All Performance Standards are applicable to this investment, but 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 and Management Systems • PS2: Labor and Working Conditions • PS3: Pollution Prevention and Abatement • PS4: Community Health, Safety and Security The proposed Project with associated utilities and facilities will be located at the Eldorado Integrated Development and Free Zone S.A.E Company site, which is at Sector-2 of the Southern Region of the Economic and Industrial Zone, North West of the Suez Gulf at Ain Sokhna. No protected areas, protected species, or cultural heritage sites were identified in the draft ESIA. Indigenous peoples were not identified in the project area. Therefore PS 5, 6, 7 and 8 are not applicable.

This is a Category B project according to IFC’s Environmental and Social Review Procedures because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The investment involves a greenfield PET manufacturing site in Egypt. The proposed Project with associated utilities and facilities will be located at the Eldorado Integrated Development and Free Zone S.A.E Company site, which is at Sector-2 of the Southern Region of the Economic and Industrial Zone, North West of the Suez Gulf at Ain Sokhna. The land is a freehold land. There are no communities within 6 km of the proposed project site. Mitigation measures for the potential environmental and social impacts are identified and incorporated into an attached Environmental and Social Action Plan (ESAP).

The key environmental and social issues for this project include the following: - Environmental and social management system - Wastewater treatment and discharge - Operational hazards and hazard operability study - Greenhouse gas emissions and energy efficiency SAPL has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with the environmental and social requirements. These include Egyptian laws and regulations, the IFC Environment and Social Performance Standards and the World Bank Group (WBG) environmental, health and safety guidelines. The information about how these potential impacts will be addressed by SAPL is summarized in the paragraphs that follow. Further information is provided in the attached ESAP, which is agreed upon by IFC and SAPL and will address the compliance gaps with IFC’s requirements. 1. Social and Environmental Assessment and Management Systems Site Situation and natural environment: The proposed new PET site is located in an existing designated industrial park in Ain Sokhna, Egypt. There is an access road to the site from the Red Sea coastal highway. Electricity and water will be provided by the industrial park. There is no residential community at or near the site. The preliminary ESIA screening for the site indicates that there are no protected areas, protected species, or cultural heritage sites at or near the proposed project site. Environmental and Social Assessment: SAPL contracted external experts to conduct environmental and social assessments for the proposed site according to both Egyptian regulatory requirements and IFC Performance Standards. IFC reviewed the draft ESIA together with major data from the Company and made preliminary conclusions. According the draft ESIA, the proposed project will meet both local regulatory requirements and IFC policy/guidelines upon successful implementation of the mitigation measures. SAPL is committed to finalize the ESIA before the construction and ensure that the ESIA meets both local regulatory requirements and IFC E&S policies and World Bank Group (WBG) EHS guidelines. The ESIA will also be disclosed on the IFC website and locally. The project area is not included in or near any potential archeological sites, which are known to the Egyptian Government. However, there is always a potential to find buried antiquities in Egypt. As indicated in the ESAP, SAPL will prepare a Chance Finds Procedure of potential buried antiquities for the construction works. Environmental, health, and safety (EHS) management and organization: The EHS management at the Indian operations is under technical and HR managers. SAPL implemented ISO 14001:2004 Environmental management system and BS OHSAS 18001:2007 Occupational Health and Safety management system in its Indian operations. In accordance with the ESAP, SAPL will establish an EHS management structure at Egypt plant, based on the model of its Indian operations. Furthermore, SAPL will set up an effective corporate EHS management system based on the requirements of IFC Performance Standards. Training, monitoring, and reporting: SAPL has an established program to provide necessary training for all its employees in the field of environmental and social performances related to its current operations in India. SAPL also conducts routine environmental, health and safety monitoring for its operations. SAPL keeps its environmental and social performance records through its internal reporting structure. SAPL will copy these systems for its Egyptian operations, and disclose its ESAP, which will be drafted together with IFC, to the nearby communities in Sokhna, Egypt, and disclose its annual E&S performance reports on its website. 2. Labor and Working Conditions Human Resources Policy and Management: SAPL has a Human Resources policy which specifies the terms of employment and working conditions at its Indian site. These include procedures for hiring and recruiting, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, leave and vacation, and retiring. The HR department also works as an employee grievance mechanism. SAPL only hires employees older than 20. For the Egyptian operation, SAPL is committed to implement a similar HR policy to meet requirements of Egyptian regulations and IFC Performance Standard 2. SAPL will prepare a human resources policy and procedures for its Egyptian operation and the employees should have access to the HR policy and procedures. The HR office will also provide a grievance mechanism for the employees. Working Conditions and Worker’s Organizations: SAPL will hire a local law firm to provide legal assistance on labor issues. SAPL allows collective bargaining and will follow all the Egyptian labor laws and related IFC requirements for working conditions and worker’s organization. SAPL is committed to comply with IFC requirements for the labor camp during the construction period. Non-Discrimination and Equal Opportunity: Hiring and promotion are strictly merit-based and there are relevant non-discrimination and equal opportunity rules in the HR policy. At the proposed Egyptian plant, SAPL may have 350 to 400 employees, in which 30 to 40 will be from India, and the remaining 300 to 350 employees mainly hired locally from Ain Sokhna, Egypt. Retrenchment and Protecting the Work Force: Although retrenchment is not expected for this project, construction works will require a temporary workforce of roughly 1,000 contractors. SAPL will hire local employees for operations, the permanent workforce will be around 350. SAPL is committed to comply with Egyptian labor law and will not hire workers below the age of 20 Occupational health and safety (OHS): Operational safety is highly emphasized in the operation at SAPL. There is routine OHS training including new employee training and annual refreshers at its Indian operations. For the plant in Egypt, OHS operational procedures for each position will be prepared three months prior to trial production, and all employees will be trained in OHS procedures based on their positions before the trial production. SAPL will also develop workplace air quality/noise monitoring programs, and track the statistical trends of near-miss and accidents, as part of its EHS management system programs/procedures. 3. Pollution Prevention and Abatement Raw materials and resource consumption: At the Egyptian site, the proposed major raw material consumption is Purified Terephthalic Acid (360,000 t/y), Mono Ethylene Glycol (142,000 t/y), water (1100 t/d), electricity (67,200 MWhr/y) from local gas-based power plant, and natural gas (6000 Nm3/hr) from the national gas network for process heating. Environmental Compliances: SAPL will generate approximately 124 t/d wastewater at its Egyptian site after treatment and recycling. All the treated water will be recycled in the process or greenbelt. According to the initial analysis and modeling calculations of the draft ESIA, air emissions, and ambient air/noise will meet both local regulatory requirements and WBG guideline limits upon successful implementation of the mitigation methods. Solid and hazardous wastes: Domestic non-hazardous solid wastes will be picked up by municipal contractors for sanitary disposal at a local landfill. The major industrial solid wastes are off-spec oligomers, which are sold for other industrial use. Used catalysts are sent back to the manufacturers for regeneration. The other limited amounts of hazardous wastes generated at the Egyptian site will be sent to the hazardous waste disposal center in Alexandria for recycling and disposal. The design and operation of the hazardous waste disposal center meets the requirements of European Union. Operational hazard: Some of SAPL’s raw materials are hazardous. The transportation, storage, and handling of these materials at the Indian plant meets local regulatory and WBG guideline requirements. SAPL will implement a similar hazardous material management system at the Egyptian operations. As stated in the ESAP, SAPL will conduct hazard operability (HAZOP) studies for the Egyptian site during the detailed design phase. Fire prevention and emergency response: SAPL will install adequate firefighting equipment at the proposed site. SAPL will have its own fire fighting staff and first aid clinic onsite. SAPL plans to conduct mock emergency response (ER) drills once a month, and plant-wide ER evacuation drills twice a year. The nearest fire station, set up for the industrial park, is approximately 10 minutes from the site. Greenhouse gases (GHG) and energy efficiency: At the proposed Egyptian site, according to preliminary estimates from the ESIA, SAPL will generate 95,550 t/y GHG directly for process heating and generate 39816 t/y GHG indirectly from power purchase. As required in the ESAP, SAPL will conduct a routing energy efficiency audit during operations to identify potential energy efficiency measures and potentially reduce GHG emission. 4. Community Health, Safety, and Security Community health, safety and security: The proposed site is located inside a designated industrial zone. There is a tourist resort around 6 km from the proposed site, but there are no communities near the industrial park. The qualitative risk assessment (QRA) for the Egyptian site is still under preparation. However, due to the distance, the nearest tourist resort is unlikely to be impacted by a major fire. Emergency preparedness and response: The raw materials and products at the Egyptian site will be transported along the Red Sea coast highway by contractors directly from a port to the south. The main raw materials and products are not toxic. SAPL will have ER plans available and conduct routine drills for fire fighting and potential chemical explosion/releases. SAPL will coordinate with neighboring companies and involve the local hospital, and fire brigade. In accordance with the ESAP, SAPL will only contract with transportation companies that have defensive driving programs, acceptable safe driving records, and sufficient emergency response methods. SAPL will also monitor the hazardous material transportation and require the transportation company to report the accident rates quarterly. Security personnel: SAPL will hire an external agency for plant security, which conducts routine ID checks at the gates plus security monitoring. The security personnel do not have any firearms. For serious security issues, SAPL reports directly to the local police station.

SAPL will hold its first public consultation meeting at its Egyptian site before the constructions. During the peak construction period, there will be approximately 1,000 contract laborers working at the site, including 200 management staff and technical laborers from India and China. SAPL will prepare a labor camp management plan to minimize the social, cultural, and environmental risks during the construction phase. In addition, SAPL will hold a second formal public consultation meeting at the Egyptian site before trial production, and maintain regular communications with the communities in Sokhna area.

SAPL will disclose this document on its website. SAPL will also disclose the Arabic versions of this document and the Executive Summary of ESIA (once available) at factory gate of the Project site located at Eldorado Integrated Development and Free Zone S.A.E., which is at Sector 2 of the Southern Region of the Economic and Industrial Zone, North West of the Suez Gulf at Ain Sokhna. Please contact the following for inquiries or concerns about the environmental and social impacts of this project. Contact in Egypt: K.S.Reddy, Chief Operating Officer, Address Ahmed Fakhry&Losaka Streets, Nasr City, Cairo-11391. Phone: +2 02 26710925, Mobile: 0168774534. Email: info@eipet.com / ksr2010@gmail.com.