 2007), and The EHS Guidelines for Tourism and Hospitality Development (April 2007)

The EHSS impacts of the Sponsor’s operations are relatively limited. IFC’s review did not identify any significant adverse impacts or high risk exposures. Issues to address, as captured in the attached Environmental and Social Action Plan (ESAP), include: improvements in EHSS management systems, occupational health and safety, particularly during construction, waste water management and sewage treatment, and life and fire safety issues These matters can all be addressed using standard mitigation methods and procedures. Based on these considerations, this is a Category B project according to IFC’s Environmental & Social Review Procedure.

PS1: Social and Environmental Assessment and Management Systems Assessment: In terms of the Environmental Impact Assessment (EIA) Decree 58 of 1992, new major developments, including Skye CAPIC Limited and CAPIC Hexagon Limited, require an EIA. Thereafter, depending on the site location, rezoning may be required along with mandatory approval of building plans. CAPIC have commissioned EIA’s for the two hotels. The EIA is required prior to any planning and building approvals. Thereafter, a Letter of Approval is issued by the relevant government authority. For the current and future developments, CAPIC will be required to submit copies of all necessary approvals to IFC prior to the commencement of construction. CAPIC, as a private equity fund manager, operates an Environmental Management System (Environmental Social & Governance Policy & Procedure – ESG), which requires that they will undertake due diligence of potential investments including: site visits; studies and assessment of EIAs. This process, modeled along IFC PSs’, allows CAPIC to systematically review all EIAs. The review ensures that all actions required by them have either been fulfilled or put into a comprehensive Action Plan with time-bound targets for their completion. For this process, CAPIC uses an external consultant with a retainer to assist with the review for all their projects. It is the responsibility of the external consultant to recommend specialist studies as and when required. The procedures ensure that the environmental and social consultants use both local Nigerian requirements and the Performance Standards in the assessment of the project. The consultants will produce project-specific, time-bound environmental and social action plans. This same management system is being applied to these two projects. While CAPIC is the owner, Protea Hotels, a South Africa-based hotel chain, will management them. CAPIC will ensure that Protea has the organizational and management measures in place to meet IFC standards for hotels. Organizational Capacity: The ESG issues are handled at high management level, specifically at fund level by the Fund Manager CAPIC, Principal and Real Estate Industry Specialist. Management Program: The ESG allow CAPIC to undertake systematic due diligence of potential investments including: site visits; studies and assessment of EIAs. To ensure and enforce ESG issues, one of the three senior managers mentioned above will be appointed director in investee/SPV ventures, including for these two hotel projects. Training: Management of CAPIC have undergone E & S training, including IFC PSs’ training delivered in the fourth quarter of 2008 by IFC and training by the Commonwealth Development Corporation. CAPIC also has a process whereby there are weekly meetings to discuss ESG issues, amongst other operational issues. In addition, every quarter, CAPIC undertake a retreat where ESG issues are also on the agenda. Monitoring: During the investment period, CAPIC’s Investment Manager will: Confirm that the company is complying with national and local legislation and the Performance Standards relating to ESG. Ensure that the investee company/SPV is complying with CAPIC’s ESG guidelines and is reporting as such to its own Board. Review the status of implementation of Environmental and Social Action Plan (ESAP) and compliance with any legal agreements. Reporting: According to CAPIC’s ESG, reports will be compiled to provide a summary of observations made in the course of implementing the ESG system and the ESG performance of the investee companies. The reports will be prepared as follows: 1. Reports to the Board of Directors of Investee Company Frequency: Half - Yearly Responsibility: Management (CAPIC Investment Managers to ensure that this is done and to be confirmed by CAPIC representative on the Board). 2. Report to CAPIC Frequency: Half - Yearly Responsibility: ESG Coordinator – requires Investment Managers to produce ESG reports on their Investee Companies. 3. Report to ACA Fund Investors Frequency: Annually Responsibility: ESG Coordinator to report on; Investee companies and ACA ESG system. The Investment Managers submit reports to their Fund Manager and to the ESG Coordinator who then compiles a summary for the purposes of reporting to the ACA Board and the Investors. The ESG coordinator will discuss any issues of concern in the reports to be submitted with the Fund Managers and if need be, recommend any further action required. ACA keeps records of reports from investee companies and reports sent to investors. In future, CAPIC will be required to submit an Annual Environmental & Social Monitoring Report (AMR) to IFC detailing environmental and social performance of these two hotel projects, as appropriate. PS2: Labor and Working Conditions Working Conditions and Terms of Employment: CAPIC signed a 10 – year management agreement with Protea, who will manage the hotels under their (Protea) brand and will be responsible for employing the personnel who will work in these hotels. Protea documents relating to their human resources were not available for review during appraisal. It is also not known at this stage what the extent of the human resources required for the two hotels and how many of these employees will be local versus expatriates. CAPIC will ensure that Protea provides IFC with an acceptable human resources policy prior to the start of operation. Nigeria ratified the International Labor Organization’s Core Labor standard. Thus, compliance with Nigerian law will also address the basic requirements of PS 2. The hotels will have in-house kitchens, and functions such as cleaning will also be undertaken in-house. Individuals will be employed according to specific Conditions of Agreement and in accordance with national law. So as to ensure compliance with this Performance Standard, CAPIC will review the hotels Conditions of Agreement against the PS 2 and amend these as deemed necessary. Skye CAPIC Limited and CAPIC Hexagon Limited have appointed WSP Africa as their Development Manager responsible for structural, electrical and mechanical engineering of the project as well as Project Management. WSP Africa will also be responsible for the individual construction sites, including ensuring compliance with occupational health and safety plans and applicable legislation. WSP Africa will contract out the construction of the facilities. For these 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, CAPIC will undertake monitoring to ensure compliance and report thereon to IFC. PS3: Pollution Prevention and Abatement The two facilities will be equipped with boreholes to supply potable water. It is estimated that each facility will require approximately 100 000 liters of potable water per day. The water will be treated using a multi-grade sand filter, activated carbon filter, iron and manganese remover system, water softener and a chemical dosing system (chlorination and pH correction). On a daily basis, filtering and flushing as well as dosing will be undertaken as part of monitoring. On monthly basis water sampling and analysis will be undertaken for compliance with WHO and NIS standards and corrective measures implemented as required. Waste water handling: The provisions for wastewater treatment were found to be adequate. The two proposed facilities will have packaged sewerage treatment facilities that include chlorination. The sewage generation is estimated at 75Kl/day with peak flow-rates of 3.5l/s. The effluent is expected to comply with relevant standards for COD, BOD, suspended solids, Ammonia and E. coli. On a daily basis, the operator will undertake a visual inspection of the treatment plant operations, recording running hours and flows and checking sterilent levels and operation of sterilization equipment. In addition, the operator will measure and record residual chlorine levels and take corrective action where required. On a fortnightly basis, a specialist will undertake inspection of the plants, sample process stream and analyze the effluent, and report analysis results and flows as well as recommending any corrective action required. Energy: The proposed developments will use back-up diesel generators. Three generators each with a capacity of 400KVA will be used at each facility. Ten days of fuel, or 48 000 liters supply for the generators will be stored on site in above ground tanks located in bund walls. The fuel storage facilities will also be equipped with a sump with semi rotary hand pump to allow spillage to be pumped to drains should there be a spillage. In addition, standard firefighting equipment and signage according to OHS Act will be put in place for emergency situations. The generator emissions are in accordance with European codes and the generators are of a size less than 1MW, recognized in World Bank Group guidelines as being below the threshold of concern for air emissions. Both Skye CAPIC Limited and CAPIC Hexagon Limited are committed to eliminating appliances that contain ozone depleting substances. As defined in the ESAP, the use of CFCs and other such substances will be avoided. Solid waste: Solid waste disposal at the facilities will be via the local municipal system. While Protea, the appointed hotel managers, may stipulate that hotel wastes should be sorted and recycled, off-site systems in Lagos are limited so as to accommodate such efforts. The ESAP defines the need for a waste management procedure within the hotels to ensure waste is adequately managed. Hazardous materials: Periodically, all the properties will be fumigated for pests and this will be contracted out to registered companies. The two hotels will ensure that pesticides sold and used at and within their premises comply with international requirements which may include Nigerian commitments. Specifically, the hotels will ensure that no class Ia (extremely hazardous) and Ib (highly hazardous) pesticides are used at and within their premises in line with IFC guidelines and WHO pesticide classification system. PS4: Community Health, Safety and Security Infrastructure and Equipment Safety: During the operational phase, the primary identified risks at all facilities are those related to Life, Fire and Safety (LFS) and Food Safety. The two proposed developments will have LFS plans incorporated in the design to manage and address such issues in the event of an emergency. These will include fire detection (smoke sensors) in the individual rooms linked to an alarm system, fire hose reels and fire extinguishers on the individual levels and directional signs displayed throughout buildings. Both Skye CAPIC Limited and CAPIC Hexagon Limited will be required to institute an independent technical review on LFS issues. The technical review will start at the design phase and following completion of construction to ensure that the relevant measures comply with national and international standards. It could not be determined during appraisal which food safety system the Protea managed hotels will use. Therefore, as required in the ESAP, both Skye CAPIC Limited and CAPIC Hexagon Limited should demonstrate compliance with an international standard within 6 months of operations commencing. At the two facilities, and as noted above, water will be sourced from boreholes and treated in packaged water treatment facilities that include chlorination. Water quality will be monitored on a daily basis and CAPIC Protea Nigeria will develop a common procedure for the two facilities. The procedure will ensure monitoring is in accordance with the WHO and NIS guidelines for monitoring potable water as already defined above. Security: Security at all facilities will be outsourced and provided on a 24 hour basis. 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.

While EIA’s have been commissioned for the two SPVs’, the extent of stakeholder consultation generally varies, and can be limited. Thus, following completion of the EIAs’ for the two SPVs’ as well as future developments, IFC has requested CAPIC to make such documentation, including the Letter of Approval, available at agreed public places for 30 days prior to construction commencing. CAPIC have adopted a strategy whereby they partner with a local landowner who would generally have knowledge of the local community, thereby facilitating community engagement.

Inquiries and comments about the project can be made through the contact provided below. Obi Nwogugu Capital Alliance Nigeria 8th Floor, C & C Towers Plot 1684, Sanusi Fafunwa Street Victoria Island, Lagos Nigeria Direct Line: +234 1 279 9678 Tel: +234 1 270 6909 – 10 / +234 1 270 4420 Ext 113 Fax: +234 1 270 6908 Email: obi.nwogugu@aca-web.com