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

This is a Category A according to IFC’s Environmental and Social Review Procedure (ESRP) due to a number of potential significant and irreversible impacts of the Project which include:
Social and economic and cultural effects on living conditions for nearby rural settlements and towns due to the influx of over 4,500 workers during the construction phase of the project which is expected to last 3 years. This includes risks of impacts to the IP population within the Project’s direct area of influence and potential effects of construction employment on worker availability for other local agro-industrial activities;
Permanent change to the landscape from its current rural characteristic into an industrial setting;
Temporary increase in traffic risks from increased flow of heavy trucks, personnel and machinery during the 3-years construction period and permanent increase in traffic risks from the increased flow of trucks to and from the facility for the delivery of raw materials during operations;
Changes to air and water quality in the vicinity of the project site during the operational phase; and
Potential impacts to archeological resources.

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.

Policy
Klabin has developed and adopted a Corporate Sustainability Policy with the input from all sectors of the Company. The Policy, which has been formally approved by the Company?s Board of Directors, outlines the following objectives:
Seek competitive quality, aiming at sustained improvement of results, continuously perfecting processes, products and services so as to meet the expectations of customers, employees, shareholders, communities and suppliers.
Ensure supply of its industrial units with wood from planted forests, in a sustainable way and without any damage to either natural or associated ecosystems.
Exercise and promote the recycling of pulp fiber in its production chain.
Prevent and avoid pollution by means of reducing environmental impact from effluents, solid wastes and emissions to air.
Promote employees? personal and professional advancement, and to strive for continuous improvement of their working environment, health and safety.
Exercise social responsibility with a focus on the communities where the Company is present.
Comply with laws and regulations applicable to product, environment, health and safety.

At the corporate level, Klabin is also involved in a series of industry initiatives to promote biodiversity conservation, through forestry and agribusiness sector industry programs, and through more than 10 company-led thematic conservation activities taking place in the Company?s own forest lands in Paran? State, Brazil (http://www.klabin.com.br/pt-br/sustentabilidade/default.aspx).

At the project level, Klabin has developed a comprehensive management system covering labor, environment, health and safety as defined in the Management Normative of Puma Project development (Normativa de Gerenciamento de implanta??o do Projeto Puma, in Portuguese). This document defines management responsabilities of the site construction, labor aspects such as HR department, recruitment, terms of employment, benefits policy, leave, mobilization and cadaster of workers, internal grievance mechanism, engagement with unions, subcontracting, uniforms, Environmental Health and Safety (EHS), security personnel, life and fire safety, emergency response, among other things.

Identification of Risks and Impacts
Brazilian environmental regulations require the preparation of detailed environmental and social impact assessments (ESIAs) as part of a stepwise environmental licensing process applicable to major industrial activities. In the State of Paran?, the Environmental Institute of Paran? (Instituto Ambiental do Paran? (IAP)) is the entity responsible for reviewing ESIAs prior to issuing Preliminary License (Licen?a Pr?via or LP) and Installation License (Licen?a de Instala??o or LI)) required prior to the start of construction activities of any major projects. This is followed by the issuance of an environmental operating license (Licen?a de Opera??o or LO) issued after regulatory inspection of the fully constructed project, just before initiation of operations. Prior to issuing the respective environmental license, IAP is responsible for requesting comments on the ESIA from other public agencies with environmental or social competencies including those agencies responsible for the regulation of agriculture, water resources, public services, and Indigenous Peoples, among others. Input from these public agencies must be considered in IAP?s decision to issue an environmental license, including any relevant input for inclusion in the terms and conditions of such license.

An environmental and social impact assessment (ESIA, or EIA in Portuguese) was prepared as part of the Brazilian environmental permitting process of the Klabin?s Puma Project. The ESIA was prepared by the consultancy P?yry Brasil, in accordance with the terms of reference issued by IAP. The ESIA is dated April 27, 2012 and includes a list of proposed environmental, social and health and safety monitoring programs contained in the Plano B?sico Ambiental (PBA, environmental and social management plans).

The ESIA presents initial baseline studies for the main environmental and social aspects, including geology, soils, land use, water resources, flora, fauna, ichthyofauna, noise, air quality, traffic, cultural resources, and socioeconomic aspects of neighboring municipalities and communities. The socioeconomic baseline information is principally based on secondary data and regional statistics and includes information on demography, economy, main institutions and infrastructure services for some of the nearby municipalities.

The ESIA documented the Sponsor?s assessment of project location alternatives which included a series of environmental and social siting criteria, including the following location criteria: it should be located outside of indigenous land and environmental protected areas (e.g., federal or state parks, wildlife refuge, etc.); on modified habitat to reduce the need for conversion of natural habitat; in an area that allows for the preservation of a 500 meter riparian areas along rivers; in an area that allows for a 200-meter exclusion zone around railroad right-of-ways; in proximity to existing interstate and state highway and railroad systems; in proximity to a regional river with the capacity to supply water for the project; at least 10 km from major urban centers and at least 1km from major interstate and state highways to minimize visual impacts as well as to minimize impacts on traffic due to the large number of heavy trucks during construction and operation; in an area with socioeconomic conditions that would benefit from the creation of jobs; and in an area of favorable air quality and prevailing wind conditions to minimize impacts to the quality of air of urban centers. Through assessment of site conditions, three candidate sites were considered for a more in-depth analysis. The selected site was the one that presented the most favorable environmental conditions and had the potential to cause fewer potential social impacts.

The ESIA also considered potential cumulative impacts, mainly focusing on potential cumulative effects to air quality and water quality from planned Project emissions during the operational phase. The analysis included potential impacts to water quality to a newly created reservoir for a hydroelectric power project located about 50km downstream of the point of wastewater discharge in the Tibagi River, the Mau? Hydroelectric Power Plant, and has 361 MW of power capacity. Evaluation of impacts to ambient water quality and ambient air quality respectively considered the effects of wastewater discharge and atmospheric emissions from the existing Klabin pulp and paper mill in Tel?maco Borba which were included in the mathematical predictive models used in the evaluation.

IAP has issued both LP and LI outlining general project?s characteristics and defining specific conditions of the licenses that includes the implementation of all management programs (PBA ? Program B?sico Ambiental, in Portuguese) as defined in the ESIA, implementation of fauna monitoring program, conditions for native vegetation clearings during construction, threshold limits for noise, water and air emissions, continuous implementation of archeological assessment and chance finds during construction, re-habilitation of degraded areas and re-vegetation of Tibagi River riparian areas in the Direct Area of Influence of the Project, implementation of participatory monitoring program providing feedback to nearby communities during construction phase and first year of operations, among other requirements.

The Sponsor has also concluded additional ESIA as required to request the environmental licenses for the access roads and railway spur and for transmission line, this last one in a format of rapid environmental assessment (RAS ? Realt?rio Ambiental Simplificado, in Portuguese); that are being reviewed by IAP and will be further disclosed to communities following Brazilian licensing procedures and the Company?s stakeholder engagement program..
The Sponsor was the first company from the pulp and paper sector in the Americas to have its forests certified by the FSC? (Forest Stewardship Certification?), in 1998, and follows the FSC certification process requirements in the forest assets under its control. These requirements include an assessment of environmental impacts appropriate to the scale and intensity of forest management operations and the uniqueness of the affected resources. Assessments include landscape level considerations as well as the impacts of on-site processing facilities and are conducted prior to commencement of planting operations. Klabin has a Strategic Forest Sustainability Management Plan that includes forests Aspects/Impacts assessment and monitoring, based on an Impact Assessment Matrix framework. In addition, Klabin has conducted a specific study to assess impacts of wood transportation to local communities, mapping transportation routes, local communities, villages, Indigenous People and ?quilombolas? communities and small towns with potential exposure to adverse impacts of wood transportation from its forestry operations.

The Sponsor has complemented the ESIA for the pulp mill project with the following tasks:
Socio-economic baseline data on the livelihoods of families and workers directly affected by Land Acquisition, including a documented report on consultations, exante-expost conditions, compensation packages (as described below in PS5 section);
Completion of socio-economic baseline for the direct area of influence with special attention to the two closest communities to the cellulose plant site: Campina Dos Pupos and Lageado Bonito, small settlements (Augusta Victoria and others) and dispersed family units located nearby Klabin Puma plant, plantations and off-site project components;
Socio-economic baseline for the municipalities where workers camps will be located with special attention to Ortigueira, Reserva Ind?gena Queimadas and Imba? (quality of public services, housing, public safety and other socio-economic services likely to be affected by workers influx during project construction activities). The social baseline determination will include collection of current public health data with an emphasis on health issues associated with the influx of temporary project labor for the construction phase, focusing on cities where workers camps will be located and communities located in close proximity to the cellulose plant;

Klabin has developed an Environmental Management Program for the project (PGA ? Programa de Gest?o Ambiental, in Portuguese) covering construction an operational phases. This program follows all steps of the management cycle (Planning, Doing, Checking and Acting) and respective elements (policy, risk assessment, operational controls, resource management, training, management programs, documenting, monitoring and reporting.). These elements are referenced in Klabin?s corporate ESMS procedures. Going forward, as set forth in the ESAP, Klabin will enhance its Management Normative of Puma Project Development incorporating its corporate ESMS procedures (CO-PRO-MEA-001 ? Risk assessment; AM-PRO-SIG 0013 - Corrective actions; AM-PRO-SIG-005 ? Recording; and SMSO ? Guidance Book of EHS Minimum Requirements for Contractors) in the EHS (14.1) and OHS (18.1) sections respectively. Klabin will also include in Management Normative of Puma Project Development the archeological work and procedures during excavations and earthworks.

Management Programs
Klabin has a well-established corporate level environmental, health, safety and social (EHSS) management program with a detailed set of standard operating procedures applicable to existing manufacturing operations. Some of these operating procedures cover aspects related to the management of EHSS aspects applicable also to construction activities including, for example, management of contractors. The environmental management programs in Klabin?s existing manufacturing assets are certified under ISO 14001 international certification program and its forest assets are certified under the Forest Stewardship Council (FSC) certification process.

At the Project level, in accordance with the terms of reference issued by IAP and as part of the Project environmental permitting process, the Sponsor has presented together with the ESIA a list of the basic environmental, social, health and safety management plans and programs that will be implemented during construction and operation of the Project which include:
Environmental Management System
Environmental Plan for the Construction Phase
Construction Workers? Retrenchment Plan
Mitigations for Impacts to the Road System
Risk Management during Construction and Operation
Solid Waste Management during the Operational Phase
Effluent Management during the Operational Phase
Air Emissions Management during the Operational Phase
Environmental Education and Social Communication
Occupational Health and Safety
Local Workforce Training
Accessibility and Mobility for Individuals with Disabilities
Archeological Monitoring and Rescue of Archeological Sites
Environmental Compensation
Aquatic Fauna Monitoring
Fauna monitoring and Rescue
Social Monitoring
Noise and Vibration Monitoring during the Operational Phase
Water Quality Monitoring
Environmental Audits during the Operational Phase

A general framework of the above listed plans and programs that have been presented in the PBA and confirmed by IAP as part of the environmental licensing process, which will have to be submitted in complete form for approval by IAP prior to their implementation, as well as to meet the conditions of the operational license.

The Sponsor will complement the management plans from the PBA for the pulp mill project based on the results of the complementary socio-economic baseline assessment and other aforementioned assessment activities. Specifically, Klabin will enhance existing social monitoring program (Programa de Monitoramento Antr?pico, in Portuguese) including community health and safety indicators associated with construction and operations activities, such as traffic (trucks) accident rates, as well as public health indicators associated with the risks of influx of construction workers such as incidence of sexually transmitted diseases. Klabin will also develop active/periodic monitoring of social impacts of workers camps in Ortigueiras municipality, including observations of workers activities, especially during weekends, and periodic consultation with local authorities, local police office, worker?s camps neighbours and Indigenous People. Periodic feedback must be provided to key stakeholders as defined in Klabin?s Stakeholder Engagement Plan (SEP).

Klabin will also develop specific management program, Impacts from Traffic Monitoring Program (Programa de Monitoramento de impactos do Tr?fego de ve?culos durante a constru??o) to monitor traffic safety conditions, dust and noise emissions from traffic during construction, including periodic field inspections and consultation with identified affected communities/receptors.

Klabin has a Forest Management Plan appropriate to the scale and intensity of operations that includes: management objectives; description of the forest resources to be managed; environmental limitations; land use and ownership status; socio-economic conditions and a profile of adjacent lands; provisions for monitoring of forest growth and dynamics; environmental safeguards based on environmental assessments; plans for the identification and protection of rare, threatened and endangered species; maps describing the forest resource base including protected areas, planned management activities and land ownership; description and justification of harvesting techniques and equipment to be used. Potential environmental impacts identified during assessments are considered during planning and operations ensuring that adverse impacts are avoided or mitigated. Klabin has a framework of Standard Operational Procedures (SOPs) defining acceptable E&S practices for forest management to meet or exceed national or regional best practice requirements and FSC requirements. Timely corrective actions are considered and implemented to address both past and potential non-conformances. Corrective Action Requests (CARs) and their respective close out actions are recorded. Klabin also has specific E&S management programs such as waste management, Fauna and Flora management, rehabilitation of riparian areas and degraded land, mandatory OHS risk prevention and health monitoring programs.

Additionally, the Sponsor has completed the required environmental and social management plans for future project-related components (i.e. access roads improvements, new railroad line, and new energy transmission line) similar to those prepared for the pulp mill construction and operation. Going forward, as set forth in the ESAP, Klabin will elaborate a Land Acquisition and Involuntary Resettlement Plan (RAP) for both railroad and transmission line, consistent with Klabin?s own policies and IFC PS5 requirements, as described below in PS5 section.

Organizational Capacity and Competency
Responsibility for the management of environmental, health, safety and social (EHSS) aspects is formally assigned to corporate level vice presidents, directors, and facility managers according to Klabin?s Sustainability Policy. At the operational level in existing pulp and paper mills, responsibility for implementation of EHSS management programs is currently held by dedicated environmental supervisors respectively reporting to the corporate environmental manager and Sustainability and Communication Manager for Puma Project. Corporate management of EHSS and Sustainability aspects falls under the Sustainability and Communications Board. Labor and occupational health and safety management responsibilities are also formally assigned to Puma?s Project HR manager and operational levels to Project?s OHS coordinator and locally based OHS supervisors with additional safety technicians, physicians and nurses . Klabin?s forestry operations have a similar, parallel, EHSS organization.

In 2010, Klabin established a Sustainability Strategy that is fully operational for its Forestry Management Unit. The Company at its highest managerial level is currently engaged in the process of (i) integrating the sustainability strategy at the corporate level in a manner that encompasses all business units (forestry plantations, industrial plant, etc.) and (ii) establishing a Sustainability Committee at a sdenior management level. Klabin?s Administrative Counsel has already appointed a Planning Director responsible for extending the Sustainability Strategy to the corporate level.

For the purpose of the construction of the Puma Project, Klabin has created a dedicated integrated project management organization jointly headed by a Human Resources (HR) and EHS Management Administration Department with a Program Manager responsible for the execution of the Puma Project, including the implementation of all expansion-related environmental, engineering, safety, and social programs. The project management organization includes EHS and Human Resources coordinators responsible for the implementation of EHS and HR aspects of a project-specific ?Management Normative of Puma Project Development? (described in more detail below). The construction?s contractors will be also required to have an EHS and HR managerial structure with supervisors and technicians as required to monitoring EHS performance of the project. Klabin has contracted an EHS auditing company to monitor and verify EPC contractors? practices during construction in accordance with Klabin?s EHS policies and procedures, Brazilian legal requirements and project related management programs. This company will have 56 employees in the field, which in addition to Klabin?s and EPC contractors EHSS employees are expected to reach 300 staff during peak of construction.

Going forward, and for the purposes of the management of EHSS aspects of the Puma Project, the Sponsor has integrated all EHSS management of the Project under an EHSS team responsible for managing the project biophysical and socio-economic aspects in close coordination with those responsible for public information, community engagement, and land acquisition/leasing.

Training
Klabin has defined in the Management Normative of Puma Project Development mandatory induction training program for all construction workers covering general project information, such as safe traffic, access and control of access to the site, workers camps, internal grievance mechanism, Collective bargaining and workers? unions, abuse of alcohol and drugs, ergonomic, transportation arrangements, employment contracts, rules of conduct/behavior, personal hygiene, contact numbers, and 20 relevant topics of EHS (PPEs, preventive risk assessment, hazardous works and permitting for hazardous works, excavations, electrical systems and equipment etc?). As set forth in ESAP, Klabin will include specific guidance for workers hosted in the Company?s camps regarding good conduct and behavior within local communities and in interacting with IP community members.

Emergency Preparedness and Response (EPR)
In order to comply with Brazilian regulatory requirements, the Project will develop occupational health and safety plans and procedures applicable to construction activities which include emergency preparedness and response. As set forth in the ESAP Klabin will conduct a Quantitative Risk Assessment and Risk Management Program following Brazilian Requirements (S?o Paulo Estate standard CETSB p4.261). The Risk Management Program must include process safety information, periodic risk review assessment, process change management, integrity of critical systems, Standard Operational Procedures (SOPs), training program, accidents investigation procedure, emergency preparedness and response, and internal audits.
Klabin will also have to design and implement life and firefighting systems in accordance with Paran? Estate fire authority, as well as a trained fire brigade, emergency drills program, and lightening protection system. As a condition of the start of new plant operations, Klabin will get final verification and approval document from local fire department in a form of AVCB (Auto de Vistoria do Corpo de Bombeiros, in Portuguese).

Monitoring and Review
As a condition of the environmental license of the Project, and consistent with the corporate environmental and social management systems of the Company, Klabin has developed a comprehensive construction and operational phase monitoring EHSS monitoring programs as described above (management programs). Indicators of EHSS performance during the construction phase has been defined and include such aspects as total size of workforce, satisfaction surveys, general milestones and achievements, number of vehicles, local vs. migrant workers, training programs for local workforce and Indigenous People, OHS inspection program, accident rates, incidents and near misses, medical/ambulatory activity, types and volumes of generated wastes, among others. Going forward, as set forth in the ESAP, Klabin will include in the report key performance indicators (KPIs) from all applicable management programs, such as air quality, environmental noise, wastewater discharge quality, and, and flora and fauna in areas with impacts to natural habitats.

Operational activities at the pulp mill will be monitored for key environmental and OHS indicators currently applied to the other manufacturing operations as well as any other defined by the local regulatory agency as part of the environmental license. These are likely to include atmospheric emissions quality, wastewater effluents quality, and solid waste generation, as well as ambient air and water quality and noise.

As part of existing forestry assets, Klabin has an E&S Monitoring program, under its Strategic Forest Sustainability Management Plan, to assess the condition of the forest, yields of forest products, chain of custody, management activities and social and environmental impacts. The E&S monitoring framework is based on Aspects/Impacts indicators matrix and includes stakeholder participation. Field inspections are conducted during, harvesting, silvicultural practices, and biomass processing. Results are collected in the field and recorded on a computer database system. As a FSC certified unit, Klabin follows a system of internal and external audits to ensure consistency with FSC standards requirements.

Klabin has a specific monitoring system for labor and OHS legal requirements based on review of legal documentation and field inspections of Klabin?s and contractors? at forests operations. Field inspections are conducted quarterly and are based on checklist verification of compliance with labor and OHS legal requirements. Documentation demonstrating compliance with training programs, accidents rates and investigations, safety conditions of transportation buses and other OHS aspects are sent on a monthly basis. OHS results are reviewed and discussed within Klabin?s or Contractors? OHS committee, as appropriate. Labor aspects, such as payment of social security fees, compensation payments under agreed deadlines, meal supply and quality are reviewed and non-conformities are communicated to contractors to be resolved. Corrective actions are identified in the contractors? management system and are monitored until completion. Forestry operation as further audited as part of the FSC certification process and identified deficiencies and monitored until proper completion of corrective actions.

Forestry management activities presently include monitoring of fauna and flora indicators following recommendations from a study conducted by NGO ?Casa da Floresta?, which includes a schedule of monitoring of High Value Conservation Forests located within Klabin?s land holdings. Klabin also monitors environmental indicators of water resources in the two river basins where forest assets are managed.

As described above, the Sponsor will revise its social monitoring program of community health and safety indicators associated with construction and operations activities such as traffic accident rates, as well as public health indicators associated with the risks of influx of construction workers such as incidence of sexually transmitted diseases. As defined in the Puma Project?s management programs, the Sponsor will also develop and implement a monitoring program which includes monitoring of groundwater quality, surface water quality, and air quality during the construction and operational phase of the project.

External Communications and Grievance Mechanisms
Klabin uses several public information mechanisms such as periodic community meetings, distribution of printed materials and radio news to ensure that the local communities are kept up to date with the project progress. For the Puma Project, Klabin is developing a Social Communication Program aimed at reducing doubts, distrust and rumors and to manage expectations. The PBA states that the Project will be required to implement an Environmental Education and Social Communication Program with the commencement of construction activities. The aims of this program will be to provide reliable project-specific information to the community and also as an on-going channel for interaction with community members.

In addition, Klabin has developed and implement an external Community Grievance Redress Mechanism for Puma Project called ?talk to Klabin? (fale com a Klabin, in Portuguese), including different means of communication, such as an email adress, free phone line and suggestion boxes distributed in 32 points within the area of influence of the project. Going forward, as set forth in the ESAP, Klabin will develop a formal procedure to receive record, treat and respond to grievances in accordance with IFC PS1 requirements.

On-going Reporting to Affected Communities
Public reporting requirements in Brazil are defined on a project-specific basis and this will be the case with the proposed Project which is still in the process of regulatory approvals. Key E&S indicators are gathered in managerial reports and internally disclosed as needed. Klabin also discloses annually relevant E&S information and indicators to the public under the sustainability reporting standard of the Global Reporting Initiative (GRI), available at their website (ri.klabin.com.br/static/ptb/arquivos/RelatoriodeSustentabilidadecompleto.pdf). The external reporting is performed on an aggregated basis for their operations in Brazil, and covers the following topics: Certification status of forestry and manufacturing operations (per ISO and FSC standards); Stakeholder engagement programs; Number of employees with information about functional categories, and distribution by contractual status, sex, and race; Functional training hours by category of employees; OHS accident rates (frequency and severity) for own employees and subcontractors, including total number of lost work days; Carbon footprint; Processing of recycled paper and paperboard in manufacturing business; Energy consumption by fuel type; Water consumption (including recycling rates); Waste and effluents (in absolute volumes); Recycling; and Biodiversity conservation (including number of identified species under conservation status).

Klabin quarterly reports to IAP on the results of existing Social Monitoring Program, which includes a summary of all communication and engagement activities with relevant stakeholders. Going forward, and as required in the Environmental License (LP), the Sponsor will develop and implement a Project-specific environmental and social reporting program for the communities located in the project?s direct area of influence. The community reporting program will disclose relevant indicators of environmental and social performance applicable to the Puma Project construction and operational activities.

Working Conditions and Management of Worker Relationship -
At the peak of the construction period, the Project will require a temporary work force of approximately between 8,600 and 9,000 workers qualified and skilled levels to perform the various phases of project construction. About 50% of the total construction workforce of the construction is expected to be employed locally and regionally from other cities of the State of Paran?. Worker camps will only house workers who live too far for daily commuting and total capacity for 4,600 workers during the peak of construction. The Sponsor will also make use of locally available hotel and housing rental space to house professional level staff. The Sponsor?s approach to the management of this large temporary workforce is described further below under the respective section of this summary.

During the operational phase, the Project will require an approximate direct labor force of 1,900 in the pulp mill. Forestry operations will require another 500 direct employees. The Company plans to apply its existing corporate human resources management system to the Project once it becomes operational. The Company communicates employee rights and responsibilities through a brief, publicly available, Human Resource Policy (http://www.klabin.com.br/pt-br/recursos-humanos/default.aspx) and in more detail through individual employment contracts, the Company Code of Conduct, and through collective bargaining agreements signed with local unions. The HR Policy outlines the Company?s commitment to the well-being of employees; key employment benefits, such as employee profit sharing, complementary pension plan, discounted drugs, dental assistance, and life insurance; focus on occupational safety; and leadership training, among others.

Individual employment contracts define such terms as salary or hourly rates, working hours, and payment schedule. The Company Code of Conduct defines some of the employer and the employee rights and responsibilities in such areas as relations between employees and external parties (i.e. community, clients, and service providers) in order to avoid conflicts of interests; use of drugs and alcohol; occupational safety; political activities in the workplace; and responsibility for the protection of the Company property.

IFC found no evidence that Sponsor restricts freedom of association of its employees. In Brazil, workers normally affiliate with local or regional labor unions organized to cover their specific industry activities. Operational employees in the Company?s pulp and paper mill in Tel?maco Borba are affiliated to the Union for Workers of the Pulp and Paper Industry (?Sindicato de Trabalhadores da Ind?stria de Papel, Celulose, e Pasta de Madeira? - http://www.sindicatodopapeltb.com/) a union specifically focusing on pulp and paper industries and an example of the type of unions available for future employees at the new pulp mill. In the case of Tel?maco Borba, the Company and the Union have signed a Collective Bargaining Agreement for the 2011-2012 period which covers key labor aspects such as: salaries; working hours; contracting and layoffs; labor stability; benefits, rights and responsibilities; occupational health and safety; workers organization and union relations; and contributions to the union. Klabin has also engaged in negotiations and collective agreements with unions during construction phase, which means that terms of collective bargains will have to be negotiated with worker?s unions and approved by directly by workers in open reunions (Assembleia de trabalhadores, in Portuguese).

The Company is also committed to the continued contribution to local economic development and plans to maximize the hiring of local labor for the construction and operational phases of the project. The Company is engaged with the government-sponsored National Industrial Service Training Institute (Servi?o Nacional de Aprendizagem Industrial ?SENAI?) representation in Tel?maco Borba to develop and implement training programs for regional residents interested in pursuing careers in the new pulp mill.

Klabin has been collaborating with government-sponsored labor agencies from local municipalities (Ortigueira, Telemaco Borba, Tibagi, Pontagrossa, Londrina and Curi?va), which are receiving CVs from local workers, and putting together a labor database for contractors that are encouraged by Klabin to use these sources for recruitment of its own workforce.

The Company actively encourages employees and managers to openly discuss and resolve conflicts. Employees are currently able to lodge complaints internally through the Human Resources department and Company management and externally through the public Labor Rights system (Justi?a do Trabalho). Due to the large number of workers during the construction phase, Klabin takes working environment very seriously to avoid generalized conflicts and potential stops or strikes. The Project Puma Management rules document defines expected labor practices for contractors, such as terms of employment, restrictions for subcontracting, engagement with worker?s Unions, migrant worker?s rights, remuneration policy and collective bargaining, leave and rest time, medical benefits, workers transport, supply of uniforms, food supply, among other things. In addition Klabin is implementing an internal grievance mechanism (ouvidoria, in Portuguese), available for all workers to better manage conflicts. As a set forth in ESAP, Klabin will create an internal grievance procedure defining the channels for placing grievances, as well as recording procedures, treating and responding to complaints.
Klabin has defined a set of HR measures described in its Management Normative of Puma Project Development to limit and avoid uncontrolled influx of workers across contractors. Klabin has put in place a web based database in which contractor?s feed with workers information and have to provide copies of required documents for verification (employment contract, admission and periodic medical exams, ID, address or accommodation site, copy of workers? labor booklet etc?) before Klabin issues individual access permission. Klabin has full control of access to construction site and contractors must demonstrate compliance with all requirements defined in the Project?s Management Normative. Klabin has developed a local labor pool database in collaboration with local labor agencies, and contractors must use this resource as a primary source for recruitment. Klabin has also defined geographic limitations for migrant workers, that can only be coming from immediate adjacent states from Paran? (700km from Ortigueira), meaning S?o Paulo, Santa Catarina, Mato Grosso do Sul and eventually Rio Grande do Sul. Klabin has engaged in a National Agreement to Improve Working Conditions in the Construction Industry that defines some rules for hiring migrant workers. Accordingly, and to avoid uncontrolled flow of migrant workers to Ortigueiras, construction contractors must only hire non local worker?s at their home town, and pay for all expenses of the transport from and to their home town when the work is finished. Contractor?s must inform regional Ministry of Labor office at workers home town and get a clearance document to be presented at Ortigueiras Labor office. All accommodations for migrant workers will be provided and controlled by Klabin and all workers must inform local address or accommodation site to get access permission. Accommodations for skilled professionals (hotels and town houses), normally permanent workers from contractors, must be informed and will be audited. Subcontracting is only allowed for temporary activities not considered core business of the contractor (a.e. air conditioning maintenance, fleet repair etc.)
Protecting the Workforce
Brazilian labor laws prohibit discriminatory practices and define minimum of age of work. The Sponsor complies with local requirements, supporting equal opportunity and non-discrimination in employment and requiring all prospective employees to demonstrate proof of age of 18 years or older.

Occupational Health and Safety
During the construction phase of the project, according to Brazilian legal requirements, the Sponsor and its contractors will be required to develop and implement a series of mandatory occupational health and safety (OHS) management programs, including:
Medical Surveillance Program (PCMSO, Programa de Controle M?dico e Sa?de Ocupacional);
Internal Commission for Prevention of Accidents (CIPA, Comiss?o Interna de Preven??o de Acidentes);
Personal Protective Equipment (PPE) Program; and
Environmental Risk Prevention Program (PPRA, Programa de Preven??o de Riscos Ambientais).

Klabin has an OHS Management Program that requires contractors do follow all Brazilian OHS Standards (Normas Regulamentadoras do Minist?rio do Trabalho), and implement specific management tools, such as:
Occupational Safety assessment of all activities;
Daily Occupational Safety Discussions
Permission for hazardous works
Internal OHS management system including Policy statement, verification and compliance with legal requirements, OHS objectives and targets, management programs, worker?s safety commissions, commitment, internal audits and forma procedures.
In addition, and as described above in PS1, Klabin will require conformity with its own EHS Guidebook for Contractors during construction phase.

During the operational phase of the Project, the Sponsor plans to implement plant-specific OHS management programs that comply with its corporate OHS Management System which is currently applicable to all of its operations in Brazil. The OHS Management System contains a comprehensive set of plans and procedures covering such aspects as:
Identification and assessment of potential OHS risks;
Over 40 OHS operational procedures including, for example: work in confined spaces; machine safety; potential exposures to radioactive energy sources; work in heights; electrical safety and lock-out-tag-out procedures; permit-required activities; handling of chemical substances etc.;
Training and training effectiveness review; and
OHS monitoring and the use and disclosure of the monitoring results.

Workers Engaged by Third Parties
During the Project?s construction phase, contractors will be legally bound to follow the Sponsor?s ?Contractors Human Resources Management Manual? and a ?Contractors OHS Manual? both of which outline local legal requirements and provide additional details about occupational illness and accident prevention procedures required by the Sponsor and which include minimum requirements to ensure that subcontractors? workers can integrate into the Sponsor?s own Safety, Health and Environmental (SHE) Program.

The Project?s Normative comprehensively outlines a series of Sponsor requirements to ensure that the workers engaged by Contractors are afforded minimum standard of labor rights and benefits. These include:
HR administrative structure with capacity for effective HR management;
Recruitment, selection, and contracting including requirements to focus on local labor sources to the extent feasible;
Mobilization and demobilization of migrant workers including payment terms;
Contract terms including definition of payment terms, working hours etc.;
Grievance process and rights to exercise freedom of association;
Accessory benefits including quality of temporary lodging, food etc.;
Emergency care (equipment and staffing requirements); and
OHS organizational capacity requirements (i.e. minimum number of OHS technicians and supervisors, among others).

The Contractors OHS Manual provides approximately 30 specific OHS procedures applicable to civil / mechanical construction works as well as OHS obligations specifically designed for a list of 20 different types of service providers. These manuals are also applicable to contracted service providers for existing Company operations and will be applied during the operational phase of the project to suppliers of products and services.

Based on the results of the socio-economic baseline and complementary assessment of impacts, the Sponsor will evaluate the risk of influx of project workers on public services (e.g. health, education, and utilities) and developed a Workers Influx Management Program. The program shall provide mitigation measures commensurate with the risk, including but not limited to: local worker recruitment plan to reduce the chance of unplanned camp followers, including procedures to identify who are local hires or not, in coordination with local public authorities; operation of local contracting office where workers will need to show verification of local residence; requiring contractors to provide minimum percentages of non-qualified local hires; actions to pursue gender balance, monitoring the potential pressure of worker influx in public services, and establishing formal agreements with local public agencies to ensure that corrective measures are implemented if pressure on public services is detected.

Supply Chain
The operation of the proposed pulp mill will depend on the continued supply of pine and eucalyptus wood to produce 1.1 million tons per year of eucalyptus based pulp and 0.4 million tons of pine based pulp. Wood will be supplied from sources located at an average of 72 km from the proposed pulp mill. Approximately 63% of the sourcing will be from the Sponsor?s own plantations, 10% from leased properties operated by the Sponsor, and another 27% from independent suppliers. The Sponsor currently supports a network of approximately 8,000 small plantation independent growers providing them with pre-financing, seedlings, and technical support. The Sponsor presently audits a small sample of the third party suppliers in order to comply with the FSC certification requirements for controlled sources of wood.

Management of Waste Streams
The proposed Project will be based on a Kraft pulping process and will apply technologies and practices that are consistent with Good International Industry Practice (GIIP) to minimize the generation of waste streams (i.e. solid waste, effluents, air emissions (including odors), noise/vibration) and their discharges to the environment as described below.

Solid Wastes - The Project will initially generate construction related solid wastes consisting primarily of wood and metal scrap, miscellaneous wastes from cafeterias and offices, and sanitary waste and sludge from portable toilets and onsite wastewater treatment facilities. During the operational phase, the proposed Project will generate significant quantities of solid wastes from the manufacturing process, including wastes from wood handling operations, dregs and grits from the causticizer, lime mud, biomass boiler ashes, empty chemical containers, and sludge from water and wastewater treatment processes. Non-process solid wastes will include packaging paper and cardboard, plastics, metallic scrap, fluorescent lamps and batteries, and miscellaneous wastes from mechanical maintenance shops and plant maintenance (including used oil, glass, tires etc.), cafeteria services, and medical services.

Solid wastes will be managed according to the Sponsor?s corporate procedures and Brazilian requirements during both the construction and operational phases. Wastes will be segregated by classification into hazardous and non-hazardous / recyclable and non-recyclable, stored and disposed of where applicable. Klabin?s corporate environmental management programs include detailed procedures for the selection and monitoring of waste management contractors providing transport, treatment, and disposal services.

Organic wastes from manufacturing processes, cafeterias, and sludge will be used to produce compost that will be sent back to forest planting locations. The Project site will include a 15 ha composting area built with surface drainage and a clay layer. Wood wastes will be burned into biomass boiler and ash, lime mud, and dregs/grits from the causticizer also will be sold as soil amendment (i.e. to reduce soil acidity and may also provide macronutrients such as phosphorus, potassium, calcium, and magnesium), under the authorization and supervision of Brazilian agricultural authorities. Paper, cardboard, plastic, metal scraps, glass, tires, and lubricant oil will be recycled by authorized contractors.

The Project will include the construction of an on-site landfill dedicated to plant operations. The landfill will be constructed for the disposal of Class IIA (non-hazardous, non-inert solid wastes in accordance with Brazilian Technical Norm ABNT NBT 10.004). Only those wastes that cannot be recycled will be disposed at the landfill. These wastes may include the sludge from the water treatment plant and from the wastewater treatment plant (WWTP) tertiary treatment. The landfill design will include 50 cm compacted soil layer, overlain by a membrane of high-density polyethylene. It will include a leachate monitoring system to detect potential leaks to the environment, and a leachate collection system. Leachate will be collected and transported to the on-site WWTP for treatment.

Wastewater ? The Project will include process measures to reduce organic loads in effluents during the pulping process which include:
Washing of the brown stock before the delignification;
Oxygen delignification before the bleaching;
Use of elemental chlorine free (ECF) bleaching with chlorine dioxide;
Collection and recycling of spent cooking liquors; and
Stripping and reuse of evaporation and digester condensates.

In addition, to prevent chemicals or untreated effluents from being discharged to the environment, the design of the Project include an emergency pond, which will store effluents that do not comply with the specified quality. The Project will have online monitoring of pH, temperature and conductivity. If the online monitoring detects values outside of the specifications, control valves will close and the effluent will be directed to the emergency pond. This pond will have a storage capacity of 100,000 m3 and would allow the pulp mill to operate for approximately 14 hours.

The Project will include the construction and operation of a wastewater treatment plant (WWTP) that will operate continuously and will include primary, secondary and tertiary treatments prior to the discharge of treated effluents to the Tibagi River via three underwater pipes with diffusers. The various treatments aim at the removal of solids, organic load, phosphorus, nitrogen, chemical oxygen demand (COD) and color. The Project will generate approximately 7,000 m3/h of effluent. The WWTP is being designed to meet the following discharge limits:

WWTP Design Levels
Parameter
Units
Predicted Value
IPPC BREF (2001)
WBG EHS Guidelines
Process water flow
m3/ADt
29-32
30-50
50
pH

6 ? 8

6-9
TSS
kg/ADt
0.706

1.5
COD
kg/ADt
5.645
8-23
20
BOD5
kg/ADt
0.353
0.3-1.5
1
AOX
kg/ADt
0.071
<0.25
0.25
Total N
kg/ADt
0.106
0.1-0.25
0.2
Total P
kg/ADt
0.007
0.01-0.03
0.03
Notes:
m3/ADt ? cubic meters per 1,000 kg of air dry pulp; kg/ADt ? kilograms of pollutant per 1,000 kg of air dry pulp; TSS ? Total Suspended Solids; COD- chemical oxygen demand; BOD ? Biological oxygen demand; AOX ? Chlorinated organic substance; N ? nitrogen; and P ? phosphorous; IPPC BREF ? European Union Integrated Pollution Prevention and Control Best Available Technique Reference Document (2001); WBG EHS ? World Bank Group Environmental Health and Safety Guidelines.

As part of the Project effluent quality monitoring program, untreated and treated effluents will be monitored to assess the efficiency of the WWTP and to ensure compliance with Brazilian standards. Effluent flow, pH, conductivity, and temperature will be monitored online. COD, suspended solids and settable solids and color will be measured on a daily basis. Biological oxygen demand (BOD) will be measured twice a week (at least). Total phosphorus and total nitrogen, oil and grease will be measured on a monthly basis. Heavy metals, sulfates, sulfides, chlorides, phenols, sodium, calcium and iron will be measured on a yearly basis. This monitoring program will begin at start of operations and will be conducted for the life of the Project.

The Project proposes to use three underwater discharge pipes with 33 diffusers. Based on preliminary simulations for wastewater discharge scenarios considering the Tibagi River?s average and low-flow conditions, project discharges will not have a significant impact on the quality of the receiving water which is presently categorized as a Class 2 water body (water suitable for human consumption following treatment) per Brazilian regulations.

The Sponsor has updated the dispersion modeling including simulations for Dissolved Oxygen, BOD, QOD, phosphorus and nitrogen, and in both scenarios of lowest river flow (Q7,10) and average flow was concluded that the the concentrations went back to same upstream level before reaching the water reservoir area and that river has self-depuration capacity to assimilate the wastewater discharge .

Atmospheric Emissions - The Project will employ chemical recovery processes to reclaim spent cooking chemicals used in the pulping process. Black liquor will be concentrated in multi-effect evaporators to 80% by dry solids before it is incinerated in the plant?s recovery boiler, as a measure to reduce sulfur emissions. Stripper systems will be used to treat the condensates generated during the evaporation of the black liquor. Methanol from the strippers will be removed in the methanol column and incinerated in the recovery boiler. Diluted and concentrated non-condensable gases from cooking, evaporation, foul condensate tank and methanol handling will be collected and incinerated in the recovery boiler. Gases from the dissolving tanks will be washed and injected in the recovery boiler. Combustion gases will be treated with high-efficiency electrostatic precipitators to control PM emissions.

The biomass boiler will use pinus and/or eucalyptus bark and will consist of fluidized bed technology. Combustion gases will be treated with electrostatic precipitator to control the emissions of PM.

The two lime kilns will be feed by loading and transportation systems that include dust removal technology. The lime kilns will use predominantly oil as fuel, but will also be able to burn turpentine, methanol, tail oil and hydrogen as auxiliary fuels. Lime kilns will have electrostatic precipitators to control the emissions of particulates.

Optimum operating conditions will be monitored online to guarantee best results in the air emissions released to the environment. The Project will have online monitoring of temperature, flow, pressure, humidity, excess oxygen, total reduced sulfur (TRS) and carbon monoxide.

In addition, the heights of the stacks are being designed according to Good Engineering Practice (GEP) to ensure best air dispersion and stack heights are as follows: Recovery Boiler ? 160 meters; Biomass Boiler ? 100 meters; and Lime kilns ? two stacks 100 meters each. The combined emissions from these three sources are estimated to be as follows:

Projected Stack Emissions
Parameter
Units
Predicted Value
IPPC BREF (2001)
WBG EHS Guidelines
TSP
kg/ADt
0.409
0.2-0.5
0.5
SOx as SO2
kg/ADt
0.332
0.2-0.4
0.4
NOx as NO2
kg/ADt
2.188
1.0-1.5
1.5-2.0
TRS as SO2
kg/ADt
0.054
0.1-0.2
0.2
Notes: kg/ADt ? kilograms of pollutant per 1,000 kg of air dry pulp; TSP ? Total suspended particulate; SO2 ? sulfur dioxide; S ? sulfur; NO2 ? Nitrogen dioxide; TRS ? total reduced sulfur compounds; IPPC BREF ? European Union Integrated Pollution Prevention and Control Best Available Technique Reference Document (2001); WBG EHS ? World Bank Group Environmental Health and Safety Guidelines.

Following licensing requirements, Klabin conducted preliminary air dispersion modeling using global weather models data (WRF ? Weather Research and Forecasting). Initial results suggest that the project atmospheric emissions will not have a negative impact on the regional airshed and that ambient air quality levels for the above parameters will remain well below applicable Brazilian ambient air quality standards. Klabin also conducted cumulative impact assessment considering emissions from existing plant in Telemaco Borba, and which concluded that emissions from Telemaco Borba site won?t intervene or overlap with Puma?s project emissions. Nonetheless, the Sponsor will deploy a meteorological station in the site and will collect data to update the dispersion modeling and confirm preliminary results .
The air emission monitoring program has been defined in coordination with IAP. The Air emissions control program defines the air emission monitoring approach, via stack tests, of carbon monoxide (CO), oxygen (O2), particulate matter (PM), sulfur dioxide (SO2), TRS and nitrogen oxides (NOx) on a semi-annual basis, and specific control measures described above to achieve compliance with Federal (CONAMA 382/06) and Estate Level (SEMA 54/06) threshold requirements

Noise Emissions ? The Project will generate significant levels of noise during construction and operations. The main sources will consist of transport related activities for daily transport of construction workers between the worker camps or the nearby cities and the construction site, and construction site civil works activities. During the operational phase, main sources of noise will consist of the transport of raw materials, mainly wood, from the plantations to the Project, wood harvesting operations, and pulp mill operations (i.e. log yard handling activities, power and process equipment noise, steam system purges, etc).

Noise prevention and mitigation measures considered in the ESIA include such aspects as the project siting in a rural area away from major population centers; purchasing of sufficient land for the construction of the pulp mill in consideration of the need for a sizable buffer zone to provide additional setback to nearby residents; installation of vibration isolation for mechanical equipment and acoustic enclosures for large pieces of equipment with high noise levels; use mufflers and other suitable devises on engine exhausts and compressor components; use of mufflers for materials transport equipment (during construction and operation); limitations of forest harvesting and wood transport activities as required by local law.

The Project proposes to monitor ambient noise levels at seven locations, which represent residential receptors. Noise monitoring will start at commencement of construction activities. Going forward, as described above in PS1 section, Klabin will also develop specific management program (programa de Monitoramento de impactos do Tr?fego de ve?culos durante a constru??o) to monitor dust and noise emissions from traffic during construction.

Hazardous Materials Management
During construction, the Sponsor and its contractors will be required to prepare and implement environmental management plans and procedures in accordance with the environmental license and Ministry of Labor and Employment?s Regulatory Norm (NR) 18, which establishes procedures and standards for construction sites. NR-18 requires the preparation of the Program of Conditions and Working Environment for the Construction Industry (Programa de Condi??es e Meio Ambiente de Trabalho na Ind?stria da Constru??o ? PCMAT). The PCMAT includes the preparation of an Environmental Risk Prevention Program (PPRA, Programa de Preven??o de Riscos Ambientais) and the implementation of hazardous materials storage and handling procedures and practices. These typically include dedicated fueling and chemical storage areas with secondary containment and the implementation of spill prevention and control measures.

During operation, the Project will require the use of various hazardous materials that will be transported to the Project site via trucks and which will be stored on site in designated chemical storage areas. A risk analysis was conducted as part of the ESIA to identify risks associated with the following hazardous materials (and proposed storage volumes): Sulfuric Acid (98% by weight, 750 m3); Sodium Bisulfite ( 100 m3); Caustic soda (50% by weight, 2,000 m3); Caustic soda (20% by weight, 350 m3); Hydrogen Peroxide (450 m3); Methanol (200 m3); Solution of Sodium Chlorate (1,200 m3); Chlorine Dioxide (10 g/L, 2,500 m3); Diesel (100 m3); and Fuel oil (4000 m3). The above listed chemicals are used at other pulp mills operated by Klabin and the Company has standard plans and procedures that will be used at the proposed Project site. The design of the Project includes measures for proper storage of hazardous materials, secondary containment for potential spills, spills response planning, and specific health and safety procedures and training for worker?s protection.

In the forestry management operations, Klabin currently uses three types of authorized herbicides for weed control based on field assessment of weed infestation and on a qualified agronomist prescription. Klabin also monitor ants? infestation and chemical control decisions are based on the economical level of control, consistent with IPM principles and IFC requirements. Klabin does not use pesticides within hazard class Ia or Ib according to WHO pesticides hazard classification system.

Greenhouse Gases
Because Klabin owns and operates many forest plantations of pinus and eucalyptus in Southern Brazil, the Company reports that its carbon sequestration capacity exceeds emission of GHG released at pulp and paper mill facilities and the project will also co-generate energy from biomass for own consumption and to be sold to the grid.

Klabin has complement the GHG impact evaluation included in the ESIA with a project-specific analysis of potential GHG emissions for the Project, taking into consideration temporary direct and indirect emissions from the construction and operational phases (Scope 1,2 and 3 of the World Resources Institute (WRI) GHG emissions estimation methodology. Results show that emissions from construction phase are 3,804 ton of CO2 eq and annual emissions of 2,521,727 ton of CO2 eq during operations.

Infrastructure and Equipment Design and Safety
Potentially community health impacts are related to dust and noise due to the movement of heavy equipment, materials and project personnel during construction and heavy trucks with raw and processed materials during operation, affecting the population of rural villages and settlements located within a few kilometers away from the cellulose plant. To avoid/minimize risks on public health and disturbance in living conditions associated with construction/operation activities, the Sponsor has set in place specific programs and preventive/mitigation actions, including: earth roads pavement and watering, noise monitoring and vehicle/machinery controls.

Potential community safety risks are related to increased vehicular traffic and the potential for accidents involving both humans and domestic animals. To avoid/minimize risks associated with its vehicular movements, the Sponsor has set in place safety programs and preventive mitigation actions including: road signals, vehicle control, safety and defensive driver training and sanctions for traffic violators.

Forest operations can affect communities? health and safety primarily due to the risk of impacts from wood transportation, from tree falls during storms or harvesting, and due to forests fires which can represent a risk to nearby households or communities. Klabin has a series of operational procedures applicable to planting and harvesting operations including increased setbacks of plantations from residential buildings to avoid accidental tree falls during harvesting or due to natural storm events. The Company also has procedures for contractors conducting harvesting and transport activities that include driver safety requirements in transportation of wood. Klabin also has a well-structured forestry fire prevention plan that includes watch towers, radio communication, meteorological monitoring, permanent terrestrial monitoring, training, fire fighting trucks and a network of water supply points for fire fighting. Klabin?s fire brigade relies on 36 direct employees and 50 other employees from contractor?s fire fighting teams.

Hazardous Materials Management and Safety
Klabin plans to have contractual terms and conditions for contractors transporting hazardous materials during the construction and operational phases of the project requiring them to have: valid environmental license for the transportation of hazardous materials; specific driver?s license to drive trucks containing hazardous materials; contractors must have valid agreements with emergency response companies that provide 24/7 services; hazardous material loads must be accompanied by material safety data sheets (MSDS) and trucks must have emergency response equipment in case of a spill. Spill prevention and response planning at the pulp mill site will include procedure for response to accidents involving hazardous materials within or near the Project site.

Ecosystem Services
The total water availability within the Tibagi River Basin is estimated at 32 million m3/day. Water uses of this river system include about 41% for municipal water utilities, 33% for industrial uses (about half of which is destined for pulp and paper facilities), and an additional 17% for agricultural uses. According to the Project ESIA, the volume of water required during operations will be approximately 8,100 m3/hr and the consumptive use will be approximately 0.11 m3/second. Based on available hydrological information presented in the ESIA, the Tibagi River average flow is estimated to be approximately 292 m3/second and the low flow (Q 7,10) is estimated to be 34 m3/second. The Project?s consumptive use is estimated to represent less than 1% of the average flow and 2.3% of the low flow.

The ESIA identifies the Maua Hydroelectric Power Plant, a 360 MW hydropower project which came into operation at the beginning of 2013, and a water user downstream of the Project?s intake and discharge structures. Results of the preliminary effluent discharge model indicate that there will be no impact to the surface water quality that could impact the quality of the Maua?s reservoir water. Based on the above information, the Project is not expected to have a negative effect on the Tibagi River?s water quality or affect its current receiving water body classification as defined by local law.

Community Exposure to Disease
Other potential risks on public health are to workers influx, involving towns where workers camps will be established, including sexually transmitted and other communicable diseases. The PBA includes the ?Anthropic (Social) Monitoring Program? in which mitigation measures include:
Contractors will favor local workers and training will be available for jobs available during constructions.
Medical services will be provided to workers at the construction site and workers will be subject to initial medical examination.
Awareness regarding sexually transmitted diseases will be provided to workers

Security Personnel
Klabin has access protocols for its operations in Tel?maco Borba which include checkpoints prior to entry into company facilities, and will also implement means of access control at the construction site and workers? accommodations. Security personnel are unarmed and are trained to respond to potential treats to company facilities and infrastructure, including procurement of public safety officials to address criminal activities.

Protection and Conservation of Biodiversity
The area of the Project is zoned rural and characterized by modified habitat that includes plantations of pinus and eucalyptus, agricultural parcels, and some fragmented remnants of native forests of the Atlantic Rain Forest. The results of the initial biological baseline surveys conducted in the first quarter of 2012 indicate that the area consists of a fragmented mosaic of assemblies of Atlantic Forest vegetation in different stages of regeneration with significant biodiversity value. For instance, the results of the initial surveys identified 8 mammals listed as threatened and endangered (T&E) species. In addition, 21 species were identified as endemic to the Atlantic Rain Forest. These include 19 species of birds, one species of amphibian and one species of reptile. For plant species, the two main T&E species include Araucaria angustifolia and Cedrela fissilis.

For the construction of the pulp mill, rail road spur and transmission line it is expected to have small amounts of clearing of fragmented areas of native vegetation, that will be compensated in the form of re-vegetation in another areas and investments in existing areas assigned for conservation in the same region.

The ESIA for the proposed Project states that monitoring programs will be implemented beginning at the start of construction. During site preparation, biologists will be available to monitor and rescue animals. Depending on the condition of the rescued animal, it may be released at a suitable location or, in the case of injury, transported to the animal care facility located at Klabin?s ecological park, in the neighboring Municipality of Tel?maco Borba. Additional species protection measures and conservation areas may be included in the environmental compensation measures, which will be negotiated with IAP as part of the Project environmental permitting process, in accordance with Brazilian requirements.

Initial biological surveys of flora and fauna (mammals, birds, reptiles and amphibians) were conducted at the proposed Project site and along routes for the water line, effluent line and transmission line corridors. An ichthyofauna survey was also conducted in the Tibagi River, at the proposed intake and discharge locations. When the routes for the main access road, railroad, and locations for the two man camps are defined, the Company plans to conduct additional baseline studies to assess potential impacts and risks of these project components.

Management and Use of Renewable Natural Resources
Currently Klabin manages 277,635ha of forests in Tel?maco Borba region, Paran? State Brazil. From this total 132,694 are plantations and 111,104 are natural areas of Brazilian Atlantic forest for conservation (Ombrophilous Dense Forest and Semi-deciduous Dense Forest assemblies). Brazilian Atlantic Forest is a highly threatened biome and only 7% of the original land cover remains conserved.

Part of the existing plantation will be designated to the new pulp plant supply. Klabin?s plantations are FSC certified and no conversion of natural areas is expected for this project. In 2010 Klabin started to conduct a baseline assessment of all natural/conservation areas, determining the areas of initial, medium and advanced stages of natural regeneration. Klabin also started mapping the High Conservation Value Forests (HCVF) within its areas and identified 5,634ha of HCVFs (1, 2, 3 and 4)

Although Klabin already has 111,104 ha of natural areas of Brazilian Atlantic Forest as a biodiversity set aside, which is expected to be more than enough to achieve compliance with legal Brazilian set aside requirements, the Company is still in the process of regularization of these areas under the Brazilian Forest code requirements.

Klabin also purchases wood from small local suppliers, supported by a forest promotion program called ?Fomento Florestal?, and under FSC controlled wood standard requirements. This standard includes provisions against the supply of illegally harvested wood or plantations that resulted in conversion of natural or semi natural areas.

There are several Indigenous Peoples (IP) Reserves located in the central region of the State of Paran?. The two IP reserves that are geographically closest to the Project consist of the Queimadas IP Reserve, located approximately 22 km from the cellulose plant site (immediately adjacent to the City of Ortigueira), and the Tibagy/Mococa IP Reserve located about 35 km from the plant site, on the shores of the Tibagi River, downstream from the Project site. The Queimadas IP Reserve is populated by approximately 600 members of the Kaingang (J? Lingustic family) and a few Tupi/Guarani families (Guarani language). It encompasses a territory of almost 3,100 ha and has been legally established and recognized by Brazilian authorities since 1915, with the most recent territorial demarcation confirmed in 1996. Several other IP reserves are located in proximity to the Sponsor?s extensive forestry plantations in the region.

Brazilian legislation on the protection and preservation of indigenous peoples, their ancestral culture and territory, requires the participation of Federal Institutions such as FUNAI (the most senior Brazilian authority on indigenous affairs) in the environmental license process in case of projects with confirmed presence of indigenous reserves or with any type of interference (socio/environmental impact) with indigenous peoples. As required by the Brazilian legislation, the Instituto Ambiental do Paran? sent the ESIA to FUNAI requesting its official opinion/approval although IAP had not received a response from FUNAI as of the time of IFC?s appraisal.

The ESIA that has been issued to FUNAI for review includes proposed 2 worker camps in Ortigueira municipality and thus, the whole Queimadas municipality and IP Reserves were placed within the Area of Influence of Social-economic Environment, (?rea de Influ?ncia Direata do Meio Socioecon?mico, in Portuguese) and IP groups were briefly described in the social baseline of the EIA, although impacts on IP populations were not very well documented


The Tibagy/Mococa Indigenous Reserve is populated by Kaingang and Tupi/Guarani family groups with a population of about 156 inhabitants and a territory of about 860 hectares; the reserve has been legally established / recognized by Brazilian authorities. The Tibagy / Mococa Indigenous Reserve is located about 35 km away from the Cellulose plant; its territory and community will not be affected by the industrial plant, access road network, railroad, transmission line corridor, workers camps.

In order to meet the requirements of IFC?s Performance Standard 7, the Sponsor has completed complementary assessment activities as follows:
A social base-line of Kaingang and Mococa IP groups and an assessment of potential social impacts on the IP reserves located in Ortigueiras.
A Report on the Queimadas and Tibagy/Mococa IP Reserves concerning: (a) legal status of the IR (land demarcation, collective property title, official registry records, land tenure conflicts over boundaries, etc.); (b) procedures/mechanisms for iterative free, prior, and informed consultation and decision making with this Indigenous community and pertinent authorities; (c) identification/assessment of any adverse project impact associated to the location of workers camps in Ortigueira municipality, workers influx, management of nearby plantations (if any) traffic toward and from the cellulose plant;
Klabin has proactively engaged with FUNAI seeking of a formal opinion and concept/approval on impacts and management practices to be implemented to protect the Queimadas IP community from potential adverse impacts, and to request a Terms of Reference for an IP management Program to be developed and implemented by the client;
Given employment opportunities for indigenous workers were demanded by IP groups, Klabin is acting in close collaboration and under the guidance of FUNAI personnel to prepare a protocol to secure culturally-competent reasonable provisions to accommodate, avoid discrimination and properly treat indigenous workers from any of the nearby indigenous reserves in eventual labor relations with non-indigenous workers;
Klabin has offered labor training program for the IP members (a.e. welding, industrial electric works, civil construction works), in cooperation with SENAI, and nineteen IP members are attending those courses.

After reviewing above mentioned documentation, FUANI has issued a ToR of the IP component to complete the EIA (compnente Indigena do EIA, in Portuguese), but however most aspects of ToR has been already meet. Going forward Klabin will enhance social baseline and impact assessment document to meet specific additional requirements from FUNAI, including an IP corrective/compensatory action Plan, which will be present to IAP and communicated to FUNAI, following the formal licensing process. At the end, when all requirements of the ToR have been met, FUNAI will issue a consent letter of the project.

Going forward, as set forth in the ESAP, based on the Indigenous Environmental Assessment (PBA do Componente ind?gena in Portuguese) agreed between FUNAI (Brazilian governmental protection agency for Indian interests) and the Sponsor, the latter will further expand the recently developed systematic relationship with IP communities located in closest proximity to the PUMA project.

As required by the Brazilian legislation on Protection of Cultural and Historical Patrimony, Klabin prepared an Archaeological Monitoring and Rescue Program. The program objective is to furnish the scientific knowledge and technical and logistic base to secure the protection of cultural and historical patrimony in the area encompassing the cellulose plant site, the water intake, treatment and release works, the 230kv transmission line and a buffer zone reserved for environmental protection around the plant.

During the ESIA (February 2012) and in advance of soil removal, Klabin hired the services of Miguel Grassler - YGARIB? Instituto de Pesquisa e Estudos Socioambientais (Curitiba), a recognized anthropologist to carry out the Phase One of the Prospective/Rescue Study in order to protect cultural and historical patrimony likely to be affected/damaged by construction activities, especially those requiring soil removal, following a terms of reference approved by the Instituto de Patrimonio Historico e Artistico Nacional - IPHAN. The field research, rescue and analysis of material remains were carried out in close consultation with the IPHAN and pertinent State of Paran? authorities. Among important findings, the research officially identified/registered 13 archaeological sites with pre-Columbian remains in the area under study that will be impacted by the project construction works. The majority of ceramic artifacts found are related to the Kaingang indigenous people (J? Linguistic Family), semi-nomads, based on fruit and honey recollection, fishing and hunting activities with incipient agriculture), a culture whose descendants are still alive, and some of whom are currently living in the two nearby Indigenous Reserves of Queimadas and Tibagy/Mococa, together with Guarani groups (Tupi-Guarani linguistic family).

Same approach has been taken in the ESIA and RAS of the access roads, transmission line, and railroad spur, field studies was extended to cover all project-associated components, especially those requiring soil removals. In addition, the Sponsor is implementing the second phase (Phase Two) of the Archaeological Monitoring and Rescue Program during the construction phase (2013-2015). To this end, a team of resident archaeologist is remaining in the construction site to monitor soil removal engineering works and rescue archaeological remains that might appear during the construction period.

During the operation phase, Klabin plans to promote and carry out a Cultural Patrimony Public Education Program in the Ortigueira / Tel?maco Borba /Imba? taking advantage of the archeological findings in the project area.

The Archeological Management program included in the PBA describes the chance find, monitoring and patrimony procedures that were further complemented by following Cultural and Patrimony Prospection/Protection program and Archeological Monitoring Report dated July 2013, presented and approved by IPHAN. As set forth in the ESAP, The Sponsor will develop and implement a Second Phase cultural Patrimony Prospection/Protection Plan, following a schedule defined by IAP/IPHAN and as a condition to be completed before the request of the Environmental License for Operation (LO ? Licensa de Opera??o, in Portuguese). Klabin has provided to IPHAN a report explaining: (a) the chance-find procedures to be followed during the construction phase of the project main facilities as well as off-site associated components; mechanism to protect any further cultural assets found; (b) the mechanism/procedures to protect any further cultural assets found during construction activities; and (c) mechanism/procedures in case archaeological findings require in-situ protection. All archeological material rescued during construction are being/will be stored in the Parana Estate Historical/Archeological Museum (Museu Paranaense) and, as defined in a condition of the Environmental License, will be permanently placed in a technical collection (reserva t?cnica, in Portuguese) in Ortigueiras, to be defined in cooperation with Museu Paranaense.

As previously described in PS1 section, Klabin will include in the Management Normative of Puma Project development, specific procedures for contractors to follow Archeological Management Plan requirements.

The Archeological Management plan includes a Patrimony Educational program aimed to local communities and will include specific and culturally appropriate arrangements to ensure that nearby Indigenous Peoples communities are included and benefit from the Cultural Patrimony Public Education Program currently under development.

Klabin is a company with an active and well known presence in the Project region dating more than 70 years in the State of Paraná. In general, local communities and authorities regard the company as a dynamic economic development force in the region, specifically through the creation of employment opportunities in both forestry plantations management and industrial processing of pulp and paper. Klabin social investment in local health and education infrastructure is highly visible and appreciated by local communities. Moreover, entire villages (e.g. Telêmaco Borba) have been founded by Klabin as its workers accommodation strategy.

For the Puma project, Klabin commenced its community engagement during the preparation of the ESIA. Around eleven (11) meetings attended by approximately 390 persons were conducted by Klabin team between May and July of 2012. Informative meetings were held in all surrounding communities to present the expected project impacts, risks and benefits including the following meetings:

Publicly elected officials from Telêmaco Borba (Mayor, Assistant Mayors, and Council Members);
Publicly elected officials from Ortigueira (Mayor, Assistant Mayors, and Council Members);
Residents from Lageado Bonito;
Residents from Campina dos Pupos;
Residents from the Indigenous People’s community of Tibagy/Mococa;
Residents from the Indigenous People’s community of Queimadas;
Representatives from the Federal Institute of Paraná;
Representatives from the Public Prosecutor Office of Telêmaco Borba and Ortigueira;
Local representatives from the Brazilian Armed Forces;
Local representatives from the civil, environmental, military, and road police departments; and
Middle and upper management groups from Klabin’s pulp mill in Telêmaco Borba.

The most common concerns expressed by representatives from local communities consisted of:
Inquiries about whether there would be job opportunities;
Inquiries about opportunities for training to be able to apply for job openings;
Concerns about continued access to community areas (cemetery in Lageado Bonito);
Questions about the location of workers camps;
Whether the local infrastructure such as roads and the local public health center would be improved;
Interest in offering food services (locally grown produce) to the project during the construction phase;
Whether additional land would be acquired by the Company for forestry operations; and
Whether the quality of water resources would be monitored, among other comments.

The regulatory driven community consultation process for the Project culminated with two official Public Audiences held in the City of Ortigueira on July 12, 2012 and on September 26, 2012. The widely publicized events were attended by approximately 1500 participants in total (1000 in the first and 500 in the second meeting) from Ortigueira, Telêmaco Borba, and numerous smaller communities from the project area and region. The Public Audiences were convened and moderated by representatives from IAP and included formal presentations from Klabin’s Corporate Managing Director, IAP, and Poyry, the consulting firm responsible for the preparation of the ESIA. Also included declarations of support for the Project from the Mayors of Ortigueira and Telêmaco Borba and from State of Paraná Deputies representing the project region. The Audiences included question and answer periods where attendees were given the opportunity to express their views. Among the most common comments were statements of support for the project, followed by requests for improved access to technical training programs to increase the employment opportunities of local residents. Two additional stakeholder meetings were held after the first public audience in the month of August with 220 persons in the Faculty of Telêmaco Borba and with 21 representatives from the Regional Employment Agency.

Klabin has in place an ongoing stakeholder engagement program that includes a stakeholder mapping, stakeholder database, external grievance mechanism (described in PS1) and communication plan. Going forward, Klabin will consolidate all existing stakeholder engagement components in a single stakeholder engagement Plan – SEP.

Klabin is permanently engaging with relevant stakeholders, and another twenty (20) meeting were conducted after mandatory consultative process, including indigenous people groups, authorities, estate level and municipal labor agencies, public attorney, local communities and students, and which were attended by approximately 730 persons. Klabin is also sharing project’s information with general public using local media such as newspaper and radios. When necessary, Klabin is delivering written letters to neighbors to inform relevant events (a.e. start of earthworks).

The complete set of Category A documentation is available from the World Bank Infoshop:

World Bank Infoshop
1818 H Street, N.W., Room J1-060
Washington, DC 20433, USA
Telephone: (202)-458-4500
Fax: (202) 522-1500 (USA)
E-mail: mailto:pic@worldbank.org

Hours of Operation: 9:00am to 5:00pm (Monday through Friday)

The complete set of Category A documentation is also available locally at the following locations:

Francisco Razzolini
Klabin S/A
Avenida Brigadeiro Faria Lima, 3600, 3º, 4° e 5º andares,
São Paulo – SP 04538-132

Prefeitura Municipal de Ortigueira
Rua São Paulo, 80
84350-000 Ortiqueira PR
42 3277-1388

Prefeitura Municipal de Telêmaco Borba
Praça Dr. Horácio Klabin, 37
84261-170 Telêmaco Borba PR
42 3271 1000


Information Disclosed

The complete set of environmental and social impact assessment documents are available in the Environmental Institute of Parana (IAP) Website:
http://www.iap.pr.gov.br/modules/conteudo/conteudo.php?conteudo=646

The following complete set of Category A documentation regarding the Project has been released locally and to the World Bank Infoshop.

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME I - CARACTERIZAÇÃO DO EMPREENDIMENTO - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012);

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME II (TOMO I) - DIAGNÓSTICO AMBIENTAL - MEIO FÍSICO - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012);

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME II (TOMO II) - DIAGNÓSTICO AMBIENTAL - MEIO BIÓTICO - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012);

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME II (TOMO III) - DIAGNÓSTICO AMBIENTAL – MEIO SOCIOECONÔMICO - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012);

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME III - AVALIAÇÃO DE IMPACTOS - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012);

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME IV - ESTUDOS COMPLEMENTARES - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012);

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, VOLUME V - LAUDOS - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012); and

ESTUDO DE IMPACTO AMBIENTAL – EIA INDUSTRIAL, PLANO DE ACOMPANHAMENTO E MONITORAMENTO - PBA - KLABIN - PAPEL E CELULOSE - PROJETO PUMA – PR (Dated April 27, 2012).

Broad Community Support is not applicable for this project

Klabin S.A.(31903) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Environmental and Social Management Plans Complement the management plans from the PBA for the pulp mill project as follows: • Incorporate in the Management Normative of Puma Project Development Klabin’s corporate ESMS procedures (CO-PRO-MEA-001 – Risk assessment; AM-PRO-SIG 0013 - Corrective actions; AM-PRO-SIG-005 – Recording; and SMSO – Guidance Book of EHS Minimum Requirements for Contractors) in the EHS (14.1) and OHS (18.1) sections respectively. • Include in Management Normative of Puma Project Development the archeological work and chance find procedure during excavations and earthworks. • Enhance existing social monitoring program (Programa de Monitoramento Antrópico, in Portuguese) including community health and safety indicators, such as traffic accident rates, as well as public health indicators associated with the risks of influx of construction workers such as incidence of sexually transmitted diseases • Develop specific management program, Impacts from Traffic monitoring program (programa de Monitoramento de impactos do Tráfego de veículos durante a construção) to monitor traffic safety conditions, dust and noise emssions from traffic during construction.	31-Mar-2014	Completed	Completed	11/24/2014
Training -Worker Camps Code of Conduct Include specific guidance for workers hosted in company’s camps regarding good conduct and behavior within local communities and in interacting with IP community members.	31-Mar-2014	Completed	Completed	4/30/2015
Emergency Preparedness and Response (EPR) Conduct a Quantitative Risk Assessment and Risk Management Program following Brazilian Requirements (São Paulo Estate standard CETSB p4.261) for the operational phase.	31-Dec-2015	Completed	Completed	4/29/2016
Monitoring and Review Enhance Project’s Puma monthly management report including key indicators of performance from all applicable management programs such as air quality, community nuisance due to workers influx, environmental noise, wastewater discharge quality, and, and flora and fauna in areas with impacts to natural habitats	31-Mar-2014	Completed	Completed	11/24/2014
Stakeholder Engagement Klabin will consolidate all existing stakeholder engagement components in a single stakeholder engagement Plan - SEP. Klabin will also Update Puma’s Project communication program to incorporate the engagement needs of Railroad Spur, access roads and transmission line as well as to provide feedback of project developments, management and monitoring programs (PBAs) to affected communities.	30-Jun-2014	Completed	Completed	1/1/2015
Stakeholder Engagement – Grievance Mechanism Klabin will formalize existing grievance practices in a format of a procedure including the channels to receive record, treat and respond to grievances in accordance with IFC PS1 requirements.	31-Mar-2014	Completed	Completed	11/24/2014
Employee Grievance Mechanism Klabin will formalize existing grievance practices in a format of a procedure including the channels for placing grievances, as well as recording procedures, treating and responding to complaints.	31-Mar-2014	Completed	Completed	11/24/2014
Supply Chain Management Program – Labor Aspects Complement its existing wood supply chain management and monitoring program to ensure that all third party suppliers report to the Company on basic aspects related to compliance with Brazilian labor laws. As part of its own monitoring activities, the Sponsor will cross reference public sources of information to ensure that suppliers are not included in the government lists of violators of labor laws.	30-Jun-2014	Completed	Completed	11/24/2014
Air Emissions Klabin will deploy a meteorological station in the Puma’s Project site to collect local data to update the dispersion modeling and confirm preliminary results	31-Dec-2015	Completed	Completed	4/29/2016
Land Acquisition and Resettlement Management - In order to comply with IFC’s Performance Standard 5, the Sponsor will document its on-going land acquisition and resettlement compensation process as follows: (i) Develop and implement a Strategic Resettlement Framework to secure the replacement of productive land and provision of social, economic and technical assistance for restoring/improving livelyhoods and social support networks of all vulnerable. The strategy will encompass socio-economic and legal assistance for physical relocation and property rights;	31-Mar-2014	Completed	Completed	11/24/2014
Land Acquisition and Resettlement Management (ii) Complete a Land Acquisition and Resettlement Plan (RAP) for associated facilities, including: (a) detailed information on land/properties acquired and to be acquired; (b) socio-economic baseline information of affected owners and their families: (c) ) vulnerability analysis and eligibility for assisted resettlement and/or livelihoods restoration: (d) impact assessment on the livelihoods of vulnerable families and land-dependent workers (caseros); (e) evidence of consultations and compensation alternatives offered by Klabin; (f) compensation package agreed upon with each affected family and, (g) support given or to be given by Klabin for resettlement, employment/income restoration and reestablishment of living conditions;	31-Jul-2014	Completed	Completed	1/11/2016
Indigenous People Complete updated IP Baseline/impact assessment study incorporating requirements from FUNAI’s ToR and disclose it to IP communities.	31-Jan-2014	Completed	Completed	1/11/2016
Indigenous People Complete IP management program following FUNAI’s ToR requirements	30-Jun-2014	Completed	Completed	1/11/2016
Employment of Indigenous Peoples Prepare a protocol to for provisions to accommodate, avoid discrimination and properly treat indigenous workers in eventual labor relations with non-indigenous workers.	31-Jul-2014	Completed	Completed	4/30/2015
Cultural Heritage Complete archeological studies in the Direct Area Of Influence of The project as required in the Environmental Licenses. Klabin will include specific and culturally appropriate arrangements to ensure that nearby Indigenous Peoples communities are included and benefit from the Cultural heritage Public Education Program currently under development.	31-Dec-2014	Completed	Completed	1/11/2016