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: While all Performance Standards are applicable to this investment, IFC’s E&S 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; - PS5: Land Acquisition and Involuntary Resettlement; and - PS6: Biodiversity Conservation and Sustainable Natural Resource ManagementThere are no groups in the Project area that would be considered Indigenous People and as such PS7-Indigenous Peoples does not apply. No cultural heritage sites have been identified in the area as such PS8-Cultural Heritage does not apply, however a chance find procedure will be in place during construction period.

The key E&S issues in this Project are life and fire safety; occupational health and safety during construction and operation; solid and liquid waste management; traffic safety; and community engagement. As such the project is a category B project as the aforementioned impacts are site specific, limited in scope and can be readily managed by implementing the proposed environmental and social management plan. Furthermore the proposed project will be developed in partnership with Vitafoam Nigeria PLC, the parent company ( NIS ISO 9001: 2000 certified in 2004) has committed to use best industry practices in the development of this Project.

The Company has presented adequate information and plans to address the E&S impacts to ensure that the Project complies or will comply with national laws and IFC’s Performance Standards on Social and Environmental Sustainability upon implementation of the specific agreed mitigation measures. The information regarding how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow, and in the Environmental and Social Action Plan which is disclosed with this review summary. PS1: SOCIAL AND ENVIRONMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS The Environmental Protection Act in Sierra Leone requires that an Environmental Impact Assessment (EIA) is undertaken for the type of activity of the proposed Project. The EIA contains sections on social, economic and cultural effects that the Project may have on the society; and community and local authority consultation. In compliance with EIA guidelines, the Project EIA was publicly disclosed. On approval of the EIA, The Sierra Leone Environmental Protection Agency (SLEPA) issues an EIA license. The Company will hire a professional to manage Health, Safety, Environment and Social (HSES) matters. This HSES manager will be trained by the Vitafoam Nigeria PLC EHS manager and will replicate the Environmental Health and Safety procedures and programs already established in the Nigerian operation and incorporating IFC’s EHS guidelines as relevant. The HSES management programs will be developed and implemented during both construction and operation in order to ensure that the Project is undertaken in a manner consistent with the requirements of host country laws, Vitafoam Nigeria PLC, and IFC’s Performance Standards. The key E&S issues to be addressed by the management programs include: (i) life and fire safety; (ii) occupational health and safety practices and training; (iii) labor and working conditions; (iv) emergency preparedness and response; (v) first aid;(vi) chemical storage and handling; (vii) traffic safety; (viii) solid and liquid waste management; (ix) equipment maintenance (such as generators, boilers, air filters);( x) community engagement; (xi) environmental and social performance monitoring. The Nigerian operation has developed a user friendly HSE handbook which should also be replicated and provided to all employees in the Company. As part of this investment the Company will be required to complete the Annual Monitoring Report (AMR) developed by IFC for reporting HSES performances. This AMR could be used as a basis of sustainability reporting to senior management. PS2: LABOUR AND WORKING CONDITIONS The Company will develop a Human Resources (HR) policy, practices and procedures operating handbook similar to those of Vitafoam Nigeria PLC and in line with the requirements of this Performance Standard as well as in compliance with the national labor and employment laws. The legal employment age in Sierra Leone is 18 years old. Prior to employment, potential candidate must provide an identification card or other proof of age. Sierra Leone has a National Social Security and Insurance Trust (NASSIT) that requires contributions from employees and employers. The Company plans to hire approximately 70 employees. The Company will prioritize local employment and require that the construction contractor does the same. Each employee will be provided with an employment contract which will contain terms and conditions of their employment (such as duration of the contract; job title; terms of reference; wages and benefits; hours of work; overtime arrangements and compensation; and probation period). The Employee Handbook similar to that of the Nigerian operation will outline the employee’s rights under national labor and employment law including the right to freedom of association, compensation system including overtime, working conditions and terms of employment, holidays, sick leave, maternity leave and other type of leave, insurance benefit, access to training, promotion, loans, performance evaluation system, performance awards, termination of employment, retirement, grievance mechanism, and discipline, furthermore the Company will practice non discrimination with regards to the aforementioned matters. The Company will provide its workers with a safe work environment. As the raw materials used in the production process are flammables, implementation of adequate life and fire safety measures are critical. The Company, similarly to the practice of its parent company, will have smoke detectors, a sprinkler system, water and CO2 based extinguishers, and water hoses in compliance with life and safety code to respond to fire emergency whilst fire fighters arrive at the scene. In addition all emergency exits will be clearly marked and free of obstructions. In conformity with the parent company’s practices, the Company will provide its workers with adequate PPEs such as safety boots, gas masks, hand gloves, goggles, ear plugs, and uniforms. Wash stations will be available to rinse off chemical contamination. Several first aid kits will be available around the production facility to response to minor injuries. BREAT CONSTRUCTION (BC) has been retained as the construction contractor responsible for plumbing, electrical, and steel works. As the site construction has not yet begun, visits to one of BC’s completed work and one construction site were undertaken to observe quality of work and Occupational Health and Safety (OHS) practices. The main observation from the construction site visit was that workers were not wearing PPE. BC does not have a written health and safety management system. It relies on hiring experienced staff and the supervision of the foreman at each site to implement OHS practices. Personal Protective Equipments (PPE) are not systematically provided to workers unless required by a client. The Company will require that BC provides its workers at the Project site with PPE such as boots, hard hats, masks, goggles, gloves, hi visibility vests, ear plugs as relevant to the activity undertaken. Furthermore, BC will develop an EHS management plan for construction activities at the Project site prior to commencement of construction works. BREAT CONSTRUCTION has approximately 350 employees; wages are negotiated by the union and a handbook outlining benefits, wages, allowances (such as transport), medical coverage is available to staff. BC provides its employees with private workers’ compensation insurance. Workers can lodge grievances through the union or to Human Resources. PS3 POLLUTION PREVENTION AND ABATEMENT Raw materials used in the production process include the following active ingredients polyol, isocyanate, toluene di isocyanate, and methylene chloride. These chemicals are sourced by British Vita PLC which provides technical partnership to Vitafoam Nigeria PLC. The chemicals will be stored within a secondary containment system totaling no less than 110% of the storage tanks full capacity. The chemicals will be pumped into the production process through hoses to minimize spillage from handling of the products. The Company will have a procedure to ensure the safety of the delivery of these chemicals to the Project site, and that drivers are trained with regards to emergency response in case of spillage during transportation. The Company will secure a vendor to dispose off or recycle the empty tanks. The production facility design consists of 1m20 high walls on each side with a connected roof leaving the side of the building open. Extraction hoods with extraction fans will be installed as necessary to ensure proper ventilation. The cutting and sewing areas will also be properly ventilated and equipped with industrial vacuum cleaner to minimize respirable dust. The Company plans to source its electricity needs from the national grid and diesel generators as backup; discussions with two other manufacturing companies indicated that the majority of electricity need for businesses is provided by generators. These generators will be subject to a regular maintenance schedule to limit air emissions. The above ground diesel tanks for the generators, as well as the raw material tanks (chemical) will each have a secondary containment system totaling no less than 110% of the storage tanks full capacity. The Water is supplied by gravity dam below the hills and is provided by Sierra Leone Water Company - SALWACO. The Company plans to have a borehole as a backup. Discussion with the community indicated that water shortage is not an issue in the area. A full water tank will be available in sufficient quantity to service the sprinkler system. Sewage pipes will be connected from the site to the municipal sewage collection system. The Company will install oil and water separators to prevent off site escape of accidental spills. Waste from foam mattress is recycled in the production of other types of mattress. Solid waste other than foam will be stored in a designated area and collected by the municipal waste management system. Pesticide will be used in limited quantities, and the Company will ensure that no class 1A or 1B pesticides are used in their operation. As part of its annual reporting to IFC the Company will report on its carbon footprint. PS4 COMMUNITY HEALTH SAFETY AND SECURITY The Project is located in a mixed residential, commercial and agricultural area. Entry to the site is from the main Freetown-Waterloo Highway which is tarmac road up to 450 m to the site theater dirt roads begin. Once the factory becomes fully operational there will be a significant amount of truck movement which is likely to increase as production increases. In order to reduce community exposure to accidents and fugitive dust on the 450m dirt road section, speed bumps put in place, low speed limit implemented, and proper watering of the dirt road undertaken. With regards to increase noise level from traffic, this should be on a limited basis as the plant will operate Mondays to Saturdays from 8am to 7pm. As production increases, the Company should review its logistics management plan to safely manage the increased truck traffic to its facility. The Company will develop an emergency preparedness and response system as part of its ESMS under PS1. Fire drills will be undertaken on a regular basis and at least once involving the local fire department, and the community in the immediate vicinity of the site. The Company will use the services of a credible third private security force to guard its premises and will incorporate in its contract the requirement of IFC PS4. Furthermore, the Company will include in its ESMS a mechanism for reporting credible allegations of unlawful or abusive acts to police authorities. LAND ACQUISITION AND INVOLUNTARY RESETTLEMENT The land is 5.1 acres and was acquired through the Ministry of Land which granted the Company a 50 year lease in December 2008. The land is a government owned land; there are no community lands in this part of Sierra Leone (Western Area). Part of the land was used by a few gardeners who have been economically displaced prior to the Company fencing the property. There was no official census of the number of gardeners but it is estimated at approximately 10. The gardeners were informed of the Project and were given a planting season to reap their vegetables. Since the Project site has been fenced these gardeners have relocated their activities to nearby fields. Despite the fact that the land was not a community land, the Company still engaged with community leaders and provided monetary compensation to the affected gardeners through community leaders; this is further discussed under the community engagement section below. BIODIVERSITY CONSERVATION AND SUSTAINABLE NATURAL RESOURCES MANAGEMENT The Project site is located in the bottom portion of the hills in an area of secondary vegetation types formed after clearing of the forest, normally wooded savanna in nature. The Project site has been used for agricultural purposes for many years, first by Chinese farmers who left in the early 1970s, and then by the local community for small scale gardening of vegetables such as cabbage, potatoes and other root vegetables. The Company plans to sink a borehole under its premises to complement its water needs. Field observations during ESIA indicate that the groundwater is not expected to be significant and it is anticipated to generally be restricted to fractures within the granite basement. As recommended in the ESIA, the Project should include a landscape plan used primarily as a wind barrier for the prevention of odor emissions. The grown tree plants surrounding the site should be preserved to the extent possible. The ESIA indicates that the once virgin forest vegetation that covered the hills within the project area has been vastly depleted and the forest resources used mostly for fuel wood.

In compliance with the EIA guidelines, the Company has consulted with the local community through the public disclosure of the EIA. A notice was posted at the Hasting local district offices informing the public of the EIA study, the Project, and soliciting comments. A public hearing attended by local Council officials, youth leaders and the community was held with the presence of Vitafoam SL representatives, and the EIA consultant who responded to questions from the public. The meeting was apparently attending by approximately 200 people. As economic displacement of a few the gardeners on the Project site took place, the Company provided a token compensation to the affected people through the community leaders despite the fact that the gardeners were giving sufficient time to relocate their activities. A subsequent meeting including the Ministry of Land as well as the Company representatives took place following complaints from women in the community that they had not benefited from the Project. The Company provided a grant to five women for them to start a catering business to service the workers at the plant. The fence around the Project site was built using mainly workers from the local community. The hiring of local community workers for building the fence as well as public awareness of the Project was confirmed during interviews with local community members. Unemployment amongst the youth is high and the Project is seen as a welcomed opportunity. The Company is committed to community engagement and development, and it is thinking through potential community development initiative.

Environmental and Social Impact Assessment (ESIA) for the proposed Hasting plant dated April 2009 undertaken by Dr. Ronnie Frazer-Williams Local Disclosure of Documents 1) Vitafoam SL, Hasting Plant Egba Town Hastings Village 2) Dr. Ronnie Frazer-Williams Environmental Consultant +232 78 524 381/+232 33 27 68 92 wfdar@yahoo.com