All Performance Standards are applicable to IFC investments and, to manage E&S risks related to future operations, GAC will adopt IFC’s Performance Standards together with legal and other standards and requirements that apply. IFC’s environmental and social due diligence indicates that the specific investment related to Company operations in the Caspian region will have impacts which must be managed in a manner consistent with the following Performance Standards: PS1: Social and Environmental Assessment and Management Systems PS2: Labor and Working Conditions PS3: Pollution Prevention and Abatement PS4: Community Health, Safety and Security Performance Standards 5, 6, 7 and 8 are not expected to be relevant as no land acquisition resulting in involuntary resettlement is expected and no sensitive natural habitats or natural resource use, indigenous peoples, and/or cultural heritage will be directly impacted.

This is a Category B investment because environmental and social impacts associated with GAC’s activities will be limited and easily avoided or reduced through mitigation and management measures that can be readily applied and implemented through adherence to the Company’s policies and procedures. GAC is a recognized global operator in the marine, shipping and logistics service industry, an industry that is strongly regulated in relation to EHS management through international maritime standards and shipping codes. Compliance with these standards and codes is a pre-requisite for vessels using international ports and harbors around the world. Effective E&S management is also a specific requirement of the Company’s key client base and therefore demonstration of the careful management of E&S risks through compliance with international standards is essential for GAC’s activities.

E&S issues relating to the investment are summarized below along with specific information on how potential impacts and risks are addressed by the Company. Upon implementation of the specific measures described below, GAC’s activities will comply with E&S requirements, namely host country laws and regulations, IFC’s Performance Standards and the applicable IFC EHS guidelines. Performance Standard 1: Social and Environmental Assessment and Management Systems GAC has a Group Health, Safety, Security and Environment (HSSE) Policy that commits all of GAC group companies to establish a local HSSE Management System that is relevant to their operations and reflects local laws and local conditions. HSSE Management Systems are integrated with a Quality Management System that is organized to comply with ISO 9000: 2000 at all locations. The integrated Management Systems cover marine operations and onshore activities as required. Potential hazards and related adverse impacts to operations, personnel or damage to the environment are identified through risk assessments carried and the E&S management procedures that are implemented through the Management System to control and manage these risks are designed, at a minimum, to ensure compliance with all relevant and applicable legislative requirements. GAC will adopt IFC’s Performance Standards as part of legal and other requirements that apply to future operations. The Management Systems also support the applicable international maritime codes and standards for GAC vessels which cover International Maritime Organization (IMO) protocols consisting of a Safety Management System as per the International Safety Management (ISM) Code and the International Ship and Port Facility Security (ISPS) Code. IMO Code certification for each vessel is provided annually by one of IMO’s approved auditors Bureau Veritas (BV), American Bureau of Shipping (ABS) or Det Norske Veritas (DNV). A well defined organizational structure is in place to establish and maintain the Management System including at the corporate and local level. All personnel are trained in EHS requirements as part of the GAC induction program. Specific personnel are responsible for the development, administration and maintenance of GAC EHS management procedures including risk assessment, safe working practices, vessel standards and codes. Implementation and performance is monitored through regular internal inspections and audits with corrective and preventative actions developed and tracked to address non-conformities identified. Performance is evaluated against annual objectives and targets set at a group company level. In addition to the external annual vessel audits under the IMO codes, regular external audits of GAC facilities and vessels are also carried out by GAC’s clients. In terms of continual improvement, a company-wide HSSE guidance program has been developed which each year considers existing practice along with the policies and procedures of GAC clients so that additional or alternative good industry practice may be recognized and adopted for implementation. Performance Standard 2: Labor and Working Conditions GAC’s Code of Ethics communicates the high value that the company places in staff diversity, non-discrimination and equal opportunities in all of the countries that they operate. GAC has a Human Resources Policy in place and a Human Resources Policy Manual which describes: recruitment procedures, employment conditions including training and development, compensation and benefits and the performance appraisal system. Local staff handbooks at a minimum follow local laws and regulations in terms of employees and employment. All GAC staff; shore-based personnel and vessel crew, are employed directly as permanent staff and individual conditions of employment are communicated through a contract of employment issued to each member of staff. Occupational health and safety hazards are closely managed and supporting procedures are strictly enforced. There are safety committees in place at both shore-based facilities and on-board GAC vessels. Health and safety risk assessments are conducted prior to each activity and procedures, including emergency response procedures, are agreed and amended where necessary for each identified potential accident or emergency situation. A crisis management plan has also been developed. All vessels adhere to the IMO SOLAS (Safety of Life at Seas) standard. Incidents in relation to all Company activities, including near misses, are reported to corporate management on a monthly basis. Records for 2008 and 2009 indicate minor incidents within industry norms. All incidents are investigated and any non-conformity with procedures recorded and, where necessary to prevent re-occurrence, new corrective actions are implemented. Performance Standard 3: Pollution Prevention and Abatement All vessels conform to the IMO MARPOL (Marine Pollution Prevention) standards for waste management and pollution control including the handling and disposal of garbage and liquid effluents which includes: the shipment to shore for disposal of all solid waste material and the treatment and disposal of sewage waters and oily waters in accordance with this international standard. In terms of vessel air emissions, GAC’s fleet has International Air Pollution Prevention certification (IAPP) in place for applicable engines for the emissions of nitrogen oxides and sulfur oxides. Shipboard Oil Pollution Emergency Plans (SOPEP) are available for each vessel as is necessary under the vessel’s ISM Code. These emergency plans contain the oil and/or chemical spill contingency arrangements in place and the response to be implemented in the event of a spill. Waste management procedures are implemented at all GAC onshore bases in accordance with local regulatory requirements, although onshore waste management and housekeeping procedures and standards are currently under review as part of GAC’s continual improvement of E&S management and performance. The development of consistent procedural standards in these areas will form part of GAC’s HSSE guidance program for 2010. Performance Standard 4: Community Health, Safety and Security Impacts on communities are minimal. GAC shore-based facilities are located in existing port areas and industrial sites. Existing facilities meet international design parameters for safe and secure operations of ports and storage terminals and GAC will ensure that any future facilities will also adhere to international standards. In accordance with the requirements of Performance Standard 4, GAC will ensure that the exposure of local communities to potential EHS risks and impacts associated with base facility operations is minimized.

GAC is committed to providing EHS information to its stakeholders where necessary. No local communities are expected to be directly affected by impacts associated with GAC’s routine activities in the Caspian area. GAC will however implement procedures for engaging with communities in the event that communities are present in the vicinity of future onshore facilities. Communications would include information regarding GAC operations, the EHS aspects of their operations and would facilitate dialog with the communities through the relevant authorities to address any concerns. In these instances, GAC will implement a system to document and address community grievances.

Due to the global nature of the shipping industry, no local communities are expected to be directly affected by the project. Any queries and/or comments about the project may be directed to: Mr. William Nisser Group Treasurer Gulf Agency Company Ltd. P.O. Box 18006, JAFZ Dubai United Arab Emirates Phone: +971 4 8811411 william.nisser@gacworld.com www.gacworld.com