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 and Management Systems; - PS2: Labor and Working Conditions; - PS3: Pollution Prevention and Abatement; - PS4: Community Health, Safety and Security; It was determined after review that issues described by the other Performance Standards are not encountered in this project for the following reasons: PS5: land was acquired through willing buyer/seller process from the previous private owner. No person or economic activity was displaced as a result of this transaction; PS6, PS7 and PS8: the land to be developed is located in a modified habitat, adjacent to a main road and used for animal pasture. The area has no known special biodiversity significance, nor are indigenous peoples or cultural heritage encountered.

The key social and environmental issues associated with this project are community engagement and the planning process, management of environmental impacts and occupational health and safety during construction, equitable working conditions; energy and water use and discharge of waste water, minimization of solid waste and, life and fire safety. This project has limited off-site social and environmental impacts and those there are may be mitigated by readily available techniques. This is therefore a Category B project according to IFC’s Environmental and Social Review Procedure.

The company has presented plans to address environmental and social impacts to ensure that the proposed project will, upon implementation of the agreed mitigation measures comply with the environmental and social requirements of the Costa Rican laws and regulations and IFC Performance Standards and applicable IFC Guidelines. These mitigation measures are described below. - Social and Environmental Assessment: A preliminary Environmental Impact Assessment (EIA) for the entire development, including the project and the retail and office areas is currently being undertaken to the requirements of SETENA, the National Environmental Secretariat of Costa Rica) by a local consultant. This assessment will be presented to SETENA upon completion. After review, SETENA could either require further assessment or determine that an approved environmental management program provides sufficient environmental safeguards. Once de Abril will provide IFC a copy of the EIA when available and this will be made available to interested parties locally to the project site. Expected environmental impacts/risks in construction are not significant ones. They are local, reversible, and may be easily controlled through well known engineering techniques, such as dust and erosion control, good housekeeping measures, such as proper solid waste and fuel management, and rigorous management of safety during construction. - Management Program: The developer currently expects to develop a construction project management plan following review of the EIA. In practice, environmental management responsibility will be devolved to the General Contractor by inclusion of environmental and safety-related clauses in all contracts to be signed for project execution. This will include compliance with all relevant local and national regulations. The General Contractor will be required to have at least one person responsible for environmental compliance at the site, who would in turn oversee the smaller sub-contractors’ compliance with the environmental requirements for the project. Permanent, ongoing supervision and corrective actions will be undertaken by the developer. The Contractor will have responsibility for ensuring safety on the worksite, and will, for example, regularly check that proper sanitary facilities are installed, that cool, safe water is available to all workers, and that protective equipment is worn as required for noise protection (ear-plugs, etc.), dust protection (goggles, etc.), personal fall protection (life-lines, harnesses, etc.) and other more general protective equipment (steel toe boots, reflective vests, hard helmets, gloves, etc.) During the project’s operational phase, the property will be managed by a Marriott team in full compliance with Marriott’s highly regarded social and environmental requirements. The Sponsor’s project manager was trained in application of the Performance Standards by IFC, and has incorporated Performance Standard requirements into project specifications and tendering documents. Marriott’s staff, who will have responsibility for ongoing hotel management have been trained under that company’s environmental program. -Labor and Working Conditions: The hotel will adopt the Human Resources policies of Marriott Courtyard and the requirements of Costa Rican law, and therefore will meet IFC’s Performance Standard 2 requirements. The hotel will use employees rather than contracted workers for all normally-required positions in the hotel. The nature of the working relationship is communicated to potential employees during the recruitment process and confirmed in writing upon taking up employment. Salaries and non-salary benefits follow local norms. The company would permit formation of worker organizations should a majority of employees seek this. Marriott has a policy of non-discrimination in employment and indeed promotes diversity among its workforce. These policies will be adopted for this project. Potential employee grievances would be addressed through parallel mechanisms, line management, the property’s human resources channel and through the General Manager’s open door policy. Retrenchment is not anticipated: this is a greenfield hotel project that will create employment. Occupational health and safety in construction was described under the management system section. In operation, hazards are well known to the hotel operator, Marriott and will be managed according to that company’s well proven procedures. - Emissions to Air: Air emissions will arise from the small gas-fired boilers used to heat water: these will be insignificant. The hotel will not have a dry-cleaning facility. A 750 kVA generator will be provided, but for standby purposes only. Zero –ODP refrigerant (R410A) will be adopted in air conditioning systems. - Emissions to Water: Sanitary waste water and kitchen effluents will be treated on site to the requirements of the Costa Rican authorities. Treatment will be an aerobic treatment system with activated sludge and an extended aeration system. - Resource Efficiency: The hotel will be designed to be an efficient user of energy and water; this is an area to which Marriott devotes considerable attention. For example, efficient air conditioning systems and controls will be used, high efficiency lighting and low flow water-using appliances will be adopted. Design data supplied by the developer indicates best practice use of energy and water. Air conditioning system design remains under review: normal practice in premises such as these is to use variable refrigerant volume (VRV) air conditioning systems, though a central chiller-based system may provide a superior solution. - Solid and Hazardous Wastes: Wastes generated will include food residues, and paper and plastic wastes, and maintenance residues such as used lubricants, oils and paints. These will be disposed to authorized municipal landfill and hazardous waste management contractors. - Community Health and Safety: The project developer has retained professional advice and has designed the life and fire safety systems of the hotel to be fully compliant with NFPA, requirements, as also required by Marriott and local regulation and meeting IFC requirements in this respect. Construction plans include an automatic sprinkler system plus hose panels in every floor, which will be supplied by a reservoir tank and a motor driven fire pump. Also, a fire alarm system has been implemented in the designs, which users smoke sensors in every room, hallways, public areas, etc, hose flow sensors, and manual pull stations. Regular checks on construction/implementation progress, and a post-construction check will be undertaken of the correct installation and functioning of all fire protection equipment, and inspection routines will be developed and maintained. Hurricane activity has also been considered in project design, by incorporating Miami Dade County’s hurricane zone requirements for roofs, exterior walls and windows (windows will be laminated impact resistant glass). Monitoring and management programs to assure hygiene and safety of hot water systems, potable water systems and swimming pool water will be established following Marriott norms, with results reported to IFC.

Community engagement to date has been limited to the presentation of the project plans to the local government of Alajuela. This will be supplemented by disclosure of a Spanish translation of this review summary at the address shown below, and a noticeboard at the project site that will depict the project under construction and give contact details for further information. Neither the developer nor the Sponsor has yet developed a community grievance mechanism, feeling this issue is well covered by the well known ability of citizens to make representation to local government in Alajuela. After opening, community engagement will take the form of advertising the facilities of the hotel to potential customers.

Project documentation will be available at Caribe Hospitality’s offices, located at the following address: Centro de Negocio Trilogía, Edificio # 1, Suite #124B, Escazú, Costa Rica.