While all Performance Standards are applicable to this corporate 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: PS 1: Social and Environmental Assessment and Management System; PS 2: Labor and Working Conditions; PS 3: Pollution Prevention and Abatement; PS 5: Land Acquisition and Involuntary Resettlement; PS 6: Biodiversity Conservation and Sustainable Natural Resource Management. PS 4 Community Health, Safety and Security, PS 7 Indigenous Peoples, and PS 8 Cultural Heritage did not apply to this investment. ECOM physical assets and operations are in open farmer fields scattered in rural areas, distant from communities, and there are no indigenous peoples and/or cultural heritage in the area of ECOM operations. No community consultation as such merits in this project. In the event that these latter Performance Standards become applicable, ECOM will provide feedback to IFC. Screening of these issues and their assessment will be done through ECOM’s social and environmental management system (SEMS).

E & S Categorization Rationale: While the existing investments of IFC in Ecom for the coffee sector have limited E&S impacts, IFC is treating this corporate investment as a Category A project, according to its Environmental and Social Review Procedures. The rational underlying this categorization is based on the well documented significant adverse social or environmental issues related to cocoa in West Africa and cotton in Central Asia, as described in PS2 (child labor) and PS 6 (deforestation), and the associated E&S residual risks given the supply chain dynamics. In such category A investment, IFC will continue to monitor the implementation of Ecom’s procurement policy, and how Ecom is making use of its social and environmental management system to ensure the inclusion of E&S issues into its supply chain management system, and that ultimately guarantee that the company’s operations are consistent with IFC Performance Standards and World Bank Group Environmental, Health and Safety General Guidelines (WBG General EHS Guidelines) to avoid and mitigate impacts, and monitor progress in establishing better E&S practices across its supply chain. Despite this provision, it is likely that Ecom's ability to manage their supply chain in some geographical areas will be challenging, and that there will be instances of child labor at suppliers fields that will not be consistent with PS2.

IFC''s review of this corporate investment highlighted environmental and social issues for Ecom’s own operations, as well as those associated to Ecom’s supply chain. IFC analysis of E&S impacts of Ecom operations entailed the assessment of environmental and social risks and impacts and the implementation of measures to meet the requirements of the Performance Standards and WBG General EHS Guidelines. The E&S review of Ecom’s supply chain involved the analysis of impacts associated to PS2 and PS6, and assessed compliance of Ecom’s management system to meet the requirements of PS1, to identify mitigation measures and actions necessary for the project to manage impacts on an ongoing basis. Issues reviewed included occupational health and safety, food safety, and social performance in its operations, worldwide supply chain trading, production, and processing of the coffee, cocoa, cotton and other commodities managed by Ecom; labor practices, working conditions and terms of employment for its employees and contractors; integrated pest and disease management by farmers; effluent management at Ecom controlled facilities; land acquisition for the construction of the cotton gin in Tajikistan; and biodiversity conservation near farming areas.

Ecom’s business plan is providing a sound technical approach to advancing sustainability standards in agro-commodities. After a careful review of the Company’s management of sustainability in its supply chain, and given the significant existing environmental and social issues in the cocoa and cotton sectors, Ecom has demonstrated its commitment to increasing sustainability in cocoa and cotton through pro-actively promoting sustainability initiatives in West Africa and Central Asia. Specifically, Ecom has adopted third party certification in the coffee and cocoa supply chains, as the most effective approach to promote and secure sustainable environmental and social farming practices while ensuring improvement of livelihoods of farmers within a business development approach. Where certification standards do not yet exist, as is the case of cotton, Ecom is part of the multi-stakeholder strategy to create them (e.g. The Better Cotton Initiative - BCI). Currently, farmers in Nicaragua, Honduras, El Salvador, Costa Rica, Mexico, Colombia, Peru, Brazil, Indonesia, Vietnam, PNG, Uganda, Kenya, Tanzania, Ivory Coast, Nigeria, and Tajikistan, are being trained in best farming practices to meet the standards of independent certification bodies.

Ecom is already implementing E&S mitigation measures to address E&S risks and impacts. To ensure that Ecom will further comply with national environmental and social laws and regulations, the IFC Performance Standards and WBG General EHS Guidelines, the Company will implement the specific agreed measures summarized below and in the attached Environmental and Social Action Plan (ESAP).


PS1: Social and Environmental Assessment and Management Systems

Aside from two previous IFC’s investments in 2006 and 2008, IFC provided, in 2010, a corporate loan to finance advances to Ecom coffee suppliers, as long term loans for farms improvement, replanting of coffee trees, investments needed to attain farm certification and productivity improvements in Nicaragua, Guatemala, Honduras and Costa Rica. In the past months, Ecom has successfully addressed its 2010 ESAP and has presented to IFC the implementation plan for the corporate and supply chain’s SEMS. Ecom confirmed the appointment of a corporate E&S managing director, and a team of 3 commodity sustainability program executives (coffee, cocoa, and cotton). Additionally, Ecom had already appointed a Corporate Sustainability Director leading a bottom up sustainability strategy driven by origins and client demand that has placed the Company’s corporate reputation toward sustainability. A supply chain policy has been developed promoting sustainable purchasing practices in accordance with IFC’s Performance Standard requirements; supplier categories were defined based on a E&S risk rating which feeds into Ecom’s supplier database, a pilot was implemented to assess the level of traceability to farmers (traceability per commodity and origin) in 6 countries, potential social and environmental risks involved in their operations by commodity (e.g. child or forced labour, deforestation and/or loss of biodiversity) and the monitoring of E&S risks in each supply chain. In addition to training farmers in internationally recognized certification standards, the Company plans to train farmers and its own staff at the corporate level on sustainability issues related to IFC Performance Standard requirements. Occupational health and safety issues were audited for the Beneficio Atlantico coffee facility in Nicaragua, and the Company is in the process to develop an implementation plan and schedule for the proposed mitigation measures to assure continued compliance with WBG General EHS Guidelines. A corporate grievance mechanism has also been made operational. As part of compliance with the ESAP, Ecom also provided to IFC a statement abiding to the Protocol of Montreal on the use of methyl bromide.

Social and Environmental Management System (SEMS)
Ecom''s operations are largely decentralized with strong corporate oversight of commercial transactions. The Company places environmental and social issues (E&S) at the forefront of its global business strategy and operations using the concept that addressing sustainability issues will further develop its comparative advantage and improve its financial performance. In accordance with the attached ESAP, the Company will continue to implement the SEMS in its supply chain operations, covering all relevant aspects of IFC Performance Standards, WBG EHS guidelines, and agro-commodity voluntary standards.

In addition to the reporting format of each of the certification schemes, Ecom has its internal reporting format for compliance self-assessment of its operations outside of the United States, Europe, and Australia. Key information is provided on each facility (e.g. E&S performance indicators), together with identified E&S risks and impacts addressed and recommended mitigation measures, wherever technically and commercially feasible. During 2010, the scope of the self-assessment format was updated to capture E&S information from the WBG EHS guidelines and the IFC Annual Monitoring Report (AMR). Ecom will conduct a series of internal audits on the effectiveness of the self-assessments to increase social and environmental knowledge of its own staff. For its supply chain, it will categorize suppliers according to their risk, level of certification and traceability, and examine the changes over time. The Company is implementing an approach that provides insight over time into the “non-certified purchasing” or spot purchasing, where some informal information is available.

Training
Being an origin integrated company, Ecom will implement a training program for their field staff to build in-house capacity to further train farmers to improve their productivity and in the standards required by internationally recognized certification schemes. This in turn will increase the volume of third party certified produce traded. The program, with participation of 180 agronomists, has sustainably increased volumes of certified coffee in the past years and, in 2010, has been extrapolating the methodology and training modules to cocoa and cotton. A training program to inform and engage staff on the SEMS and IFC performance Standards requirements is being developed by ECOM. The training activities include sessions for farmers with whom the Company has purchase contracts to inform them that Ecom expects them to comply with country legislation related to social and environmental issues, and relevant IFC Performance Standard requirements. Ecom corporate staff will be also trained to carry out E&S reviews and determine nature, scale, and importance of environmental and social issues in any given location.

Monitoring and Reporting
To proactively address potential exposure to E&S risks associated with suppliers and own operations in the short and long term, the Company has implemented, as part of the SEMS, a process for reporting and monitoring environmental and social information to senior management. During 2010, Ecom developed and implemented an “internal origin survey” to inform senior management of potential levels of supply of certified product that could be achieved at each origin, associated E&S risks, and most effective mitigation strategies. The survey is done periodically to keep track of emerging E&S issues (also residual risk), and associated potential business risks, together with determining the needs for emphasizing training of local staff on management on the emerging E&S issues. Country surveys will provide understanding at the corporate level senior management of E&S issues. Additionally, frequent management visits to all origins allow for review and discussion of local data, assess the local trade dynamics, and assess the status of certification supply and demand.

Supply Chain
Ecom’s objective is to simplify the supply chain, reduce the number of intermediaries, work directly with producers, operate at origin and destination, and increase traceability and third party certification of products. Given the growing markets for certified sustainable produced commodities, Ecom focuses on certification in origins (such as AAA (Nespresso), Cafe Practices (Starbucks), Fair Trade, Organic, Rainforest Alliance, and UTZ Certified), and participates in strategic discussions and multi-stakeholders’s industry platforms that promote market-driven sustainability standards, including traceability and certification. Building direct relationships with suppliers in countries of origination allows Ecom to support them to improve quality and quantity of produced commodity, introduce and scale up sustainable farming practices, and have a positive effect on the livelihoods of farmers. Ecom views certification as a first step for organizing farmers and providing basic training, which serves as a stepping stone towards improving quality, quantity, and the ability to sell into higher value markets.

As part of its SEMS, the Company is implementing a policy to ensure sustainable purchasing procedures and to increase certified commodities. As part of the policy, Ecom is updating its supplier database to collect information on farmer suppliers in each of the country/locations where Ecom operates. The supplier’s database includes information on compliance with national environmental legislation (for example illegal land clearing). It will help identify and classify suppliers according to risk to: a) set future targets for traceability and certified product volumes in the supply chain; b) gradually increase the number of low risk suppliers; and c) phase out suppliers that are high risk. The supplier’s database is a tool to monitor the dynamics of certified suppliers, and is being expanded to incorporate broader country supply chain data and allow aggregation. On completion of data collection and analysis, ECOM will adopt changes in the Company''s SEMS for the management of suppliers to reduce E&S risks in the supply chain.

IFC will continuously evaluate Ecom’s purchase policy and how this policy drives inclusion of environmental and social issues into their supply chain risk management system procedures, how Ecom identifies where their supplies are originating, and how ECOM assesses if these supply chains are using child or forced labor and/or contributing to significant conversion of natural or critical habitats leading to biodiversity loss. Origin managers are focused on the physical commodity and on in-country origination. All country managers are aware of certification requirements, and are sensitive to any supply chain issues that could cause reputational concerns for the Company and its manufacturer clients.

Coffee
Ecom is well experienced in supporting farmers to produce certified coffee. The geographic range of projects and the expansion of certified products into mainstream coffee retailing is the largest evidence of the work done by ECOM to improve producer farming practices. Overall, Ecom claims trading about 20% of all certified coffee sold globally. Ecom has developed a partnership with the Centre de Coopération Internationale en Recherche Agronomique pour le Développement (CIRAD) to produce hybrid tree seedlings in Mexico and Nicaragua. Ecom has conducted a study with the Centro Internacional de Agricultura Tropical (CIAT) to address the effect of climate change on coffee production, and identified scenarios and coffee suitability for Kenya coffee growing regions. Ecom is conducting research with GIZ in Kenya and Rainforest Alliance in Central America to assess best carbon sequestration and climate change adaptation strategies in coffee.


Cocoa
Ecom has gained considerable experience in traceability and quality improvement of cocoa in Ivory Coast. Child labour and deforestation or land conversion are key social and environmental issues for cocoa production in West Africa, which are widely reported in public documents from UN organizations, private sector, and NGO’s (the International Cocoa Initiative (ICI) oversees and sustains efforts to eliminate child labor in the production of cocoa). To address these E&S issues, Ecom works with farmers in Ivory Coast and Nigeria on certification and traceability. Ecom’s certification work with farmers in Ivory Coast has experienced a six month delay due to the social unrest that took place since November 2010. Cocoa traded in Ivory Coast, Nigeria, and Cameroun was through Ecom’s own procurement sources, and Ghana from Cocobod. Major cocoa buyers and the worldwide cocoa industry have increased their interest to develop and purchase certified cocoa products from West Africa in line with internationally accepted labor and environmental standards. MARS has publicly committed to certify its entire cocoa supply by 2020. IFC’s E&S sector review mission to West Africa in November has updated its knowledge of third party certification, traceability to origins of cocoa in West Africa, and the issues associated with reducing players in the supply chain to be closer to the producer. Further expansion of cocoa certification is hindered by the dispersion of smallholder producers over large areas, small number of farmer association/cooperatives, limited monitoring at the smallholder level, and occasional social unrest that brings small trading intermediaries back into the field. Ghana’s cocoa trading is through state operated Cocobod, also in charge of sales of inputs to farmers, while trading of cocoa in Ivory Coast is done through a wide range of private traders.

As part of the ESAP, Ecom will continue to increase third party certification in cocoa throughout the life of the IFC investment, in collaboration with clients and other partners to ensure a sustainable supply, free from child labor, and not produced by deforesting natural or critical habitats. UTZ and Rainforest Alliance are key participating third party certification bodies. The strategy for producing certified cocoa, known as Akwacao in Ivory Coast, will include social and environmental issues, and other key actions (development of farmer associations trained and equipped with viable farm management and marketing practices, implementing sustainable field production practices, tree crop rehabilitation, with reliable traceability schemes to monitor labour and environmental issues and quality, with farm gate warehouses, links to local traders, etc.), supplemented by appropriate advisory services and partnerships with existing farmer organizations and other stakeholders. Ecom will present to IFC a mutually agreed multiyear high level plan, which will include operational targets, specific activities, key milestones and schedule, to increase the procurement of third party certified cocoa each year, at each origin where projects are planned. The plan will include details of the activities to increase productivity and promote compliance with PS2 and PS6. The plan will also indicate suitable partnerships with activities addressing productivity intensification and monitoring of child labour, and being implemented by other stakeholders (such as the World Cocoa Foundation, NGOs, foundations, cocoa industry players, government agencies, etc.) at countries of origins. A joint Ecom/IFC annual review will take place to assess Ecom’s yearly performance and realign plans for procurement of third party certified cocoa for the following year. The Company will report to IFC in the Annual Monitoring Report all activities performed to promote sourcing of certified cocoa.

Cotton
Ecom sources 80% of its cotton from countries with strong regulatory framework where no E&S issues are expected to arise, namely USA, Brazil, and Mexico. These provide the highest transparency in the supply chain and Ecom is fully knowledgeable of large producer’s practices. Although the majority of Ecom’s cotton purchases are from the USA and Latin America, Ecom purchases cotton from Central Asia, which is a region with known E&S issues.

The use of forced child labor is a systematic, ongoing, and in some cases state-supported practice in the cotton industry in Central Asia. Working conditions for children harvesting cotton fall below health and safety standards. IFC has looked into child labor issues in cotton in Central Asia, and the progress made by Ecom to introduce the sustainable framework of the “Better Cotton Initiative” (BCI). The following causes have been identified as contributing factors for forced child labour in cotton harvest: short harvesting season that creates labour bottlenecks at times; a sharp increase of seasonal or permanent migration to Russia and Kazakhstan inducing reliance on child labour; and a lack of mechanization. Progress to reduce child labour has been made in some regions of Central Asia. As long as Ecom is sourcing cotton from intermediaries in Central Asia, it is highly likely that the Company will not always comply with the supply chain provisions of PS2 related to child labour. Key mitigation elements will be the further introduction of BCI and the monitoring of E&S issues at the country level. Also, Ecom has initiated a dialogue with UNICEF. Ecom’s trading operations are promoting sourcing from a range of countries in Central Asia, like Tajikistan, and have gradually decreased their cotton supply from Uzbekistan. During 2010, Ecom purchased from Uzbekistan 1.3% of the Company’s global procurement. Uzbekistan is, to date, the only logistically and economically feasible route to transport cotton in Central Asia.

Certification standards are not yet available for cotton and Ecom is part of the multi-stakeholder strategy to promote the Better Cotton Initiative (BCI). Ecom joined BCI at its early stages and is represented on the Governing Council and its Executive Committee. The Company commenced discussions with major retailers on their supply chain traceability and sustainability of production requirements. BCI has started to establish a best practices framework for the cotton industry. Ecom has initiated a "BCI Fast Track Fund" (now at 1.5 million USD) with leading retailers, such as Ikea, Levi''s, H&M, M&S, and Adidas, and funders like Dutch Sustainable Trade Initiative, Rabobank Foundation, and ICCO. As a result, the Company is participating in the first pilot projects in India and Pakistan. Separately, Ecom has engaged with the European Bank for Reconstruction and Development (EBRD) and ICCO to establish a traceable cotton project in Tajikistan that will eventually become “Better Cotton”.

Ecom aims to support and promote BCI at the institutional level to become a viable and meaningful program. Further, the Company will support BCI field implementation, that is, purchase BCI cotton where possible and will work with BCI retailers on innovative commercial supply chain projects. The “Better Cotton” Ecom project in Yovon, Tajikistan evolved during 2010 with funding from EBRD. For further support to the BCI initiative, Ecom imported approximately 1,000 MT of fertilizer and procured seed and diesel which was made available for purchase by the participating farmers. The aim is to increase productivity and involve farmers on the use of BCI rules to achieve higher E&S standards in their cotton fields. BCI production principles promote the principle of Decent Work which embraces the relevant ILO conventions and enables farmers to address labor issues in the diversity of contexts in which cotton is grown, from family smallholdings to large-scale farms. Ecom plans to expand this business model to other regions and countries in Central Asia. Elements of BCI implementation in Tajikistan include the scheme for micro-leasing of machinery, a cotton seed project, input financing, collaborate with partners to fulfill BCI national platform requirements, and implement BCI at field level with farmers in the “catchment” area of Ecom’s own gin to be built during 2011.

The Company will present to IFC a mutually agreed multiyear plan in Tajikistan to implement a training program for farmers to increase productivity, promote compliance with PS2, advance BCI cotton, and increase the amount of cotton procured as BCI cotton each year and throughout the life of the IFC investment. The end-goal is to enable participating farmers to meet the BCI requirements. The plan will include a module to sensitize farmers to the labor issues associated with worst forms of child labor (ILO 182), minimum age (ILO 138) and forced labor (ILO 29). A joint Ecom/IFC annual review will take place to assess Ecom’s yearly performance and plans for promoting BCI cotton.

Ecom will report in the AMR activities performed to promote BCI cotton, including the number of farmers participating in training programs and the amount of cotton procured per origin and country during the reporting year, including the volumes of BCI cotton. Reporting requirements will include a report on procurement in Central Asia, and all activities performed by ECOM to promote BCI cotton during the reporting period, to gradually ensure compliance of PS 2 over time.


PS2: Human resources and working conditions

Human Resource (HR) Policy and Management:
Ecom has a total permanent labor force comprising roughly 3,000 direct employees, and some 2,200 additional employees sourced through contractors. Ecom is locally managed in each origin, and all human resources policies and procedures at the Ecom facilities worldwide are reported to adhere to national regulatory requirements. These are communicated to all employees at enrollment in the Company. The HR policy is included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. The hiring and selection procedures are strict and all relevant documentation is reviewed prior to hiring. Ecom promotes good labor relations through full respect for all labor issues, and adheres to the principals of non-discrimination and equal opportunity which is included in individual labor contracts. Freedom of association and rights of workers organizations are guaranteed by Ecom and national laws, and Ecom workers may join unions if they desire. In some origins such as in Mexico or The Netherlands, there are unions at Ecom’s companies. The minimum employment age at Ecom is 18 years. Benefits generally include medical insurance, pension, and leave. Ecom will ensure that contractors follow the provisions of IFC Performance Standard 2 and will monitor its compliance. The Company does not expect retrenchment of employees.

Protection of the Workforce
Child labor or forced labor is not employed directly at Ecom controlled operations. The Company relies on third party certification bodies for consistency with acceptable labor practices in the supply chain of the traded commodities.

Occupational Health & Safety (OHS)
ECOM will conduct a gap analysis of its OHS policies and procedures at all their facilities against applicable WBG EHS General Guidelines and present an Action Plan detailing activities and budget. ECOM will conduct implementation of corrective actions to address gaps identified in the review.

Grievance Mechanism
During 2010, Ecom updated its grievance procedure for workers in accordance with IFC Performance Standard 2, including steps to be taken for workers to manifest any concern, mediation process, responsible persons, and how feedback will be given. The grievance procedure was implemented at the corporate level and at each operation.

PS3: Pollution Prevention and Abatement

Wastewater treatment
Effluents from Ecom’s operations include process wastewater from coffee wetmills, sanitary wastewater, and storm water runoff. Sanitary wastewater is disposed via local public systems or treated in septic tanks and discharged to soil. Storm water is discharged directly to public sewers, where available. Public wastewater treatment systems are often not available in areas where Ecom operates. Ecom operates 25 wet mills worldwide and is conducting an assessment of effluent quality discharged at each wet mill. If the assessment indicates non compliance with WBG’s EHS General Guidelines for wastewater quality at any given site, Ecom will take specific mitigation action. For sites not attaining compliance, the Company will present a plan for IFC’s approval to upgrade the effluent treatment system in order to comply with country regulatory limits and WBG’s EHS guideline limits for pH, BOD, COD, Total Suspended Solids, Total Nitrogen and Total Phosphorus. This plan will include specific corrective actions and timeline.

Waste management
Solid waste generated from coffee or cocoa processing activities includes organic and inorganic wastes. Organic material is typically reused as natural soil amendments and inorganic materials such as plastics; sacks etc. are sold to vendors for recycling.

Pest Management
Ecom is piloting Integrated Pest and Disease Management practices at the coffee plantations in Nicaragua. The “Broca Trap” is part of Ecom’s tools to control pests reducing the use of pesticides. Extension officers provide technical assistance in selection and use of fertilizers and pesticides. Products for export may be fumigated for pest control with Methyl Bromide, which is subject to phase-out as ozone depleting substance, or Phosphine as required under country regulations. Fumigation is carried out in the warehouses or in the ship’s hull by licensed vendors and in compliance with local regulatory requirements. Ecom has presented to IFC a phase-out plan and schedule in order to restrict use of Methyl Bromide. Similar integrated pest and disease concepts will be extended to cocoa and cotton.

PS-5 Land Acquisition and involuntary resettlement:

Ecom has recently purchased a 3.8 Ha plot in Yovon, Tajikistan to build its own cotton gin. The company will further buy land of neighboring plots. All land transactions are being done in accordance with a willing buyer-willing seller approach.

PS-6 Biodiversity Conservation and Sustainable Natural Resource Management

The expansion of low input cocoa production has been identified as the principal cause of deforestation and forest degradation of the West African Guinea Rainforest. Cocoa productivity intensification is found to be the best practice to avoid deforestation. In order to assist social and environmental traceability and subsequent certification of cocoa, Ecom’s plans for certified cocoa will focus on sustainably increasing cocoa yields, input use, and avoiding land clearance.

The “ECOM FOUNDATION, FOR DEVELOPMENT OF ORIGIN RESOURCES” (www.ecomfoundation.com) was founded in 2006 for the purpose of making a better life for producers of coffee, cocoa, cotton, and other soft commodities. Donations are geared towards healthcare, education, appropriate housing, and other special projects. The ECOM Foundation works together with local non-governmental organizations, other public charities, corporations and local and national governments. The sustainability report (http://www.ecomtrading.com/website.nsf/SustainabilityWelcome?OpenPage) conveys Ecom’s vision and initiatives regarding social, environmental, and corporate outstanding sustainability practices. Some key community development projects: -Maintaining school attendance of 1500 children in Costa Rica in the coffee producing Orosi valley. Scholarships were awarded to stay in school instead of harvesting crops; -In Indonesia, ECOM Foundation together with Starbucks restored an orphanage and refurbished two hospice houses in partnership with BAPH; -Partnering with “Grounds for Health” in Mexico, Tanzania and Nicaragua, the Foundation equipped clinics with supplies to implement the “Same Day Screen and Treat” a program pioneered by the Gates Foundation and the WHO for cervical cancer screening; - Ecom Foundation contribute funds to “Nouvelle Planete” for the construction of housing for teachers in Burkina Faso -“Seeing is Believing” Global initiative, where ECOM Foundation is a donor to Standard Charter Bank to prevent and cure blindness; - As support to the Cuá community in Nicaragua, ECOM provided 5,000 trees to the Ministry of Education so that a school project in 29 different schools could plant seedlings along the riverbanks; -Training program in Paraguay to provide skills and “Agricultural Technician” Certifications for local students. In one year the program showed a more than 50% increase in student participation and an 11% increase in agricultural yield. ECOM Foundation was chosen as a finalist in the Awards of Excellence competition organized by The Center for Nonprofit Management of Dallas; -Building of a school adjacent to a coffee mill for the children of the rural in Bengal, India. Starbucks; -Daisy school project – Bangalore -Satellite school project – El Salvador -Bogia high school agricultural curriculum – Papua New Guinea

The Company will disclose information on management of social and environmental risks and impacts associated with this corporate investment, including its supply chain, and specific country’s operation on its website: http://www.ecomtrading.com