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 The project is located on a site that was previously unoccupied and the vegetation in the general area, inclusive of the site, is comprised of degraded grassland. Thus PS 5: Land Acquisition and Involuntary Resettlement does not apply, and neither does PS 6: Biodiversity Conservation and Natural Resource Management. There are no Indigenous Peoples in Burundi and thus PS 7: Indigenous Peoples does not apply, and neither does PS 8: Cultural Heritage.

The project is located on previously vacant and disturbed land within a newly established development area within central Bujumbura. The area is zoned for commercial use and the project is in accordance with the planned usage for the area and is of limited size. Progimmo has engaged the services of an experienced architect and similarly has a qualified Project Manager to ensure construction is undertaken in accordance with the original designs. Municipal services are readily available and mitigation measures have been defined in the project Environmental and Social Action Plan (“ESAP”) to address the limited potential impacts identified. Thus this is a Category B project in accordance with the IFC’s Environmental and Social Review Procedure.

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 Progimmo, applicable national laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and the applicable World Bank Group (“WBG”) 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. Environmental, Health, and Safety (EHS) Management and Organization No environmental impact assessment was required for the project in terms of national legislation and assuming effective implementation of the mitigation measures defined below, such an assessment is not required for the project. The general area, including Progimmo’s site, has been zoned for commercial and tourism usage and the initial plans for the complex were approved by the municipal planning department. The revised designs will also require approval from the planning department. A local experienced architect has been appointed for project design, and the design and construction references have been based on the current German DIN Standards and relevant national codes of practice have been applied to the development. Whist the respective buildings are only 4 storey’s high, the wind force and earthquake analyses are still to be defined and will be verified to IFC’s satisfaction by an appropriately qualified expert. The client has appointed an experienced local Project Manager who is a qualified civil engineer and has managed numerous construction projects in Burundi. The Project Manager will be responsible for ensuring the complex is constructed in accordance with the original design specifications. In addition, the Manager will be responsible for overseeing contractor compliance with the occupational health and safety plan for the construction phase. Once operational, Progimmo will either manage the complex or appoint a project management company to do so and all the associated services such as cleaning and maintenance will be subcontracted to specialist companies. Labor and Working ConditionsAside from the technical project team and administrative support, Progimmo do not employ any personnel. The company will compile a guideline detailing human resource requirements to be applied by all companies involved in the ongoing provision of services during the complex’s operational phase to ensure alignment with this Performance Standard. This is defined as a requirement in the ESAP. A local contractor known to Mr. Hicintuka and who has previously undertaken construction projects on his behalf has been appointed for the construction phase. The number of construction personnel on-site will be 100-300 depending on the stage of construction and whether both office blocks are constructed simultaneously, or not. Progimmo’s contract with the building contractor will require compliance with PS2: Labor and Working Conditions, and national labor legislation. In addition, prior to the commencement of construction, the contractor’s human resources documentation will be submitted to IFC to confirm alignment with this Performance Standard. This will also include the occupational health and safety (“OHS”) plan to be applied during construction inclusive of the requirement for a full-time safety representative. Six months following commencement of construction, Progimmo will commission an independent specialist to audit implementation of the contractor’s human resources documentation and develop a corrective action plan if necessary. Further, the contractor will be required to regularly report on compliance with the OHS plan to Progimmo. Labor legislation in Burundi is relatively undeveloped, though various International Labor Organization Conventions have recently been ratified. These include that related to freedom of association and collective bargaining, equality of opportunity and treatment, elimination of child labor, working times and wages amongst others. To ensure all tenants comply with national labor requirements, Progimmo’s tenancy agreements will include a requirement for compliance with national labor legislation. Pollution Prevention and Abatement Potential pollution issues as identified during the construction phase are those typically associated with construction sites and include, amongst others, the discharge of contaminated (high silt loads / oil and grease) stormwater and diesel and oil spills. Given the proximity of Lake Tanganyika and the high ground water table, potential off-site discharges and on-site spills need to be adequately managed. The area is characterized by various developments in varying stages of construction, though there is a operational hotel some 150 m east of the site. Thus there will be a need to limit the potential for noise impacts on this facility, though there are various developments located closer to the hotel that are also under construction. To address impacts during the construction phase, Progimmo will compile an Environmental Management Plan (“EMP”). This Plan will define times when construction will occur and will be communicated to the neighboring hotel. In addition, the EMP will detail a procedure describing how the contractor and company shall receive and manage grievances. During the operational phase, waste streams from the complex will include domestic solid waste (e.g., paper, plastic, glass bottles) and liquid waste, which includes sewage and storm-water runoff. Solid waste will be collected by the municipality for disposal at the municipal landfill site. Currently, the area is not connected to the municipal sewerage system and given the high water table, it is not possible to dispose of waste water via septic tanks. Thus Progimmo will install a waste water treatment plant prior to the complex being operational. This plant is required to treat waste water such that it is compliant with national standards and the World Bank Group (“WBG”) Environmental, Health and Safety (“EHS”) Guidelines. Progimmo are considering options for reusing waste water such as for the irrigation of landscaped areas and in the ablution facilities. Treated waste water that cannot be reused, will be discharged via the municipal stormwater drain that ultimately discharges into the Lake. The municipality extracts water from the Lake and boreholes which is then treated prior to being supplied to the consumer. Lake Tanganyika is the second largest lake in the world and thus the sustainability of water supply is not considered an issue. Stormwater will be collected in on-site drains and discharged directly into the municipal stormwater drains. To limit the potential for contamination of stormwater from the parking areas, an oil water separator will be installed at the stormwater discharge points from the site. Electricity will be supplied from the national grid and there will be a 600 kVa backup diesel generator for each building. Given that the municipal electricity supply can be erratic, an external fuel storage tank will be required for the generators. This will be an above ground bunded tank. The total estimated electricity consumption for the complex is 1,400,000 kWh per annum and this, combined with the estimated diesel consumption for the generators and use of air conditioners, equates to a total of approximately 1000 tons of CO2 per annum. To optimize opportunities to improve energy efficiency, the company will engage with IFC’s Green Building Specialist. From time to time the property will be fumigated for pests and the chemicals used in these activities will be compliant with the WBG EHS Guidelines for such. Community Health, Safety and Security Given the nature of the development and that access to the complex will be via Avenue du Large, the main thoroughfare providing access to the development node, traffic related impacts including that related to public safety, are considered limited. The complex will have sufficient parking for tenants and some on-site parking for visitors, and there is sufficient space on the three access roads that border to the site for visitors to park. The complex’s design is still to be finalized, as is the approach to the life and fire safety (“LFS”) management system. In doing so, Progimmo will commission a LFS engineer to either design, or review the existing engineering design for the complex, to ensure compliance with an internationally recognized LFS code, the national LFS code and requirements of the WBG’s EHS General Guidelines. Further, once construction is complete, a LFS engineer will review the project to confirm the complex has been constructed in accordance with the original LFS design. Thereafter and if necessary. Progimmo and IFC will agree on a corrective action plan to ensure alignment of the complex with the original LFS designs. Progimmo are also required to provide evidence to IFC by a suitably qualified specialist that that the wind force and earthquake analyses for the complex have been undertaken against a recognized standard for such, and adequately incorporated into the complex’s design. Typically security in Burundi is provided by unarmed guards and this will similarly apply at the complex.

No environmental impact assessment has been undertaken for the project and given the nature of the project, this is considered unnecessary. The broader area is undergoing development and the complex is in accordance with the zoning for the area and one of the smaller projects being initiated. The EMP will define a procedure for managing complaints, though assuming effective implementation of the EMP, the potential for complaints should be limited.

Mr. Edouard Hicintuka, Managing Director Progimmo S. A. B. P. 2937 Tel: +257 22226226 Mobile: +257 79920300r Fax: +25722221095 Email: ehicintuka@approservices.com / progimmo@ymail.com Mr. Gaspard NiyongaboHead of Department  Urban ManagementUrban Management DepartmentMinistry of Water, Environment, Physical Planning and Urban Development Immeuble ''du Ministère des Finances'', Avenue de la Poste, Bujumbura Tel: 257 22 22 6898 Mobile: +257 79 913 867 Email : kiroro.ma@yahoo.fr