While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the project 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 PS5: Land Acquisition and Involuntary Resettlement In accordance to the Ghanaian regulations, the existing and future locations for BDCs will be industrial dedicated areas within the urban area in Accra as well as other locations around the country. None of the BDCs are or will be located in either sensitive or protected areas therefore PS 6 is not triggered. Nor the current BCDs neither the future BDCs will be located in or nearby indigenous communities and/or areas of cultural sensitivity. Thus neither PS7: Indigenous Communities nor PS8: Cultural Heritage is applicable to the project. Environmental Health & Safety (EHS) Guidelines that are expected to be applicable to this investment include: General EHS Guidelines (April 2007), and EHS Guidelines for Crude Oil and Petroleum Product Terminals (December 2007).

This is a Category B project according to IFC’s procedures for Environmental and Social Review of Projects because the project has limited adverse impacts and risks which are manageable. IFC’s appraisal of this potential investment has identified the following environmental, social, health and safety issues: Management of fuel storage, loading and unloading Control of oil spills, air emissions, and liquid effluents, safe disposal of oils, waste, etc. Safety prevention measures (i.e., fire, explosion, leaks, spills) Emergency preparedness and response Workers exposure to volatile organic vapors.

PS1: Social and Environmental Assessment and Management Systems Social and environmental assessment: IFC and SCB may conduct EHS assessment of each of the potential BDCs applying to be part of the project to ensure they comply with the IFC Performance Standards. In addition, the Environmental Protection Agency (EPA) in Ghana, requires all BDCs to submit an Environmental and Social Impact Assessment (ESIA) as part of the application process to obtain the Environmental Permit for the construction phase and then the Environmental Certificate for the operation phase. Community engagement: It is anticipated, that the BDCs will be located in areas distant from communities. However, in case that a given BDC is located near communities, as part of the ESIA process they will be required to conduct public consultation and to implement all needed actions to ensure the community will be protected against potential negative impacts. The Environmental Management Programs and the Decommissioning Plans are also part of the ESIA. Management systems and training: The BDCs will have an Environmental, and as appropriate, a Social management system. They will also conduct periodic EHS training programs for their employees and contractors. Organization: The BDCs will have EHS trained personnel to ensure all EHS aspects of its operations, its contractors, and those relevant at the associated entities in their business supply chain (trucks, terminal operations, etc.) are adequately handled. Monitoring: The BDCs will conduct monitoring of key parameters such as oil and grease concentrations after the wastewater control systems to ensure the discharge levels comply with IFC requirements. Reporting: The BDCs will submit annual EHS performance reports to IFC. PS2: Labor and Working Conditions Human Resources (HR): All BDCs will have a human resource policy in line with IFC requirements, outlining the rights and obligations of own and contracted workers during the construction and operation phase. Specifically, for the construction subcontractors, the BDCs will prepare a workers safety and protection procedure in accordance with Ghanaian and IFC requirements and will require its implementation. Special attention will be given when laborers from countries other than Ghana are part of the temporary labor force during the construction phase. Workers’ Organization: BDCs’ workers may or may not be organized in unions. However, the BDCs will not take any measures to prevent the establishment workers’ organization and this will be reflected in the BDCs HR policy. Non-Discrimination and Equal Opportunity: The BDCs will primarily hire workers from the local communities and will have an explicit non-discrimination and equal opportunity policy in their overall HR Policies. Occupational Health and Safety (OHS): The BDCs will have an Occupational Health and Safety management system as well as incident reporting / environmental incident reporting system. Terms and Conditions of Service and Grievance Mechanism: The BDCs will have in place a formal grievance mechanism for all employees. All BDC workers will be provided with labor contracts and pay slips. The pay slips will specify payments, accumulated holidays and deductions for social security. All workers are eligible for social security and health care. PS3: Pollution Prevention and Abatement Air Emissions: The storage tanks of the BDCs will be furnished with air emission control devices (i.e., internal floating roofs) to prevent VOC releases to the atmosphere. Other source of air emissions will be that from the trucks loading products. Even though, the trucks for loading and distribution operations are the responsibility of the oil marketing companies, the BDCs, as part of their internal EHS management system will ensure the trucks are in good operational condition (to reduce release of air pollutants to the atmosphere.) Liquid Waste: The BDCs will ensure that the liquid effluents generated will be properly treated prior discharge. The storm water runoff will be treated in on-site oil/grease separation systems achieving 10 mg/l of oil/grease concentration. The domestic wastewater generated will be treated properly before being discharged. It is anticipated that the domestic wastewater generated during construction will be collected and managed through septic tanks. Waste Management System: Wastes generated may include tank bottom sludge, spill cleaning materials and contaminated soil. These hazardous wastes will be properly stored until collected by third party independent agencies, which work under EPA’s supervision for proper reuse/disposal. Domestic wastes are collected and disposed by the local authorities. Energy use: Power and energy for the operations at the BDCs will be provided by national grid. Water Quality and Use: The BDCs obtained the water needed (fire, domestic, clean up) from the municipal system. There are no anticipated negative impacts from the water usage. However, whenever a new BDC is built, it addresses this aspect in the ESIA. Safety Prevention: The BDCs will ensure that their own storage tanks are build and operated in accordance with international standards ensuring they have, at a minimum, provisions for overfill protection, metering and flow control, fire protection and grounding. In addition, the storage tanks will have secondary containment with impervious surfaces with sufficient to store 1 ½ times the volume of the tank or the largest tank if several are located within the same double containment. They will also have containment in areas of potential spills and leaks such as in truck tanker loading areas. The storage tanks and components will undergo periodic maintenance and replacement of equipment. All loading and unloading activities will be conducted by qualified personnel in accordance with pre-established safety procedures. Loading and unloading activities including marine vessels and terminals will have spill prevention procedures in accordance with international standards. Emergency Response and Preparedness Plan: The BDCs will have fire and oil spill contingency and response plans include the potential accident scenarios, the magnitude of the impacts, and necessary resources and equipment. The BDCs will have a fully prepared response team available at all times. Depending on the location of the BDCs, they may establish mutual aid response when the neighbors are also required to conduct emergency response for their own operations. When appropriate, the spill prevention and response plans will be implemented in coordination with the relevant government authorities (i.e., navy, port authority, EPA, etc.) PS4: Community Health, Safety and Security Neighboring Communities: The current BDCs do not have communities nearby. The main risks are related to transportation to and from the BDCs. However, transportation is not the responsibility of the BDCs. Security Personnel Requirements: The BDCs hire private security personnel and as appropriate they will train them to ensure that any possible events with communities are for strictly defensive purposes. In cases where the BDCs receive protection from the police or military forces they will implement security policies and procedures in line with the Voluntary Principles commensurate to the security personnel. PS5: Involuntary Resettlement The BDCs acquire the land in willing buyer-willing seller basis. The local authorities ensure that the BDCs are located in authorized industrial areas. Thus it is not anticipated that either involuntary resettlement or economic displacement will occur from the installation of BDCs. However, if in any case, any of the aspects were to occur, the BDC will be required to prepare a resettlement action plan. PS6: Biodiversity Conservation & Sustainable Natural Resource Management The BDCs will not be authorized to be built in protective or preserved areas. Thus PS6 will not be triggered at the present time. PS7: Indigenous Peoples The BDCs will not be authorized to be built in indigenous communities’ areas or in their vicinity. Thus PS7 will not be triggered at the present time. PS8: Cultural Property The BDCs will not be authorized to be built studies in areas of significant cultural value or cultural heritage. Thus PS8 will not be triggered at the present time.

BDCs would need to engage with directly affected communities if their operations were to near communities. If that were the case, the ESIA process would require the BDC to engage with the communities.

Standard Chartered Bank Ghana Limited Head Office Branch High Street Building Accra