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 PS5: Land Acquisition and Involuntary Resettlement is not applicable as the land was acquired on a willing buyer-seller basis from the Government and owner of the service station, and no involuntary physical or economic displacement occurred. Given that the land was previously developed and located within the centre of Kigali, PS6: Biodiversity and Natural Resource Management is not applicable and this applies similarly to PS7: Indigenous Peoples. Finally, the EIA did not identify issues associated with cultural heritage and PS 8: Cultural Heritage is therefore not applicable.

This is a Category B project according to IFC’s Environmental and Social Review Procedure because the limited number of specific impacts that may occur are generally site specific, and those impacts can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria. The Complex is located within Kigali’s business district on a site that was previously developed for use as a post office and fuel service station. MSC Limited has commissioned a local architectural and project management company to design the facility to recognized international standards. CCECC is constructing the Complex with oversight from MSC Limited and GMK to ensure project implementation is in accordance with the specified design criteria. Although it has not been defined how the Complex will be managed, it is likely that a professional property management company will be commissioned to do so. Specific actions have been defined in the project Environmental and Social Action Plan (ESAP) to enhance environmental and social performance to which the project sponsor, and his appointed agents, will be required to comply.

The company has presented plans to address the potential environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with policies and standards internal to MSC Limited, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety (EHS) Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the ESAP which is disclosed with this document. Social and Environmental Assessment and Management Systems In terms of the Rwandan Environmental Assessment Regulations, the development required an environmental impact assessment (EIA). MSC Limited commissioned a local environmental consultancy to undertake the EIA, which was subsequently approved by the Rwanda Development Board (RDB) with a Certificate of Approval being issued for the project on 6 January 2010. The EIA includes an Environmental Management Plan (EMP) that outlines the key actions required to manage and mitigate potential impacts to acceptable levels. In addition to the requirement to implement the EMP, the Certificate of Approval defines a number of conditions that apply in addition to those defined in the EMP. As a condition of its disbursement IFC will require MSC Limited to commission an audit by an independent social and environmental consultant to confirm compliance with the EMP and conditions outlined in the EIA Certificate of Approval. In addition, a monitoring plan will be required to ensure ongoing compliance with the EMP and Certificate of Approval. MSC Limited obtained a building permit from the Kigali Local Authority (KLA) on 24 March 2010. All relevant departments within the KLA (planning, engineering, traffic, fire protection), also reviewed the building permit application and design drawings to ensure compliance with local regulations such as that related to by-laws (setbacks, ground coverage, plot ratio etc.), and the Kigali City Master Plan. During the construction phase GMK undertakes quality control on behalf of MSC Limited, utilizing experienced personnel including architects and civil, structural and mechanical engineers. Prior to the operational phase, GMK will develop a management plan to address specific environmental and social issues. This would include defining roles and responsibilities for implementation, procedures for solid and liquid waste management, monitoring of potable and waste water quality, and compliance with life and fire safety management requirements. In addition, ongoing training requirements will also be defined to ensure staffs are qualified to implement the management system and report on compliance thereto. Should management of the Complex be outsourced, or specific functions, as applicable MSC Limited will ensure there are contractual requirements in place to ensure implementation of the management and associated reporting. Aside from the reporting requirements as to be defined in the social and environmental management system defined above, as per the Certificate of Approval, and once operational, the complex is required to submit a Quarterly Effluent Quality Monitoring Report to the Compliance Monitoring Department of the RDB and the Rwanda Environmental Management Agency (REMA). Labor and Working Conditions The labor force required for the construction of this project will be in excess of 1000 workers at its peak. All unskilled workers will be hired locally and supervised by Chinese foremen. Each foreman will supervise approximately 20 workers, requiring a total of approximately 50 Chinese workers. All employment is in accordance with national legislation as contractually defined between MSC Limited and CCECC, and this similarly is to be applied to sub-contractors. The minimum age for employment in Rwanda is 18 years and CCECC is required to review personal records to ensure workers are above the legal age. By law, all contracted employees have a right to join a workers union. All workers are, whether casual or contracted, protected by the labor laws of Rwanda. Rwanda is a member of the International Labor Organization (ILO) and has ratified 46 Conventions, including those related to minimum wage, weekly rest, child labor and discrimination. The Rwanda Ministry of Justice has established a National Labor Council to oversee and ensure application of the relevant labor and social security related laws and regulations. While MSC Limited is ultimately responsible for occupational health and safety (OHS) on-site, their contract with CCECC requires the construction company to comply with national requirements and appoint appropriately qualified and experienced OHS management personnel. At the time of the appraisal the CCECC OHS manager was not available, however CCECC management indicated all construction workers are provided with personal protective equipment; this was however not evident during the site visit. All workers are subject to verbal induction training, though this is not formalized and there is no regular ongoing training or formalized incident reporting. As defined in the ESAP, IFC will require an audit of the construction site, and implementation of recommended corrective actions, to ensure OHS and labor management practices are in compliance with the Performance Standard PS2: Labor and Working Conditions. Mr. Makuza’s businesses, including MSC Limited, employ approximately 59 permanent staff of which 10% are women. MSC Limited has indicated that it intends to increase this to 30% to ensure alignment with the Government’s policy of promoting gender balance within places of work. Either MSC Limited directly, or a specialist property management company, will be responsible for operating the Complex and thus employment of staff. Prior to the operational phase, MSC Limited is required to develop a Human Resources Policy and associated documentation and this submit this to IFC to confirm compliance both with national labor legislation and this Performance Standard. In addition, MSC Limited or their appointed agent will include a condition in contracts with tenants renting office or retail space requiring compliance with national labor legislation, and IFC’s PS2: Labor and Working Conditions. While the typical OHS risks during the operational phase will be relatively low, MSC Limited or their appointed property management agent will be required to develop and implement an OHS system and associated procedures for this phase. Prior to the operational phase, MSC Limited are required to submit their OHS plan and associated documentation to IFC to confirm compliance both with national legislation, and the following IFC Performance Standard PS2: Labor and Working Conditions. Pollution Prevention and Abatement The EIA includes a brief Environmental Management Plan that will be updated to include all of RDB and IFC’s conditions for the construction and operational phase of the Complex. Ablution facilities at the construction site are connected to a conservancy tank which is regularly collected and treated by a private waste management contractor. Solid waste is collected in dedicated containers and disposed of at the municipal waste disposal site. Given the site was previously developed and located within central Kigali, road curbsides and storm water drainage are already in place. Dust control, a concern raised by stakeholders during the EIA, is undertaken by ongoing dampening of areas where dust could be generated. As the vertical construction of the building progresses, the sides of the building will be covered with shade cloth to minimize the off-site impacts on air quality. The construction site has a public complaints/suggestion box at the entrance, although no complaints have been received to date. Once operational, the Complex will use approximately 8000m3 of water per month to be supplied by the Rwanda Water and Sanitation Corporation (RWASCO). This water is treated to the World Health Organization Standards (WHO) for potable water and thus no further treatment of the potable waste is proposed. Nonetheless, the water will be monitored prior to use in the Complex in accordance with the requirements of the General EHS Guidelines. The basement of the Complex been designed to include a solid waste recycling area where recyclable and food waste will be separated from general waste, which will be disposed of at a registered waste disposal site. Food waste will be made available for use, either as livestock feed or for the production of compost, depending on demand. Recyclable waste will be made available to recycling contractors depending on demand for these materials. The Complex will use an estimated 420,000 kWh of electricity per month, to be supplied by the Rwanda Electricity Corporation (RECO). This equates to approximately 174 kWh/m², which compares favorably with global benchmarks for office and retail facilities, which range between 200 and 300 kWh/m². Two backup generators will be installed at the Complex, one with a capacity of 1000 kVA and the other with a capacity of 500 kVA. Interruptions in electricity supply are limited in Kigali, thus fuel storage on-site will be restricted to the generators built in fuel storage tanks. Various energy efficiency measures have been incorporated into the Complex’s design. The eastern and western facades of the building will be shaded using moving aluminum fins to reduce internal temperatures. Extractor fans, powered by energy produced from photo voltaic cells installed in the atrium roof, will extract rising warm air from inside the building and the natural circulation effect will result in cooler air flowing into the building. Reflective glass on the northern and southern facades of the building will also help reduce temperatures inside the building by reflecting direct sunlight. As a result of these design features, no air conditioning will be required. It is estimated that the Complex will generate around 3,200 tonnes CO2 equivalent per annum. The Complex will generate approximately 11,000 m3 of sewerage and wastewater per annum, primarily from ablution and kitchen facilities. All wastewater, including sewerage, will be treated by an on-site wastewater treatment system. The system to be installed is the JETINC 3000 Series which operates using an aerobic digestion process. The treatment process has three main stages; i) aeration; ii) clarification, and iii) chlorination, to ensure that the IFC’s EHS guideline standards for wastewater discharge quality are achieved prior to release from the treatment system. The kitchens located in the food court on the ground floor and a rooftop restaurant will be fitted with grease traps to lessen the grease load on the treatment system. The Complex has been designed such that treated water discharged from the plant will be used for flushing toilets and washing paved areas, with the excess treated water being released via a soak pit. As defined in the ESAP, a waste water monitoring plan will be compiled for the development, in accordance with the General EHS Guidelines. Community Health, Safety and Security The Complex has been designed in accordance with the recently promulgated Rwanda Building Codes and Standards Regulations, which are based on the British Standards. The seismic risk zoning of the site’s location was factored into the design of the building, in accordance with local codes and regulations. The complex has been designed to safely withstand an earthquake of up to 8 on the Richter scale, with the highest seismic event recorded in Kigali to date measuring 5.9 on the Richter scale. In terms of the American Society of Civil Engineers safety design code ASCE 41, the complex has been designed to a the “Immediate Occupancy” standard. To ensure the Complex’s design complies with the national requirements for life, fire and safety, and the General EHS Guidelines, an independent review of these designs will be undertaken. Thereafter and if required, the design will be amended accordingly. In addition, once construction of the Complex is complete, and prior to the public opening, MSC Limited will commission a further independent audit to confirm that the Complex has been constructed in accordance with the original life, fire and safety designs, including any proposed amendments as defined in the initial audit. In addition, this will also include a review of the site specific emergency response plan to ensure it is responsive to the Complex’s life, fire and safety management system. For the duration of the construction phase a solid sheet metal barrier wall has been erected around the site perimeter to ensure that access to the site is restricted to the main entrance gate only. No armed security is currently being utilized at the construction site. Although security plans have not yet been developed by MSC Limited for the operational phase of the Complex, all security arrangements will be made in accordance with IFC’s Performance Standard PS4: Community Health, Safety & Security.

An EIA was undertaken for the project which involved consultation with various interested and affected parties including local and national authorities, and representatives from adjacent properties. This consultation took the form of one-on-one meetings with stakeholders and the EIA reports were also made available for review. A public complaints box and large sign board have been placed at the entrance to the site with all relevant contact numbers clearly visible.

This ESRS document and companion ESAP, the EIA documentation and Environmental Permit will be available at GMK’s and RDB’s offices. Contact details are provided below: GMK Architects Mr. Kamiya, HJ, Vianney Managing Director Address: 1719 Boulevard Umuganda, Kigali Mobile: +250 - (0) 788300804 Email: gmkkgI1@gmail.com Clare Akamanzi Rwanda Development Board Address: Cnr Boulevard Umuganda & Nyarutarama, Kigali Email: info@rdb.rw Phone: +250 252573396 / +250 252502350