While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 7 – Indigenous Peoples
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The existing SPPB and Olecar areas of influence are heavily modified and degraded due to the extensive industrial and domestic activity that has taken place in the Cartagena Bay for decades. Nonetheless, this is a Category A project because of the potentially significant and diverse environmental and social impacts and risks associated with Pacific Infrastructure’s investment plan, including potential significant impacts on natural habitats and on Afro-Colombian and Indigenous Peoples (IPs) communities, as well as a potentially complex land acquisition process primarily associated with Olecar’s right-of-way (ROW) easement.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Sociedad Portuaria Puerto Bahía (SPPB): Key ESHS impacts and risks during construction include: the potential negative impacts to a total of five Afro-Colombian communities; the potential negative impact on coastal-mangrove natural habitat remaining at Ciénaga Honda; and potential risks related with the directional drilling of the pipeline under el Canal de Dique to connect the transference station with the storage tanks at the terminal site; and those typically associated with large infrastructure civil works. The Cartagena bay is naturally deep, and the shallower areas near the port are 19 meters deep and therefore the SPPB project does not require dredging. Once in operation, the key ESHS impacts and risks are those characteristic of any port operation, such as potential increase of oil spills and explosions, fugitive and/or accidental spills from vessel and road traffic; treatment and disposal of ship effluent and ballast waters; potential increase in accidents between ship traffic and local artisanal fishing boats; restriction of access to fishing grounds; and occupational health and safety to port and shipyard employees. As a point of reference, Cartagena Bay currently handles an estimated volume of 3,000 container and cruise line vessels per year averaging 70,000 – 80,000 DWT. Puerto Bahía''''s operation (liquids + multipurpose) would increase this volume by approximately an additional 300 vessels per year, roughly 10% of the current traffic volume.
Oleoducto del Caribe (Olecar): Key ESHS impacts and risks during construction include: the potential negative impacts over 32 communities along the ROW, including a total of six communities considered IPs (e.g. Afro-Colombian or Indigenous Peoples communities) and Olecar''''s ability to develop adequate community engagement and management plans for the pipeline from Affected Communities and obtain Free Prior and Informed Consent (FPIC) from potentially affected IPs; land acquisition and potential involuntary physical and economic resettlement related with ROW easement; and potential impact on natural habitats (e.g. Canal del Dique Estuary) along the pipeline''''s routing direct area of influence; and those typically associated with large infrastructure linear civil works. Once in operation, the key ESHS impacts and risks are those characteristic of any pipeline operation, such as fugitive and/or accidental spills; noise and air emissions from pumping stations; community health and safety; and occupational health and safety due to maintenance activities.
Pacific Infrastructure (PI): The Company will have in place procedures and capacity in place to manage all these impacts and risks with existing pollution prevention and control technologies and with standard environmental and social management practices, such as those described in IFC''''s EHS Guidelines.
The sections that follow describe how PI expects to manage potential ESHS impacts and risks of its operations, including proposed mitigation measures necessary to ensure that both SPPB and Olecar will be consistent with the IFC Performance Standards.
Environmental and Social Impact and Risks Identification Process and proposed Management Program:
Sociedad Portuaria Puerto Bahía (SPPB): SPPB has conducted two different but complimentary ESIAs in accordance with Colombian environmental laws and regulations and in-line with GIIP. The first ESIA process involved extensive social and environmental baseline determination as well as an exhaustive impact and risk identification process. This ESIA was approved by the ANLA (Autoridad Nacional de Licencias Ambientales) on August 19th, 2011 via resolution 1635.
After this first approval, PI modified the original SPPB design by (a) eliminating a fluvial terminal component in the initial design, (b) expanding the terrestrial footprint by incorporating a 8.5-ha site on the right bank of Canal del Dique (Pasacaballos), (c) incorporating an additional maritime area under concession for liquids loading berths and vessel maneuvering, (d) construction of berthing positions for the exclusive handling of hydrocarbons and derivatives, and (e) construction of dry cargo loading dock (solid bulk and general cargo). This new design also included (f) directional drilling under the canal to construct a single pipeline connecting the transference station with the main storage area at the terminal, and (g) the construction of a 2x5 MW natural gas power plant for internal consumption. This modification required an additional comprehensive ESIA process that was approved by ANLA on November 19th, 2012 via resolution 0950.
During the ESIA process environmental baseline conditions were determined, potential impacts of construction and operations assessed, and mitigation and monitoring plans and mitigation measures developed. These include solid waste, water quality, and effluent management programs, and air quality and emissions management and control, among others.
Similarly, as part of the both ESIAs processes the Company commissioned Fundación Mamonal to carry out a social baseline, and Fundación Puerto Bahía engaged the five potentially affected Afro-Colombian communities located within SPPB''''s direct area of influence, namely the communities of Ararca, Santa Ana, Pasacaballos, Caño de Oro, and Bocachica. In compliance with ANLA''''s request SPPB carried extensive community consultation and engagement with Affected Communities, including the five Afro-Colombian communities. The main ESHS impacts and risk jointly identified between the SPPB and the Affected Communities included: increase in noise levels; affectation of air quality; landscape alterations and potential changes in temperature; risk associated to hazardous materials/liquids spills; further deterioration of marine and coastal habitats; affectation of fishing sites, routes and fisherman income; changes in communities social dynamic and potential for social conflict; alterations of traditional cultural patterns (acculturation); employment generation; and improvement in access roads and local infrastructure. The Environmental and Social Management Plan (ESMP) has been discussed and agreed with Affected Communities, and specific avoidance, reduction, mitigation, or compensation measures have been prepared for each one of these identified impacts and risks.
In compliance with applicable Colombian social and environmental, labor, and occupational laws and regulations, SPPB has developed an ESMP containing a total of 19 management programs to be applied during the construction phase and 10 management programs to be applied during operation, respectively. For construction, these include an overarching Environmental and Social Management Plan (GA-1) and a Health and Safety Management Plan (GA-2), and a series of more specific programs such as: biotic natural resources conservation (e.g. mangrove compensation, protection of endangered species); abiotic natural resources preservation (e.g. soil conservation, surface water and drainage management); pollution prevention and control and monitoring plans (e.g. air and noise emissions, air and water quality, solid and hazardous waste management); and social management activities (e.g. fisheries management, community communication and engagement, local hiring, environmental awareness and education); among others. Similarly for the operations phase, there is an overarching ESHS Management Plan (GAO-1) and a series of specific programs mostly focused on monitoring the effectiveness of the different resource conservation, pollution prevention and control, and social communication and engagement activities and programs.
Oleoducto del Caribe (Olecar): Prior to the commencement of a full ESIA process, the ANLA required PI to perform a comprehensive alternative analysis (DAA- Diagnóstico Ambiental de Alternativas). This alternative analysis evaluated three potential routings for the pipeline as well as the no-pipeline option; characterized the geo-physical, environmental, and socio-economic area of influence and assessed the potential significance of ESHS impacts and risks for each alternative. With the intention of minimizing ESHS impacts and risks, PI proposed to the ANLA their technical opinion on the best alternative as well as the general proposed ESHS management framework. PI recommended Alternative 1, which is the shortest option with a total of 128 km, running mostly parallel to an existing Ecopetrol pipeline ROW. This alternative does not cross any critical habitat, and runs mostly along flat agricultural lands and pastures. Ecologically sensitive areas such as Parque Natural Regional Manglares de Guacamayas and the Monte Maria and Serrania de Coraza are completely avoided. It must be noted, however, that all three alternatives need to cross the Canal del Dique Estuary (natural habitat) before they reach the SPPB transference station. Alternative 1 affects 3.5 km of the Canal del Dique Estuary, where the company is proposing to perform directional drilling to avoid disturbances as much as possible.
On the social front all three alternatives include Affected Communities in their direct area of influence, including Afro-Colombian and Indigenous Peoples communities (Zenú). Alternative 1 direct area of influence includes a total 32 Affected Communities, as opposed to 36 and 40 affected by Alternatives 2 and 3, respectively. Of these 32 Affected Communities, 18 self-identify as IPs, but only 6 meet the criteria to be officially recognized as IPs by the GoC. All three alternatives require the negotiation of easement agreements for the ROW, however physical and/or economic displacement is expected to be limited. Alternatives 1 and 2 only require the relocation of two households when the pipeline is approaching the SPPB transfer station in the sector of Pasacaballos. Alternative 3, which was not selected, would have entailed the relocation of 23 families.
The DAA proposed a general preliminary ESHS management framework that includes a total of 30 different plans and programs, including: pollution prevention and control measures; protection of river crossings; solid, liquid and hazardous waste management procedures; soil protection and re-vegetation programs; biodiversity resources management; and social management programs related to prior and informed consultation and community engagement, resettlement and livelihood restoration, local employment and grievance mechanism. The Management framework will be further developed and strengthen, including its consultation with Affected Communities as part of the ESIA process.
On November 21st, 2012, ANLA issued via Auto 3622 its authorization to proceed with the full ESIA process for Alternative 1, including extensive social and environmental baseline analysis, community consultation and engagement activities, and a process of prior and informed consultation (Consulta Previa) with affected IPs communities.
Pacific Infrastructure: Going forward and to ensure appropriate management of the risks and impacts of all additional future developments, PI will develop an integrated corporate-level environmental, social and health and safety management system (ESHS-MS), which will contain, at a minimum, the following elements:
Policy: PI will develop an overarching Policy statement of the ESHS objectives and principles guiding the organization''''s ESHS performance. The policy will describe specific objectives and aspirations for its ESHS performance, consistent and with direct reference to the IFC Performance Standards, including principles of FPIC when Indigenous Peoples (IPs) are affected. In addition to the commitment of compliance with all applicable Colombian ESHS laws and regulations, the policy should also include other major ESHS commitments such as compliance with good international pollution prevention and control practices as those described in the applicable IFC EHS Guidelines (e.g. Ports Harbors and Terminals, Crude Oil and Petroleum Product Terminals).
Risks and Impacts Identification Process and Management: The corporate ESHS-MS will define PI''''s social and environmental risk and impact identification process consistent with GIIP. This process will include all the necessary steps and methods that are required to screen, identify, analyze, measure, or assess, in quantitative terms to the extent possible, the potential risks and impacts (including environmental, social, health, and safety, and labor and security) associated with the activities to be developed, and assure that the mitigation hierarchy is applied to manage all identified impacts and risks. When applicable, this process will involve a full-scale Environmental and Social Impact Assessments (ESIAs) process that will follow GIIP, conform to Colombian laws and regulations, as well as those of IFC''''s Performance Standards. The findings of the project-specific ESIAs will detail a program of mitigation and performance improvement measures and actions necessary to effectively manage the ESHS risks and impacts of each of its developments in line with PI''''s corporate Policy. Project-specific assessments will be used to establish action plans and metrics for project construction and operation. EPC contracts for each project will incorporate the relevant project-specific mitigation measures and actions identified during the assessment process to ensure compliance with Colombian requirements, as well as IFC PS. Project-specific mitigation measures will include management of impacts and risks addressed in PS2 through PS8.
Organizational Capacity:
Sociedad Portuaria Puerto Bahía (SPPB): During construction, the Environmental and Social Management Plan (GA-1) is being executed by a team 6 people, including a social and an environmental inspector from Oiltanking as well as one ESHS manager of the EPC contractor. In addition, and given the complexity associated with the social aspects of the project, and the need to have good engagement and communication team in the field, Fundación Puerto Bahía has a team of 6 social liaisons to execute and supervise the appropriate application of the social plans and programs, and receive and manage any community grievances. During operation SPPB expects to have a team of two people executing the Environmental and Social Management Plan (GAO-1), and continue with the support from the Fundación Puerto Bahía''''s social team.
Oleoducto del Caribe (Olecar): Since this sub-project is only at the conceptual stages, currently PI has hired Ecoforest to perform all the ESIA activities. In compliance with PI''''s own ESHS policy and IFC PS, Olecar will designate an appropriately qualified team supported by adequate financial and professional resources to design and implement the relevant ESHS plans and programs. The resulting Management Plans will be in line with IFC''''s Performance Standards 1 through 8 as needed. Some of the specific Management Plans will include, but not be limited to: Integrated Social Management Plan incorporating PS1 (Stakeholder Engagement) and PS7 (Indigenous Peoples) requirements; Security Forces Management Plan as per PS4 (Community Health, Safety and Security), Land Acquisition Plan as per PS5 (Land Acquisition and Involuntary Resettlement), among others.
Pacific Infrastructure: Going forward and at the corporate level, the Company will designate an appropriately qualified individual supported by adequate team of professionals and financial resources, with overall ESHS corporate responsibilities. To ensure adequate support of the newly designated ESHS manager, PI will clearly define his/her responsibilities and communicate these to the rest of the Company and site operating staff. The corporate ESHS department will also be provided with sufficient authority and resources to achieve effective and continuous ESHS performance across all of PI''''s business activities. This may include in-house staff, as well as external consultants. In addition, as an integral component of the corporate ESHS-MS, PI will retain an external environmental and social advisory consulting firm (ESAC) with extensive and proven international experience applying IFC Performance Standards to help guide future developments.
Monitoring and Review:
Sociedad Portuaria Puerto Bahía (SPPB): During the ESIA process overall baseline ambient quality was assessed, and generally it was determined that the project area of influence is modified and degraded due to the extensive industrial and domestic activity that has taken place in the Cartagena Bay for decades, including untreated domestic and industrial wastewater and sedimentation and contaminant transport from the Magdalena river present in the Canal del Dique. Water quality (e.g. ToC, coliforms, pH, TSS, nitrates, ammonia, TPH, BOD, COD, heavy metals, PAHs, Oil & Grease) was measured in 2007 and 2008 in several sites of the Bay, the Canal del Dique and Ciénaga Honda, generally reflecting poor water quality, especially in the Canal del Dique where high zinc levels were reported. Sediments were measured at the same sites as water quality, where zinc was the only elevated contaminant. PM10 concentration was also measured in five stations around the project''''s direct area of influence during 2007 and 2009, and noise levels were also measured in a total of 5 stations, with day and night campaigns in the same two years. All air quality and noise measured values were within the acceptable Colombian legal requirements, with the exception of noise night levels which greatly exceeded the permitted 45 d[B]A residential values.
The pollution prevention and control and monitoring plans have the objective of verifying the effectiveness of the proposed impact mitigation measures, and include procedures to assess air, soil, water and marine sediments quality, as well as noise levels. In addition, the ESMP also includes a sub-program to monitor any measurable impact over flora and fauna, a sub-program to assess the effectiveness of the social management sub-program.
Twice a year, SPPB presents environmental and social compliance reports (Informe de Cumplimiento Ambiental – ICA) to the ANLA. In addition, the SPPB environmental manager meets on a weekly basis with his EPC and Oiltanking counterparts, and presents weekly compliance status reports.
Oleoducto del Caribe (Olecar): The Olecar ESIA report will propose standard supervision, monitoring, and reporting procedures compatible with Colombian regulation and GIIP.
Pacific Infrastructure: Responsible corporate staff will monitor ESHS performance of future developments against ESIA-based action plans, as well as established monitoring protocols and metrics (e.g. air emissions, air quality). The results of routine monitoring and measurement activities carried out at the project level, as well as any environmental or safety incidents will be recorded. In addition, PI will implement a formal ESHS audit program to further ensure environment and safety performance for all its business activities. The program will include detailed audit protocols for environmental and safety issues. Conducted by competent environmental and safety professionals from within the Company, audits will be undertaken for construction sites and operating installations. Non-conformances with established standards and metrics and the related corrective action recommendations will be recorded and tracked. Project specific environmental monitoring framework will be based on the ESIA environmental and social management plans and programs and address: (i) emissions and ambient air quality, (ii) noise, (iii) wastewater and solid waste, and (iv) occupational health and safety performance indicators, among others. Specific environmental monitoring measures to be implemented will be identified during the ESIA process including the parameters to be measured, sampling and analytical methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and the definition of thresholds that signal the need for corrective actions. Monitoring thresholds will be consistent with those referenced in the applicable IFC EHS Guidelines and Colombia environmental quality standards.
Monthly, quarterly, and annual operations and environmental performance data will be consolidated into reports and made available to PI senior management. The results of ESHS monitoring will be evaluated and documented at both individual sub-projects and corporate level. Reports will furnish the information and data needed to determine compliance with the corporate ESHS Policy and ESHS-MS. The format of these reports will include a summary of findings and recommendations.
In addition, as an integral component of the corporate ESHS-MS, PI will hire an ESAC with extensive and proven international experience applying IFC Performance Standards, that will closely supervise PI''''s sub-project compliance with IFC PS. This supervision will include periodic site visits as well as documentation review, and the development of corrective action plans if any breaches are encountered during supervision activities.

Sociedad Portuaria Puerto Bahía (SPPB): PI will ensure that SPPB has in place a project-level Human Resources Policy and procedures in line with its corporate Human Resources Policy, local regulations and IFC PS2, and additionally it will include provisions to ensure that the Construction Contractor and Sub-Contractors abide by the same requirements.

During the port construction phase around 150 jobs will be created. SPPB gives priority to hiring local people when skills match available jobs and during construction it is expected that between 20% and 30% will be hired from local communities. During operation it is expected that SPPB generates 150 permanent jobs, with approximately 40% - 60% being local hires. The project’s ESHS-MP includes a training program for local communities, focused but not limited to project job opportunities. The training program also covers areas such as tourism services and development of communal productive projects for project local procurement and supply. SPPB has started several training programs in alliance with the Technical Training Service (SENA) and various educative institutions. SPPB has carried out an Inventory of Local Workers and Skills covering the 5 affected Afro-Colombian Communities.

The company is already hiring local workers (73 male and female workers) for community investment programs; it is also offering labor training courses with about 219 participants as well as language training (English) and is providing technical support to a local women’s enterprise aimed at providing uniforms and related supply to Puerto Bahía. However a Comprehensive local hiring, selection and training program with defined quotas by community, gender equity strategies, indicators, and other labor-related matters is still to be jointly defined with the participation of the Community Oversight Committee. The plan needs to be communicated to the 5 affected Afro-Colombian communities and should be observed by the main Contractor and Sub-Contractors.

In terms of OHS during construction of SPPB, the EPC will be responsible for the implementation of the Health and Safety Management Plan (GA-2). The EPC has designed an implementation plan that has been reviewed and approved by both Oiltanking and SPPB ESHS manager. This plan includes three sub-programs: occupational safety, preventive and occupational medicine, and industrial hygiene. These programs follow Colombian regulation and standard GIIPs and include: need for an early hazard and risk identification process associate to each task, required protection equipment and qualifications, entry and regular medical physical exams for all workers, and performance indicators such as Loss Time Incidents (LTI), frequency and severity rates, and labor absenteeism, among other. For operations, as part of IFC financing, SPPB will also develop an OHS management plan aligned with GIIP.

Oleoducto del Caribe (Olecar): As in the case of SPPB, PI will ensure that prior to construct
ion Olecar has in place a project-level Human Resources Policy and procedures in line with its corporate Human Resources Policy, local regulations and IFC PS2, and additionally it will include provisions to ensure that the Construction Contractor and Sub-Contractors abide by the same requirements. It will also have in place a Local Hiring Procedure similar to the one to be implemented in SPPB.

In terms of OHS for Olecar, in compliance with Colombian regulations and in alignment with IFC requirements and GIIP, the ESIA process will include the evaluation of OHS risks related to the construction and operation of this pipeline, and propose detail management plans and procedures commensurate to these hazards and risks.

Pacific Infrastructure: In terms of labor issues at the corporate level, PI will have in place a Human Resources Policy in accordance with Colombian labor laws and IFC’s PS2 requirements which will clearly define the rights and obligations of employees and the employer, including: compensation and benefits; working hours, overtime and leave policy; occupational health and safety policy; grievance redress procedure; rights to join worker’s organizations and to bargain collectively. According to local labor laws, all employees must receive copies of their contracts upon being hired.

Additionally, as stated under PS1 above, PI will develop an integrated environmental, social and health and safety management system (ESHS-MS), which will be applied across all of its operations and sub-projects. This ESHS-MS will include Occupational Health and Safety (OHS) as an integral component, and as a minimum, will assure that: all work processes and tasks’ OHS hazards and risks are well identified; safety risks are evaluated based on the nature of the hazards, magnitude of the risks and consequences, frequency and probability of exposure/occurrence, and potential severity of harm; and these potential hazards are managed in compliance with GIIP. Management strategies will include appropriate process design, mandatory use of personal protection equipment, definition of minimum qualification, training and restrictions, success indicators and clear supervision and reporting mechanisms.

Sociedad Portuaria Puerto Bahia (SPPB): Construction and operating activities are not expected to significantly worsen the existing degraded environmental conditions of the Cartagena Bay and the Canal del Dique areas, and SPPB has in place standard pollution prevention and control practice aligned with GIIP, such as:

Pollution Prevention and Control: The pollution prevention and control and monitoring plans have the objective of measuring and documenting any incremental impacts related to the SPPB construction and operation activities as well as the effectiveness of the proposed mitigation measures. These Plans include 2 air quality and 5 noise monitoring sites to be measured twice a year and 5 water and marine sediment quality sampling sites also to be measured twice a year. There will not be construction or operation activities between 9:00 pm and 7:00 am.

Effluent Waste Management: During the construction phase, there will be one portable toilet per each 15 workers. SPPB will construct an activated sludge waste water treatment plan, which will be installed and operated by a permitted local supplier. Operating procedure MAO-MSRH-3 describes proposed designs for the terminal to segregate and treat wastewater, storm water, and runoffs throughout the facilities, including oil/water separators and grease traps, especially at vehicle maintenance areas. Surface runoff and storm water will be stopped from reaching the bay without treatment, especially to the area of Cienaga Honda. SPPB does not plan to manage liquid wastes generated by ships (i.e. bilge waste, ballast water, sewage, and used oils). The ESMPs indicate that the Port of Cartagena has several companies that provide this service in compliance with International Convention for the Prevention of Pollution from Ships (MARPOL) 73/38 guidelines, such as ORCO Ltda.

Solid Waste Management: The construction and operation ESMPs describe a hazardous and non-hazardous solid waste management plan that includes an evaluation of potential sources of solid wastes and defines procedures for its reduction, handling, storage, segregation, recycling, transportation, and final disposal. Both hazardous and non-hazardous solid waste, including any potential refuse from land and marine excavation required for construction, will be collected and disposed by licensed serviced companies and disposed in permitted sites.

Management of Hazardous Materials (Hazmats): SPPB will be a multipurpose terminal, and therefore will handle containerized general cargo, bulk cargo (e.g. coffee, sugar, iron), special cargo (e.g. chemical substances) and liquids (e.g. crude oil and derivatives). The ESMPs include one separate program for each of this type of cargo. These include procedures for the storage and handling in compliance with GIIP, such as those outlined in MARPOL annexes I, II, II and IV and the International Management of Dangerous Goods Code (IMDG). The terminal layout includes a section for dangerous cargo, which
will be appropriately designed, as well as an area to isolate any hazmat containing cargo that may be damaged or leaking. Slop tanks will be constructed especially to collect tank mud, tank washings and other oil-yielding mixtures and will be treated and disposed-off by a permitted third party.

Emergency Preparedness and Response: The ESIA presents a very detailed Contingency Plan, where natural and human driven emergencies are analyzed with regard to their probability of occurrence, severity of the consequences and vulnerability of the potential environmental or social receptors. This risk analysis identified a total of 31 potential emergencies out of which three require the design of detail actions. The most significant emergency relates to crude oil spill, and the Plan considers three potential scenarios: crude oil spill in the bay (Ships of >333,000 bbls capacity), crude oil spilled at the loading docks, and oil-spills/leaks along the transference lines. Detail vulnerability evaluation has been performed, identifying nearby coral reefs, estuaries, beaches, mangrove areas, and towns as zones where clear actions are defined to stop crude from reaching in case of accidental spill. These plans include emergency procedures, required training, and equipment needs. There is a defined Crisis Management team divided in levels of command according to the magnitude of the emergency that includes Local Action Center at the Terminal jointly working with Immediate Action Brigades. The plan involves permanent capacity building, prevention and surveillance strategies, and control, containment and removal procedure and equipment. Spill prevention drills are defined, as well as preventive ships, barges and equipment check-up points and periodic revisions. In addition, the Plan also defines procedures, training, personnel and equipment needs, and chain of command, in case of fires, explosions, earthquakes, hurricanes, ship and vehicle collisions, accidental falling of heavy cargo or equipment, and man-in-water, kidnaps, civil uprising, among others.

This Contingency Plan includes extensive training (e.g. first aid, rescue, fire fighting, spill containment and clean up, earthquake preparedness) and an information/ communication program that includes a list of all the near-by hospital and emergency response organization, such as firemen, coast guard, and civil defense. Furthermore, SPPB is a member of the local APELL Cartagena chapter which is led by the National Industry Association (ANDI).

Resource Efficiency: To be able to set resource efficiency targets and reduce overall impacts, SPPB will implement a system to track resource use (e.g. water, electricity, fuel). As currently designed, SPPB will use state-of-the-art equipment to reduce emissions and maximize efficiencies, and is expected to be a zero-discharge operation, where the effluents for the waste water treatment plan will be used to irrigate landscape and greenery at the terminal site.

Oleduc
to del Caribe (Olecar): In compliance with Colombian regulations and in alignment with IFC requirements and GIIP, the ESIA process will include an exhaustive evaluation related with resource use and pollution impacts and risks of both construction and operation, and assure that appropriate resource efficiency and pollution prevention and control measures are designed.

Pacific Infrastructure: Finally, PI’s corporate-level ESHS-MS will describe common operational procedures that apply across all business activities for resources efficiency, pollution prevention and control, environmental monitoring, and emergency preparedness and response. PI business activities will follow emission management and control procedures, which will describe GIIP, follow mitigation hierarchy principles, and propose first preventive measures, then recycling and recirculation to reduce emissions, and lastly end-of-pipe pollution control solutions. As much as technically and financially possible, PI will avoid or minimize pollution from project activities that could potentially cause adverse impacts on human health and the environment, promote more sustainable use of resources, including energy and water; and reduce project related GHG emissions. In addition, PI will implement all applicable aspects of the IFC General and Sector Environmental, Health, and Safety Guidelines, including but not limited to the Harbors and Terminals, Crude Oil and Petroleum Product Terminals, and Thermal Power Plants.

Sociedad Portuaria Puerto Bahía (SPPB): SPPB Contingency Plan has processes in place to address the hazards posed to neighboring communities by storage and transportation of crude oil, petroleum derived liquids, as well as other chemical and hazardous substances. The Contingency Plan was presented to and discussed with nearby communities with special emphasis in Pasacaballos which is the town closest to the terminal and transference facilities. Emergency response is expected to be coordinated with government agencies and the community, and SPPB will assess any government capacity shortcomings to adequately aid the community in emergency response and update its Contingency Plan to compensate for government capacity shortcomings.

Other risk to neighboring communities relates to the potential increase in accidents between cars and pedestrians with port-related traffic, during both construction and operation. However, the SPPB traffic will be served by a newly built highway that bypasses the nearby town of Pasacaballos. This traffic flow pattern was specifically requested by and agreed upon with the neighboring community of Pasacaballos. Additionally, the port’s operation is not expected to increase traffic flow within the nearby towns of Ararca and Santa Ana. Also, as a result of the consultation process with the Affected Communities the company agreed to bring construction materials and machinery mainly via ships and barges to avoid, as much as possible, traffic impacts and risks, which were, by far the greatest health and safety concern identified by the potential Affected Communities. Nevertheless, there will be some transport of construction materials, equipment, and workers by land to and from the project site during construction which generate dust and traffic safety potential impacts. The ESHS–MP widely discussed with nearby communities contains a series of mitigation measures including maritime and fluvial transport of materials and heavy machinery, speed limits, dust control, etc. In addition, and based on community concerns, the Company decided to establish a buffer zone between the 8.5 ha on the right bank of Canal del Dique and the community of Pasacaballos. In addition, the company will develop a Traffic Management Plan for Construction and for Operations that defines the safety features for traffic inside the project site and access areas as well as a series of measures aimed at minimizing impacts outside the port such as waiting parking areas for trucks.

Fishermen operating nearby the SPPB have coexisted with port marine traffic for over 40 years, and have learned to navigate outside ship navigation routes and roadstead. The ESMP include several management actions that were jointly identified and agreed upon with communities, applying preventive/mitigation measurements based on recognized GIIP. As a condition to IFC’s investment, SPPB will include a navigation safety awareness and emergency response program to be provided to all fi
shermen in the project’s area of influence.

SPPB will obtain the International Ships and Port Facilities Security (ISPS) Code certification Levels I to avoid and control any illicit activity or terrorist act involving international ships. Such acts include piracy, armed attacks, terrorism, sabotage (alteration or stealing of cargo), contraband, people’s trafficking, and management of dangerous goods.

During operation SPPB will engage the services of a private security company that should be certified and supervised by the National Superintendence for Security Companies (Superintendencia de Vigilancia y Seguridad Privada). Personnel from the National Police are also expected to be present at SPPB during operations. As condition of IFC’s investment, for construction and operations the Company will develop a Security Forces Management Plan to ensure coordination with the public armed forces and that all security personnel based on IFC’s PS4 and the Voluntary Principles in terms of implementation of code of conduct, training, equipment and monitoring of security personnel.

Oleoducto del Caribe (Olecar): It is expected that in compliance with Colombian regulations and in alignment with IFC requirements and GIIP, the ESIA process will determine potential risk to neighboring communities along the ROW, and implement appropriate mechanisms to avoid, prevent, reduce, mitigate and compensate any potential impact, and assure that potentially affected communities are aware of the potential risks, know how to respond to any emergencies, and have clear mechanisms to manage grievances. Prior to starting construction, the Company will have in place a Security Forces Management Plan for Olecar.

Pacific Infrastructure: As part of the corporate-level ESHS-MS, PI will develop a corporate-wide framework that can be used to consistently update and tailor the Emergency Response Plans (ERP) for each facility or sub-project and include the necessary emergency and response scenarios involving neighboring communities. This ERP will assure that quantitative risk assessments are updated for all PI assets and determine potential risk to neighboring communities and that site specific community emergency preparedness and response plans are developed per the findings of these assessments. The ERP will anticipate and avoid adverse impacts on the health and safety of the Affected Community during the project life, from both routine and non-routine circumstances; and ensuring that safeguarding of personnel and property is carried out in accordance with relevant human rights principles and in a manner that avoids or minimizes risks to the Affected Communities.

PI will also adopt a corporate-level Security Forces Management Protocol to ensure that any engagement of private or public security forces to protect its facilities follow the requirements of PS4 and the Voluntary Principles on Security and Human Rights.

Sociedad Portuaria Puerto Bahía (SPPB): The SPPB is located within Cartagena Bay which is a modified coastal habitat, highly intervened by human activity, and where the basic ecological functions of the ecosystem have been disturbed for years. The land where the port facilities will be located, was first licensed as coal terminal, and latter used for 10 years as a shrimp farm.

Nonetheless, areas of the larger Cartagena Bay are still considered Natural Habitat, including some areas containing mangrove forest and coral reefs. Furthermore, vegetation clearance required for the SPPB will include the removal of 3.48 ha of mangrove cover, that even if degraded and the product of secondary colonization, are composed of viable assemblages of plant and animals largely of native origin that do maintain their primary ecological functions. The ESMP includes compensation for affectation to mangrove in a ratio of 1:10, dry forest in a ratio of 1:4, and bush vegetation in a ratio of 1:1. To date, SPPB has planted and is maintaining a total of 107.5 Ha with red mangrove (Rhizophora mangle) in the areas of Caño Matunilla, Caño Lequerica, Covado, and Ciénaga de la Virgen, and 25.0 Ha of diverse tree species in Arroyo Coral, Arroyo Polón, and Arroyo Largo. All reforestation activities have been carried out using workforce from local communities.

The closest Natural Habitat to the project is the estuarine mangrove forest of Ciénaga Honda. No material disturbance to the basic ecological functions of this ecosystem is expected as a result of the Project.

In addition, the construction ESMPs include extensive and continuous monitoring and awareness raising education activities associated with vulnerable and endangered species known in Cartagena Bay, emphasizing on species such as the Spotted Sandpiper (Actitis macularia), Blue-winged Teal (Anas discors), and Black-necked Screamer (Chauna chavaria), the American crocodile (Crocodylus acutus), Red-footed tortoise (Chelonoidis carbonaria), Pond Slider (Trachemys scripta ornata), Magdalena Rive turtle (Podocnemis lewyana) and the Marine turtles: Green sea turtle (Chelonia mydas), Loggerhead Sea Turtle (Caretta caretta), and the Hawksbill turtle (Eretmochelys imbricata), all under some sort of protected status in Colombia.

Furthermore the ESMPS also include quarterly collection of phytoplankton, zooplankton and marine benthic samples at the same 5 stations where the water and marine sediment quality samples will be collected.

Oleoducto del Caribe (Olecar): The alternative selected will cross approximately 3.5 km of the Canal del Dique Estuary, which is a natural habitat and reportedly a Key Biodiversity Area (KBA) for its relevance to migratory bird species. Given the ESIA process is just commencing, there is limited information of potential impacts and expected mitigation measures. PI, however, has represented that they expect to avoid any impact to the estuary and any KBA, and are currently planning to perform di
rect drilling under the 3.5 km of overlap of the ROW with the Canal del Dique Estuary.

Pacific Infrastructure: PI will develop, as part of the corporate ESHS-MS, a Biodiversity Conservation and Sustainable Management of Living Natural Resources Framework, that will be applied across all PI business activities to assure that any project affecting either natural or critical habitats will comply with the requirements under PS6 by: fostering the protection and conservation of biodiversity; maintaining the benefits from ecosystem services; and promoting the sustainable management of living natural resources through the adoption of practices that integrate conservation needs and development priorities.

Sociedad Portuaria Puerto Bahía (SPPB): In the early stages of the ESIA process for SPPB, five (5) communities (Pasacaballos, Ararca, Santa Ana, Bocachica and Caño del Oro) with a total population of 22,000 inhabitants were identified within the project’s Direct Area of Influence. These five communities were certified by the Colombian Government, through the Ministry of Interior, as being Afro-Colombian Communities who had collective rights on their territory, were ruled by traditional collective organizations such as the Consejos Comunitarios Afro-Descendientes and had traditional cultural systems which, as per Law 70 of 1993, gives them tribal/indigenous status and rights. One such right is to be subject to Prior Consultation (Consulta Previa) and ongoing engagement, as per Decree 1320 of 1998, in cases where projects may generate environmental, economic, social, and cultural impacts on their lands, natural resources and culture; even in cases where their property rights are not fully regularized. In these cases, the Ministry of Interior acts as a guarantor of: (1) the rights of IPs and Afro-Colombian communities and (2) the integrity of the Prior Consultation process.

As per the requirements described above SPPB, in conjunction with environmental authorities, the Ministry of Interior, the People’s Defender (Defensor del Pueblo, National Ombudsman), and other regional and local authorities, started a Prior Consultation process in 2010 with the five Afro-Colombian communities in relation to the construction and operation of the SPPB project, including any potential future expansions. The process included signed agreements with the five Afro-Colombian communities that were made official and confirmed by the relevant national and local authorities who participated in the process. The most recent set of agreements between SPPB and the communities were signed on September 2012.

The process was conducted in a culturally appropriated manner and included training workshops for the communities on applicable laws and rights of Afro-Colombian Communities and technical workshops on the nature and scope of the SPPB project and its potential impacts. As describe above on PS1, through these workshops, and other instances, the five Afro-Colombian communities actively participated in the process of identification of potential social and environmental impacts and in the definition of corresponding mitigation and compensation measures. A specific Management Plan was defined with the communities to reinforce their cultural identity and traditions.

The mechanisms for ensuring the ongoing engagement between SPPB and the communities include an Oversight Committee formally established during the consultation process, composed of legal representatives of the affected communities and the Board of the Community Council of Afro-Colombian Communities. The Oversight Committee should meet every two months with SPPB management and representatives of the Ministry of In
terior to verify compliance with the agreed E&S Management Plans. Grievances are mainly received through 3 mechanisms: i) daily visits to communities by SPPB social team; ii) bimonthly meetings with the Community Oversight Committee for compliance monitoring and iii) a Fishermen Committee (Mesa de Pescadores) created during the consultation process.

Oleoducto del Caribe (Olecar): Olecar is expected to have the typical limited impacts associated to this type of pipelines (e.g. temporary nuisances during construction, some limits to land use on the ROW, etc) on the lands of approximately thirty two (32) Affected Communities, eighteen (18) of which self-identify as IPs, but only six (6) have been officially recognized as IPs by the GoC to date. Out of these six communities, three (3) are Indigenous Communities (Cabildos Indígenas) of Zenú ethnicity (i.e. Palo Alto; Puerto Viejo; Reparo Torrente), and three (3) are Afro-Colombian Communities similar to those described in SPPB (i.e. Barule; Humberto Hernández; Pasacaballos). In the case of Pasacaballos, SPPB has already conducted two consultation exercises related to the licensing of the terminal, and has well-established relationships inside this community.

The IP certification process conducted by the Ministry of Interior is a well- structured and documented process that includes site visits, consultations with the communities, and the participation of qualified anthropologists. The process provides adequate safeguard to communities’ rights and legal remedies are provided, and uses IP identification criteria that is consistent with IFC’s PS7. It must be noted that in one case where one community clearly met the IP criteria, Olecar provided support to that community to obtain official recognition.

Since mid 2012 and to date, the level of engagement with the 32 IP and non-IP communities in the selected alignment has been associated to early ESIA efforts and the alternative analysis (DAA- Diagnóstico Ambiental de Alternativas) and is described in the Stakeholder Engagement section below. As the ESIA and project development moves forward, the Company will ensure that additional efforts are made to adequately engage those communities who receive official recognition in the future. The Company’s Integrated Social Management Plan will include a framework describing the process that will be followed to safeguard IPs and achieve and document FPIC as per local regulations and IFC PS7 for Olecar.

The corporate ESHS-MS will include an Integrated Social Management Plan with procedures to ensure adequate management of impacts and engagement with Indigenous Peoples in any of its projects as per Colombian regulations and in line with IFC’s PS7.

Free, Prior and Informed Consent (FPIC)

The engagement process conducted by SPPB with the affected Afro-Colombian Communities is consistent with the principles and requirements of IFC’s PS7 and allows for documenting the Free, Prior and Informed Consent (FPIC) of
those communities of the project. As an integral part of the corporate ESHS-MS, Pacific Infrastructure will prepare an Integrated Social Management Plan aligned with IFC’s PSs, particularly PS1 and PS7, aimed at further defining its corporate social management policy and principles; documenting the stakeholder engagement efforts conducted to date; developing a more robust grievance redress mechanisms; establishing a framework for stakeholder engagement in future activities; summarizing the key mitigation measures for social impacts and providing a monitoring and evaluation framework.

Sociedad Portuaria Puerto Bahía (SPPB): As per Colombian legislation regarding the protection of cultural heritage the ESIA for SPPB included a preliminary archeological review of the project site that was conducted by qualified experts. As a result of this process a Preventive Archaeological Program (PAP), that includes a Chance Find Procedure in line with PS8 was put in place. Additionally, any earth movement at the project site requires the authorization of the Instituto Colombiano de Antropología e Historia (ICANH) which SPPB received on September 2011.

Oleoducto del Caribe (Olecar): The alternative analysis (DAA- Diagnóstico Ambiental de Alternativas) for the pipeline alignment did not identify any significant risks associated to cultural heritage. However, as in the case of SPPB, during the ESIA process adequate assessment of the issue will be conducted and corresponding mitigation measures defined as per Colombian legislation and IFC PS8.

Pacific Infrastructure: The corporate PI ESHS-MS will include measures to ensure that cultural heritage is protected from adverse impacts from any of its business activities in compliance with local requirements, which are in line with international practices, and IFC PS8. In addition, for any construction activities associated with the development of new facilities, PI will develop and implement adequate Chance Find Procedures.

Sociedad Portuaria Puerto Bahía (SPPB): The five (5) communities directly affected by the SPPB are Afro-Colombian Communities with IP status and the process that allowed the Company to achieve FPIC for the project, as per IFC PS7, and the corresponding measures it will implement going forward are described in the PS7 Indigenous Peoples section above.
The Company’s community investment activities are conducted through the Company’s Fundación Puerto Bahía (FPB), and include: i) Job training for community members in port-related activities for the future operation of the Terminal; training is offered through strategic alliances with the National Learning Service (Servicio Nacional de Aprendizaje – SENA) and other education institutions; and ii) technical support to community-based small and medium enterprises so they can become suppliers of goods and services (e.g. industrial clothing, mangrove replanting, small fish farms, catering, port logistics and others) to SPPB and other industries in the area. Further information regarding FPB’s can be found at fundacionpuertoBahía.org/.
Oleoducto del Caribe (Olecar): The pileline alignment selected as a result of the alternative analysis (DAA- Diagnóstico Ambiental de Alternativas) will cross eight (8) municipalities in three (3) Departments (i.e. San Antero (Córdoba); Coveñas, Tolú, San Onofre (Sucre); Maria La Baja, Arjona, Turbana and Pasacaballos (Bolívar)) and will directly impact 32 communities with a combined population of approximately 19.510 people (i.e. El Porvenir, El Peñón, Marín, Minuto de Dios, Parcela el Algarrobo, Bellavista, Punta Seca, El Reparo, Torrente Usuarios I, Torrente Usuarios II, Isla Gallinazo, Puerto Viejo, El Palmar, Santa Lucía de Cocosolo, Loma el Carmelo, Macayepo, Pita Abajo, Mirabel, Pita en Medio, Pasacorriendo, El Chicho, El Bongo, La Lucha, Pajonal, Palo Alto, Sabanas de Mucacal, Níspero, Flamenco, Correa, Rocha, Ballestas, Pasacaballos. As mentioned in the PS7 section above, six out of the 32 communities are recognized as having Indigenous Peoples status, and the engagement process to be conducted with those communities is discussed in that section.
Since 2012 the Company has been engaging the Affected Communities, municipalities and local and national government agencies during early ESIA efforts and the alternative analysis. As part of this process the Company has conducted meetings with approximately 400 community representatives and over 55 meetings and workshops have been conducted with communities along the alignment to inform them about the project, gather information and consult them about the project. During these preliminary consultation efforts community representatives have expressed their interest in: i) potential benefits that the project can bring to the communities; ii) clarification about the Prior Consultation (Consulta Previa) process with IP communities; and iii) technical aspects and environmental issues. To date, no active opposition against the project has been identified.
The next phase of preparation of a comprehensive ESIA for the project will involve a process of Informed Consultation and Participation (ICP) with all directly Affected Communities, and additional measures will be implemented to ensure the FPIC of those communities identified as IPs. The Integrated Social Management Plan to be developed by the Company will describe the engagement process conducted to date for Olecar and provide a framework for future stakeholder engagement in accordance with PS1 and PS7.
Pacific Infrastructure: PI’s corporate ESHS policy reflects the Company’s commitment to stakeholder engagement in line with Colombian regulations, international good practices and IFC’s PSs. The Company will develop an Integrated Social Management Plan that will further detail de Company’s stakeholder engagement policy, principles and objectives, and provide a framework for stakeholder engagement related to SPPB, Olecar and any future project to be developed by PI.

Maria Paula Murra
Pacific Infrastructure
Vice President, Corporate Affairs
mailto:mmurra@pacinfra.com
+(57) 1 256 1033

Felipe Rodriguez
Pacific Infrastructure
Administrative Director
mailto:frodriguez@pacinfra.com
+(57) 1 256 1033

IFC has determined that there is overall Broad Community Support (BCS) for the assets being developed by Pacific Infrastructure that were more reasonably defined at the time of IFC’s due diligence, namely Sociedad Portuaria Puerto Bahía (SPPB) and Olecar. IFC’s determination of BCS took into account: i) the level of community engagement conducted to date commensurate with the different stages of development of these two main assets; and ii) the review of project documentation and the applicable Colombian regulatory framework. In the case of the SPPB, a comprehensive ESIA and stakeholder engagement process has taken place, as described under the PS7 and the Stakeholder Engagement Sections above, which has included a successful process of Free, Prior and Informed Consent (FPIC) with the directly affected five (5) Afro-Colombian Communities. IFC interviewed representatives of these communities who voiced their support for SPPB. Construction of Olecar is not expected to start until the 1st quarter of 2014 and a comprehensive ESIA process is just starting. However, the community engagement efforts conducted to date by the Company as part of the alternative analysis (DAA- Diagnóstico Ambiental de Alternativas) and the initial engagement efforts related to the ESIA do not indicate any active opposition for the development. As part of its regular supervision of the Project, IFC will verify that the Company conducts a process of Informed Consultation and Participation (ICP) with the non- indigenous communities as per PS1 and a process of Free, Prior and Informed Consent (FPIC) as per PS7 with those communities with Indigenous Peoples status. *ICP - Information Consultation and Participation **BCS - Broad Community Support

Title	Anticipated completion Date	Status	Comments	Completion Date
Develop and implement an integrated corporate-level environmental, social and health and safety management system (ESHS –MS)	07/01/2013 12:00:00 AM	Completed	Completed	11/01/2013 12:00:00 AM
Integrated Social Management Plan (ISMP) covering stakeholder engagement and IP issues as per PS1/PS7	04/03/2013 12:00:00 AM	Completed	Completed	05/01/2013 12:00:00 AM
Hire an external Environmental and Social Advisory Consulting Firm (ESAC) to monitor and confirm sub-project’s compliance with PI ESHS Policy, ESHS-MS, and IFC PS	04/03/2013 12:00:00 AM	Completed	Completed	04/01/2014 12:00:00 AM
Olecar – ESIA and E&S Management Program (including Program to include: PS1/PS7 Social Management Plan, Land Acquisition and Resettlement Plan, Emergency Response Plan, and Security Forces Management Plan, among other) compliant with local regulations and IFC PSs.	11/01/2013 12:00:00 AM	Completed	Completed	12/01/2013 12:00:00 AM
Completion Audit of Land/Easement Acquisition by a qualified third party.	12/15/2017	In Progress	In Progress