While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts that must be managed in a manner consistent with the following Performance Standards (PS):

PS1: Social and Environmental Assessment and Management;
PS2: Labor and Working Conditions;
PS3: Pollution Prevention and Abatement; and
PS4: Community Health, Safety and Security.
The Project will have no adverse impacts related to PS5: Land Acquisition and Involuntary Resettlement. The Equatoria Tower site is the property of the CEIC and was previously occupied by employees of that government department. CEIC relocated the employees to other government housing and has contributed the site as part of its investment in the UAP Properties Ltd. joint venture. The site is located within the central business district of Juba, which has been an active commercial center for decades. As such, the Project will have no adverse impacts related to other Performance Standards (i.e., those relating to Biodiversity, Indigenous Peoples and Cultural Heritage).

Equatoria Tower is a category B project according to IFC’s Policy and Performance Standards on Environmental and Social Sustainability because a limited number of specific environmental and social risks and possible impacts that may result from its construction and operation can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Key risks and issues associated with this Project relate to the Company’s capacity to: i) undertake adequate social and environmental assessment of both construction and operation of the Project; ii) manage the environmental, health and safety performance of its contractors in accordance with good international practice; iii) consult and engage with project-affected communities in accordance with local requirements and IFC Performance Standards commensurate with the project’s impact; iv) ensure that the design and construction of all facilities accords with recognized building standards, as well as an internationally accepted life, fire and safety standard; v) ensure fair, safe and healthy working conditions during construction and operations for direct employees as well as for the contract workers; vi) ensure proper handling of hazardous materials, and management of wastewater, solid and hazardous waste during construction and operations; vii) consideration of energy efficiency and resource use in building design, construction and operations.

The Company has presented plans to address the environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with local laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow.

PS1: Social and Environmental Assessment and Management System
IFC’s assessment considered: the Company’s management of its environmental, health and safety performance in the establishment and operation of its facilities; and compliance with national and local permitting requirements.

Social and Environmental Assessment
The Ministry of Environment of the Republic of South Sudan has yet to formulate policies and enact regulations for the environmental impact assessment (EIA) of capital development projects in the fledgling country. As a precaution, the Company engaged a Kenyan EIA consultant to undertake and environmental assessment of the Project in accordance with the requirements of the Kenyan National Environmental Management Authority. This EIA provides an analysis of the Project’s environmental, health and safety impacts and requisite negative impact mitigation measures in a manner consistent with the requirements of the IFC Performance Standards. The analysis serves as a basis for a detailed Environmental Management Plan, included in the EIA, to be implemented by Project Management during the construction and operation of the Equatoria Tower.

Environmental and Social Management
The Company’s social and environmental management efforts to date have been undertaken on a development-by-development basis, and there is now a need to develop a more systematic approach reflective of the increasing scale and ambition of the Company. UAP Properties Ltd. will develop a social and environmental policy statement covering its future business activities and committing that these will be developed and operated in a manner consistent with good international environmental, health and safety practice in the real estate development industry.

The Project’s Environmental Management Plan (EMP) defines the responsibilities of the building contractor (construction) and property manager (operations). The EMP includes plans for management of noise and vibration, air quality, soil and water quality, solid waste, hazardous materials, (within site) transport, health and safety, and emergency situations. In support of the EMP, CATIC, the building contractor, has prepared a health and safety plan.

Project-level environmental and social management has been contractually assigned as the responsibility of CATIC, the building contractor for Equatoria Tower. Company''s monitoring of the Project’s EMP is one of the responsibilities of the Company’s construction Project Manager. This responsibility will be exercised by the Project Manager’s on-site Clerk of Works, who reports regularly to the Project Manager. In addition, the Company will engage a qualified environmental consultant to monitor the building contractor’s compliance with the EMP. The Company will submit these quarterly monitoring reports to IFC.

In anticipation of future property development, UAP Properties Ltd. will designate a corporate-level officer to be responsible for the Company’s adherence to the environmental and social policy and who will report to the Company’s Managing Director. The officer’s tasks will include development of corporate specifications to be used in future invitations to tender for construction work and property management, and enforcement of these specifications through the monitoring of building construction and operations by contractors.

PS2: Labor and Working Conditions
IFC’s review considered project construction and operations with regard to fair, safe and healthy working conditions.
Human Resources Policies and Procedures
UAP Holdings employs 326 people in management, sales and service operations spread across Kenya, Uganda and South Sudan. The future employees of UAP Properties Ltd. – the Equatoria Towers sponsor – are subject to the Human Resources policy and procedures established by UAP Holdings. These policies and procedures are detailed in the UAP staff manual, which is provided to each new employee on induction. These policies and procedures are further harmonized with the employment regulations of the countries in which UAP Holdings operates. UAP Holdings employment practices are broadly consistent with IFC’s Performance Standards. UAP Holdings employees are free to join labor unions and the Staff Manual prohibits discrimination in hiring. UAP Holdings minimum age of employment is 22 years.

Working Conditions and Terms of Employment
UAP Properties Ltd. has contracted the construction and will contract the operation of Equatoria Tower to independent contractors. Until detailed labor regulations are promulgated by the Government of South Sudan, the Company will require its building contractor CATIC and the Project’s property manager (to be nominated) to hire and employ workers on terms and conditions established in the Kenyan Labor Relations Act and Regulations of Wages Act, which themselves are consistent with, at a minimum, the Core Labor Standards established by the International Labor Organization.

CATIC estimates that it will directly employ up to 30 Chinese nationals as building, mechanical and electrical engineers and construction foremen during the construction of the Project. These employees will be accommodated in pre-fabricated housing that has been constructed on the Project site. CATIC’s subcontractors – civil works, mechanical and electrical – will be responsible for hiring and deploying laborers on site. CATIC estimates that up to 100 workers will be employed by sub-contractors during the two year construction period. Skilled workers (equipment operators, masons, electricians) are typically recruited from Kenya, Tanzania and Uganda but the Company has imposed a requirement for 30 percent of the workforce to be recruited locally. Non-resident worker pay packages will include an allowance for rental accommodation in Juba.

The Equatoria Tower property manager will sub-contract operations, maintenance and security services from Juba-based service providers. No estimates are currently available for the direct and indirect employment generated by the Project’s operations.

Occupational Health and Safety (OHS)
CATIC enforces corporate standards for OHS on its construction sites that are consistent with good international practice in the construction industry. On site work safety is the responsibility of the construction foreman, and CATIC deputes one foreman for every ten workers. CATIC has prepared an on-site Safety and Health Plan that outlines the roles and responsibilities of its personnel in managing OHS, including training, awareness raising, site monitoring, accident reporting and corrective action protocols. UAP Properties Ltd.’s construction manager will monitor CATIC’s safety performance as part of the Company’s reporting requirements to IFC.

The Equatoria Tower property manager will be required to develop OHS policies and procedures for the operations and maintenance of the building.

PS3: Pollution Prevention and Abatement
IFC’s review considered the Company’s management of resource use, and waste emissions, discharge and disposal on the surrounding human and natural environment during construction and operations.

Energy Efficiency and Greenhouse Gas Emissions
UAP Properties Ltd. engaged a reputed Nairobi-based architectural firm to provide as safe and resource efficient a design for the Project as the limited availability of materials, equipment and furnishings in South Sudan allow. This approach has been documented in a “Green Building Statement for Equatoria Tower.” The building design includes maximizing of natural ventilation and natural light in public areas, the use of LED and compact fluorescent artificial lighting throughout the building, the use of Low-e glass in all windows and insulation in the walls, ceilings and floors to reduce the amount of air conditioning required to cool the building, and minimizing the use of finishes containing volatile organic compounds. The architects have made provision for solar water heating, rain water harvesting, water efficient dual-flush toilets, automatic sensing water taps and flushing mechanisms and recycling of treated grey water for toilet flushing and irrigation. Building operations are estimated to require 3.9m3 of water per day or approximately 5 liters of water per m2 of built up space. This rate of consumption meets benchmarks established by the British Standards Institute.

In the absence of reliable grid power, Equatoria Tower will be equipped with three 1,000 kVa prime rated synchronized diesel generators. Building operations are estimated to consume to 1.65 MWh of electricity per year or an average of 212 kWh per m2 of occupied space. This rate of consumption meets benchmarks established by the United Kingdom Institute of Electrical and Electronics Engineers (IEEE).

The greenhouse gas footprint of Equatoria Tower operations is estimated in the range of 2,300 tons per annum CO2 equivalent inclusive of emissions related to electricity generation, air conditioning and solid waste disposal.

Liquid effluents
Equatoria Tower will be equipped with and on site mechanical wastewater treatment plant to receive and treat all liquid wastes generated by the building’s operations to World Health Organization effluent standards. Treated wastewater will be recycled for use in toilets and for irrigation and the balance will be discharged to the property’s storm water drainage system.

Air Emissions
Air emissions will arise as exhaust from three 1,000 kVA diesel generators housed in the building for back-up electrical power. The Company will procure generators that are rated to be compliant with World Bank Group (WBG) General Environmental Health and Safety Guidelines emissions guideline values. The Project’s property manager will monitor and report emissions to IFC.

Solid Waste Management
Solid waste generated in building operations will be gathered in a service area, compacted, and removed by authorized contractors. The building’s property managers will promote and facilitate recycling among all tenants.

PS4: Community Health, Safety and Security
IFC’s review considered the Company’s capacity with regard to the management of the impacts of the operation of its facilities on the health, safety and security of surrounding communities.
Life and Fire Safety
The Equatoria Tower has been designed by in accordance with Kenyan building codes. All materials specified in the works comply with Kenya Bureau of Standards, the Rwandan Bureau of Standards and the United UK IEEE standards for electrical and mechanical works, as well as with all applicable local regulations. The building design accommodates self-contained fire fighting capacity including a 200,000 liter capacity dedicated water supply, hydrants and dry risers throughout the building, and fire and smoke detection systems connected to a central monitoring station. UAP Properties Ltd. will provide a formal statement from a fire safety professional confirming that the building meets all applicable British fire safety codes.

Water Quality
Potable water for the property will be sourced from an on-site bore hole and treated via a filtration and reverse osmosis process installed on the property to meet an anticipated requirement of 40,000 liters per day. The Project’s property manager will engage an independent laboratory to sample and test the quality of this water on a regular basis against international standards of potable water quality.

Emergency Preparedness and Response
The capacity of the Juba Municipality to provide emergency fire fighting and disaster management services in the case of emergency is limited. UAP Properties Ltd. will be required to engage a fire safety professional to assess the capacity of local authorities to respond to fire and other emergencies. In the absence of adequate capacity, the professional will prepare and emergency response plan to be adopted and periodically tested by the Project’s property management contractor.

Security
UAP Properties Ltd. will engage an established private security contractor to control access to the Project site during construction. The Company’s property manager will similarly engage a private security company to maintain the security of the building’s physical plant and tenants. The Company’s property management contract will reference the requirements relating to engagement of private security forces.

In the absence of statutory requirements of public notice and consultation related to capital development projects, the Company’s engagement with local communities has been confined to liaison with municipal authorities for licensing and permitting of development activities. UAP Properties Ltd. will designate an individual to serve as community liaison and the name and contact details of that individual will be posted at the Equatoria Tower construction site.

This summary will be made available for public review at the following locations:

Project Site at the Corner of Hai Neem Road and Unity Avenue, Juba

UAP Insurance South Sudan Limited
UAP Plaza, Cinema Road
Opposite Children’s Hospital
Juba, South Sudan

For further information about the project please contact:

Mr. Patrick Kanyingi, Managing Director
UAP Insurance South Sudan Limited
UAP Plaza, Cinema Road
Opposite Children’s Hospital
Juba, South Sudan

Telephone: 0959 000 000
Email: mailto:pkanyingi@uapsudan.com


Mr. Dominic Kiarie
Deputy Group Managing Director
UAP Holdings Limited,
Bishops Garden Towers, Bishops Road,
P.O.BOX 43013-00100, Nairobi, Kenya
Telephone: +2542850000
Fax:+2542716798
Email: mailto:DKiarie@uap-group.com
Website: http://www.uap-group.com

Title	Anticipated completion Date	Status	Comments	Completion Date
UAP Properties Ltd. (the “Company”) will develop and disseminate within the company an environmental and social policy statement consistent with the corporate policy of UAP Holdings.	09/30/2012	Over Due	Under discussion with IFC client
The Company will designate a corporate-level officer to be responsible for the Company’s adherence to the environmental and social policy who will report to the Company’s Managing Director.	09/30/2012	Over Due	Under discussion with IFC client
Unless and until the Government of South Sudan develops comprehensive Environmental and Social Impact Assessment (ESIA) requirements for the construction and operation of development projects, the Company will develop generic terms of reference for ESIAs of future greenfield property development projects that meet the requirements of the Performance Standards.	09/30/2012	Over Due	Under discussion with IFC client
The Company will establish a system for implementation of the Environmental Health and Safety (EHS) provisions of the Project’s Environmental Management Plan to include the following:i. Designate, train and empower a site manager to ensure contractor compliance with the EHS provisions related to the construction of the Project, including impacts of construction on communities surrounding the Project site.ii. Engage an external EHS consultant to review the compliance of the building Contractor and related sub-contractors to the EHS provisions.iii. Ensure that the nominated Property Manager incorporate and adhere to the EHS provision in the operations of the Project as a condition of the Property Management contract.	10/31/2012	Over Due	Under discussion with IFC client
The Company will post a notice at the Project construction site providing a name and contact information for a designated official with whom the public can lodge complaints related to construction activities (e.g., noise, dust, reckless driving, etc.)	09/30/2012	Completed	Completed	09/30/2012
Unless and until detailed labor regulations and standards are promulgated by the Government of South Sudan, the Company will commit to require its construction and operations contractors to apply labor and working conditions standards (including occupational health and safety standards) that meet the requirements of the Performance Standards.	09/30/2012	Completed	Completed	09/30/2012
The Company, through its nominated property management contractor, will monitor and report air emissions from the diesel generators providing electricity to Equatoria Towers on an annual basis to IFC in an Annual Monitoring Report. If emissions from any generator exceed WBG EHS General Guideline values corrective action will be taken and reported to IFC.	10/31/2013	Over Due	Under discussion with IFC client
i.The Company will provide a formal statement from a qualified fire safety professional confirming that the fire safety aspects of the design and operation of Equatoria Towers meet the requirements of the life and fire safety section of the WBG EHS General Guidelines, i.e.: compliance with all local fire safety requirements and the requirement of an internationally recognized fire safety code.ii.If such a statement cannot be made available, then an audit will be undertaken by a fire safety professional which will either confirm compliance as (i) above or list corrective actions to be taken to bring about compliance.iii.If corrective actions are required, a timetable for their implementation shall be agreed between IFC and the Company.	09/30/2012	Over Due	Under discussion with IFC client
i.At the completion of construction and handover of the building to the operator, the fire safety professional will confirm that the building was constructed and will be operated in accordance with design and thus, in its as-constructed condition, meet the requirements of the life and fire safety section of the WBG EHS General Guidelines.ii.The Company will commission the same qualified fire safety professional to assess the capacity of local authorities to respond to fire or other emergencies. In the absence of adequate capacity, the professional will prepare and emergency response plan to be adopted and periodically tested by the Project’s property management contractor.	10/31/2013	Over Due	Under discussion with IFC client
The Company, through its nominated building management contractor, will institute a program of quality testing for potable water available in Equatoria Towers.	10/31/2013	Over Due	Under discussion with IFC client
Ensure that the nominated Property Manager incorporate and adhere to the EHS provision in the operations of the Project as a condition of the Property Management contract.	10/31/2013	Over Due	Under discussion with IFC client