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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
While all IFC’s Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that this investment will have impacts which must be managed in a manner consistent with the above Performance Standards:

Impacts related to PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: no future land acquisition/lease is foreseen; the Project is located within an existing international airport areas and no conversion of natural/critical habitats will take place; and there is no presence of Indigenous Peoples or cultural artifacts.

In the event that these PSs become applicable, IAS will provide feedback to IFC. Screening and assessment of these issues against PS requirements will be done through IAS’s planned environmental and social management system (ESMS).

This proposed investment is expected to have limited environmental and social impacts that are expected to be site-specific and temporary, and none are expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, operating procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B Project in accordance with IFC’s Sustainability Policy.

Key E&S Issues and Mitigation

Key E&S issues applicable for this investment are: aircraft operations safety, including pilot and crew training programs; aircraft maintenance and servicing, including mechanic training and the management of hazardous materials and wastes; environmental protection and safety at ground sites; aircraft noise and emissions controls; employee health, safety and fair working conditions; and general passenger safety. The Project is designed to avoid, minimize and manage environmental and social risks and impacts of the Company’s operations in compliance with applicable IFC’s Performance Standards and World Bank Group (WBG) General and sector-specific (Airlines) Environmental, Health and Safety (EHS) Guidelines.

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. To ensure that IAS will further comply with Ivory Coast’ environmental, labor and social laws and regulations, IFC Performance Standards and WBG EHS Guidelines, the Company will implement the measures summarized below, and in the attached Environmental and Social Action Plan (ESAP) which has been agreed upon by IAS and IFC, and which will address any compliance gaps with IFC Performance Standards requirements.

Environmental and Social Assessment and Management System

IAS’Environmental and Social Management System (ESMS) is articulated around a Quality System, a Safety Management System, and an Environmental Management System. The Quality System comprises a Quality Manual, and associated Quality Assurance Procedures and a Manual of Operations. The Safety Management System follows the rules established by the International Civil Aviation Organization (ICAO) and the International Association of Oil and Gas Producers (OGP). IAS operates following the Air Career License (31/ANAC/NOA; issue date: 10/01/2011); the Air Operator Certificate (CI-4/05/2011/ANAC/NOA; issue date: 27/05/2011); the Air Maintenance Organization Certificate (03/ANAC/2007; issue date: 29/04/2011), and a Fuel Conformity Certificate (JIG4 Mai 2007; issue date: 10/06/2011).

The Autorité Nationale de l’Aviation Civile de Cote d’Ivoire (ANAC) is the national authority responsible for enforcing International Civil Aviation Organization (ICAO) rules locally. During the 2008 Universal Safety Oversight Audit of ICAO, Cote d’Ivoire was under global average for most of the critical elements of a safety oversight system (for 6 out of 8 critical elements). The audit teams determined the State''s level of implementation of safety-relevant ICAO Standards and Recommended Practices, associated procedures, guidance material and practices. Main concerns were related to safety oversight, technical personnel qualification and training, technical guidance, tools, and the provision of safety-critical information, licensing, certification, authorization and approval obligations, surveillance obligations, and resolution of safety concerns.

IAS Safety Management System relies upon the standards and references listed hereunder:

- ISO 9001 V2008 Standard related to Quality Management System (IAS’certification planned for 2013);

- MOM PART 145/RCI 145 and PART 66 Regulations related to Maintenance Organization Manual and Licenses of the technical staff (IAS is certified under the Autorité Nationale de l’Aviation Civile de Cote d’Ivoire);

- RC OPS 3 Regulations related to Helicopter Operations and Maintenance (IAS is certified under the Autorité Nationale de l’Aviation Civile de Cote d’Ivoire).

IAS adheres to the OHSAS 18001 Standard on Occupational Health and Safety Assessment System but does not maintain any certification. The QSE internal bureau assesses and controls, together with the department heads, team leaders of workshops, the potential damages for each hazardous situation attached to a work post. The Risk Analysis Form (RAF) is used by IAS’ Safety Manager and enables measuring, analyzing and controlling the overall risks attached to a work post. These forms determine the conditions and nature of each work post. They enable IAS Management to control the risks associated with the Company’s activities. The Individual Exposure to Nuisance Form (IENF) is also used by the Safety Manager and constitutes the individual inventory of each employee exposed to physical, chemical and biological risks attached to its work post. They allow the physician in charge of prevention to track the condition of health of each employee during annual check-ups and any additional check-ups required.

IAS compliance is verified through third party safety and operations audits by the Autorité Nationale de l’Aviation Civile de Cote d’Ivoire and by each of IAS’ clients before contracting. In addition, many of IAS clients require regular audits through the life of the contractual agreement with the Company. Over ten such compliance audits are conducted each year.

IAS’ Environmental Management Manual includes sections related to IAS’ environmental policy, planning (impacts identification, legal framework, and management programs), organization and responsibilities, audits, and planned activities. However the chapter on legal framework does not make reference to any environmental and social laws and regulations, and management programs do not identify measures to mitigate impacts previously identified. Potential cases for emergency are identified but no plan is proposed. To meet IFC requirements, IAS will compile a summary of all applicable environmental and social laws and regulations of Cote d’Ivoire. This document should also include international protocols and industry-specific codes of practice and standards. IAS will also establish management programs that will describe mitigation and performance improvement measures and actions that address the identified environmental and social risks and impacts of its activities.

Emergency Preparedness and Response

Going forward, IAS will adopt emergency preparedness and response protocols, procedures and plans that will include zoning, roles and responsibilities, communication (staff, authorities, and local population), emergency procedures, available resources (fire stations, health center, list and location of available equipment, contacts lists), and training program. The plan will provide for staff training to ensure that all employees are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes. In the plan IAS will include schedule for fire drills.

Human Resources Policies and Procedures.

At present IAS’ work force is constituted of 64 team members (25 expatriates and 39 Western Africans including 25 Ivoirians) including pilots, training captains, engineers and mechanics.

IAS has a draft internal labor regulation established in line with the Ivorian Labor Code (Law no 95-15, of 12 January 1995). In accordance with the Ivoirian Labor Code, the minimum age for recruitment of employees is 18 years which is validated through a birth certificate and national identification card. This internal regulation defines rules related to work organization, discipline, hygiene and safety. The Ivorian Labor Code adheres to the same provisions than the ILO Declaration on Fundamental Principles and Rights at Work (1998) regarding core labor standards except that it allows work of children above 14 years old.

IAS will prepare a Human Resources Policy to cover staff and management working relationships, working conditions & terms of employment, workers’ organizations, non-discrimination & equal opportunity, retrenchment, grievance redress, child labor, occupational health & safety, workers engaged by third parties, and supply chain.

Workers’ Organizations

IAS supports the freedom of association of its workers but has no employees ‘representatives. Workers do not belong to any unions. According to the Ivorian Labor Code (Law no 95-15, of 12 January 1995), employees’ representatives are elected for 2-year terms and elections are to be organized by management. Their attributions consist of transmitting workers ‘grievances to management, informing the Work Ministry (Inspection du Travail) of all non-compliances related to the Labor Code, proposing measures to improve work efficiency, and Occupational Health and Safety. By the end of 2012, delegates will be elected.

Grievance mechanism

As part of the development of its Human Resources Policy, IAS will provide a grievance mechanism for workers to raise workplace concerns. IAS will inform the workers of the grievance mechanism at the time of recruitment and make it easily accessible to them. The mechanism will involve an appropriate level of management and address concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned, without any retribution. To comply with IFC requirements, the mechanism will also allow for anonymous complaints to be raised and addressed. The mechanism will not impede access to other judicial or administrative remedies that might be available under the law or through existing arbitration procedures, or substitute for grievance mechanisms provided through collective agreements.

Occupational Health and Safety (OHS)

Although the QSE internal bureau assesses and controls, together with the department heads, team leaders of workshops, the potential damages for each hazardous situation attached to a work station, there is no OHS training plan for staff. As per IFC’s requirements, training is necessary to prevent occupational exposure to hazardous materials and processes. IAS will develop a training program for all workers on relevant aspects of OHS associated with their daily work, including emergency arrangements and OHS briefing for visitors and other third parties accessing the premises. Workers will not face any disciplinary measures or negative consequences for reporting or raising concerns about OHS.

According to the Ivorian Labor Code, medical exams are to be conducted at initial hiring and on a regular basis during the life of the contracting agreement. To ensure compliance with the national legislation, IAS will start conducting medical exams at initial hiring.

Resource Efficiency

IAS’ Environment Management Manual identifies potential impacts of its activities. Among these, energy, water, and hazardous material have been identified as resources that need to be monitored. Going forward, IAS will implement technically and financially feasible and cost effective measures for improving efficiency in its consumption of energy, water, as well as other resources and material inputs, with a focus on areas that are considered core business activities.

Pollution Prevention

IAS, based at the Abidjan International Airport, has its own fueling station on location with a 65,000 Liter capacity. In Ghana, IAS also has an agreement in place with Ghana Oil Company to access the fuel tanks at the Takoradi airport. A 1200-liter tank is already in place and a larger 2000-liter tank was ordered for delivery to the Takoradi base. IAS also maintains a stock of fuel drums for one week of operations as back-up in the event of any fuel shortage in Takoradi as this has already happened in the past IAS also has the capacity to refuel fuel tanks on the rigs. All fuel is provided and controlled by IAS in order to ensure the quality of the aviation fuel.

Aircraft noise is managed in accordance with the operational procedures established by the Autorité Nationale de l’Aviation Civile de Cote d’Ivoire and all maintenance and airside ground handling staff exposed to aircraft noise are required to wear hearing protection rated for the level of exposure.

The main sources of air emissions in heavy maintenance activities include metal finishing and cleaning activities associated with engine overhauls, helicopter exterior cleaning and painting operations. At the time of the site visit, odor from volatile organic compounds was evident in and around the paint shop. IAS will monitor emissions to ensure that relevant requirements are being met. The frequency with which emissions are monitored should be appropriate to the nature, scale and variability of this impact.

The hazardous substance storage locale for aeronautic use is implanted in hangar 2 of the runway sector. Access to the storage premises is restricted; warehouse staffs only are authorized. The organization and movements in this locale, stock management, conformity and observance of hazardous goods storage rules, and the protection of the quality of the stored ingredients are the responsibility of the warehouse supervisor working under the orders of the company’s Technical Officer and are defined in the storage of hazardous goods procedure.

Waste disposal is managed by Aeria, the company responsible for managing the Abidjan International Airport. Aeria is a joint venture between the Egis Group and the Chamber of Commerce of Marseille. No information is available on how Aeria disposes waste. Waste oil comes from oil change of vehicles and helicopters and is collected by a subcontractor of Roi Ivoire who uses it to operate boilers. IAS’Environmental Management Manual includes a section on waste sorting.

Community Health and Safety

IAS focuses on maintaining and securing maximum hygiene and sanitation in its passenger areas. This is a non-stop process which contributes to avoiding bacterial contamination risks in public areas. Public premises (boarding areas, lavatories and hallways) are sanitized daily and depending on the importance of passenger movements and flight schedules, cleaning attendants repeat the process as many times as required throughout the day. Likewise, the surrounding areas are tended to weekly. Attendants report eventual degradations immediately.

Pilot training

Pilot training is organized both in-house -- conducted by qualified staff employed in the company (Chief Pilot, Quality Assurance Officer, Technical Controller, Runway Officer, etc.) -- or is out-sourced and conducted by providers authorized by the Autorité Nationale de l’Aviation Civile de Cote d’Ivoire. Training regulations and procedures are incorporated by reference in the following manuals: Operations Manual, Flight Manual, Maintenance Program Manual, Air Operator, Maintenance Specification Manual, Air Maintenance Organization, and Maintenance Specification Manual

Cote d’Ivoire’s national regulations impose upon air operators the organization of at least one series of drills per year for the purpose of testing: safety plan and procedures, quality of equipment, training level of staff, and determining corrective actions required. In order to optimize its risk management system, IAS has set up continuous assessments or surveys concerning pilot and technician occupational proficiency maintenance, and safety drills (use of extinguishers, knowledge of aircraft and workshop safety procedures, assistance and first aid for the overall staff).

Helicopter maintenance

IAS follows the standards and specifications defined in the Oil and Gas Producers (OGP) Forum Aviation Guidelines for offshore operations, and Canadian Natural Resources International’s Safety Standards for Charter Air Carriers. IAS has its stock of spare parts and equipment at its Abidjan hangar for the daily maintenance of its aircrafts. Major scheduled maintenance operations or repairs are performed on location.

Maintenance and operations are compliant with the following national regulations: RC OPS3 CI for technical operations requirement (based on EASA OPS 3); RCI 145 for maintenance operation (based on EASA Part 145). All senior management, operations and maintenance staff are permanently based in Côte d‟Ivoire or Ghana. As such IAS was able to continue performing its services to customers during the 2004 and 2011 political events in Côte d’Ivoire. Supervision of helicopter maintenance operations is the responsibility of the Maintenance Officer . Maintenance is subject to annual audits by the Autorité Nationale de l’Aviation Civile de Cote d’Ivoire (Maintenance Audit, Security Air Operator Certificate, Certificate of Airworthiness, Radio Station Certificate).

Security

Passenger check-in is done at the Abidjan, Accra and Takoradi airports where IAS has a dedicated and fully-equipped counter (electronic scale, computer and printer). Outbound and inbound passengers are installed in separate areas. Security checks, including luggage checks and screening, are performed by Airport staffs. “Hazardous” and “Restricted goods” signs are displayed in the check-in areas and all IAS personnel have received training in that respect.

A video safety briefing is conducted in the departure hall before boarding aircrafts. A copy of the safety briefing video is remitted to customers on the offshore installation. Training is also provided to the staff with regards to specific takeoff and landing, passenger embarkation and disembarkation, as well as cargo loading and unloading procedures, which are mandatory and apply to each type of aircraft operated.

The aircrafts of IAS are equipped with SkyTrac devices providing capabilities for GPS based position flight-monitoring including tracking and mapping of aircrafts. SkyTrac also provides analysis and reporting of flight monitoring data. SkyWeb is SkyTrac’s web-based asset mapping and reporting product which can be used with relevant permission from any computer with a web browser. Access may be given to clients to view assigned aircraft in near real time on a map.

Community Engagement

IAS maintains a website with an online form for comments, grievances, information requests, job applications, etc. Moreover, in the same manner that the Company regularly communicates various information (quality actions, working conditions, trade performances, etc.), the actions and results concerning Safety, Health and Environment management are communicated:

In-house, to the staff: via postings, displays, HSWC commission, e-messaging, information meetings, etc.

Externally: via letters, e-messaging, website, reports, etc.

IAS maintains a website with an online form for comments, grievances, information requests, job applications, etc. Moreover, in the same manner that the Company regularly communicates various information (quality actions, working conditions, trade performances, etc.), the actions and results concerning Safety, Health and Environment management are communicated: In-house, to the staff: via postings, displays, HSWC commission, e-messaging, information meetings, etc.
Externally: via letters, e-messaging, website, reports, etc.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. IAS will be requested to place an advertisement in a local newspaper to inform the public that results from IFC’s environmental and social review and ESAP is available for access on its corporate website or provide a web- link to IFC’s disclosed ESRS and ESAP.

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Prepare a Human Resources Policy to cover staff and management working relationships, working conditions & terms of employment, workers’ organizations, non-discrimination & equal opportunity, retrenchment, grievance redress, child labor, occupational health & safety, workers engaged by third parties, and supply chain.	11/01/2012 12:00:00 AM	Completed	Completed	09/18/2012 12:00:00 AM
Compile a list of all environmental and social laws and regulations of Cote d’Ivoire applicable to the Company, with a brief description of each. This document will also include reference to international protocols and industry-specific codes of practice and standards.	11/01/2012 12:00:00 AM	Completed	Completed	09/17/2012 12:00:00 AM
Develop an emergency preparedness and response plan that will include zoning, roles and responsibilities, communication (staff, authorities, and local population), emergency procedures, available resources (fire stations, health center, list and location of available equipment, contacts lists), and training program. The plan will provide for staff training to ensure that all employees are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes. In the plan IAS will include schedule for fire drills.	11/01/2012 12:00:00 AM	Completed	Completed	09/17/2012 12:00:00 AM
Elect IAS employees’representatives	12/31/2012 12:00:00 AM	In Progress	Under discussion with IFC client
Develop a grievance mechanism for workers to raise workplace concerns.	12/31/2012 12:00:00 AM	In Progress	Under discussion with IFC client