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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category B project according to IFC’s Environmental and Social Review Procedures. The Project will result in a limited number of environmental and social (E&S) impacts which can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria. Key environmental, health and safety, human resource and social issues reviewed included: environmental and social management system (ESMS); waste management; land acquisition and involuntary resettlement; construction contractor management; community engagement; labor and working conditions; occupational health and safety; and water and energy use and efficiency. These are discussed in more detail in the following sections.

IFC concludes that this Project does not trigger PS7: Indigenous Peoples - there are no known populations of ethnic minorities at or near the Sponsor’s project sites. PS6: No adverse impacts to biodiversity or sustainable natural resource management were found; PS8: No evidence of the presence of or impact on Cultural Heritage was identified.

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.

Social & Environmental Assessment: For existing projects, Nam Long has applied for, and been granted required approvals by the Vietnamese Government such as construction permits, building permits and environmental impact assessment (EIA) approvals. For ongoing and future projects, the Company follows the same procedures to obtain relevant approvals and permits from the Government. The Company is required to demonstrate due implementation of corrective actions detailed in each project’s EIA before the Ministry of Environment and Natural Resources would sign off on the final EIA approval.



Management Program: The Company’s organizational structure consists of four groupings of departments and subsidiary companies whose roles and responsibilities correspond to key project development stages. Departments within Group B are responsible for land development and obtaining required Government approvals, while Group C manages construction and project management aspects. In addition to the above structure, various task-based committees have been set up within the Company, each consisting of personnel from different departments including management representatives, to discuss and make decisions on specific issues such as land compensation. On matters related to land acquisition and compensation, Nam Long has assigned several senior level managers who work together to coordinate decision making and implementation.



Nam Khang, a subsidiary company of Nam Long under Group C, is the entity responsible for overseeing construction aspects of all of the Company’s projects, including the management of contractors. The Company builds clauses and requirements related to construction waste management, health and safety, and labor and working conditions into its legal agreements with contractors. Nam Khang personnel regularly check the compliance status of contractors against agreed requirements through daily and weekly site inspections. Every site has an appointed Health & Safety (H&S) officer responsible for safety monitoring and reporting.



The Company has plans to initiate a re-organizational process in the near future, which will: i) create a dedicated Environmental Health & Safety (EHS) position under Group B whose incumbent, among his/her other duties, will work closely with Nam Khang on EHS aspects of construction activities; ii) mandate the New Project Development department under Group A to develop and implement land acquisition, resettlement, livelihood restoration and stakeholder consultation procedures, and to be responsible for ensuring their due implementation in all land acquisition activities.



In concert with the above re-organization process, the Company will establish and implement a corporate environmental & social management system consistent with IFC Performance Standard requirements by developing new or will revise existing corporate policies and procedures (including monitoring mechanisms and indicators) as needed, including but not be
limited to procedures on: labor and occupational health and safety (OHS) applicable to workers and contractor/sub-contractor workers; minimum standards for worker/contractor worker/sub-contractor accommodation; emergency preparedness and response; waste management; land acquisition, resettlement, and livelihood restoration; energy and water efficiency; and stakeholder engagement and grievance mechanisms. The Company will also appoint an appropriately qualified E&S coordinator at the corporate level responsible for ensuring implementation of the corporate E&S management system, with a direct reporting line to the COO or CEO.



Monitoring and Review: Key documents and reports are accessible to staff through the Company’s intranet as an information repository and one means of internal communications. Summary information on health & safety (and on site-based waste management on an exception-basis) is reported to the COO of the Company by Nam Khang during weekly and monthly meetings. Local Government labor and environmental bureaus also conduct regular and unannounced monitoring visits to company construction sites to inspect aspects such as any occurrence of lost time injuries, and dust and noise. Under the above mentioned re-organization process, the Company will make adjustments as needed to its reporting mechanisms to reflect the new organizational structure and procedures.

Working Conditions and Management of Worker Relationship: The Company has a workforce of 360 full time and 300 temporary workers – the latter mainly ones being employed by Nam Khang as construction workers on site. Contractors and sub-contractors employ about 200 persons at sites. There are no plans for any major upcoming reduction of its workforce.



Terms of Employment and employee rights and obligations are stated in employment contracts and the Company’s Human Resource Manual. There is a labor union in place at Nam Khang; the Company confirms that should workers wish to set up a labor union or negotiate a collective bargaining agreement at Nam Long, their right to do so will be ensured. The Company’s HR manual states that hiring, training, and professional development decisions will be made regardless of age, gender, and personal background.



The Sponsor confirms that all operations adhere to Vietnamese labor laws e.g. stipulations on working hours and payment for overtime or compensatory leave in lieu of. At the Company, weekly staff meetings are held at various levels, together with the use of email and the intranet as the means to ensure regular communications between management and staff, to receive any work related grievances, and to address them. There have been no major worker grievances received in the past year by the HR department and no cases of labor disputes. The Company’s Board of Director plans to appoint an internal Ombudsman in 2013 to further strengthen its staff communication and grievance channels.



Most of the Nam Khang’s part time workers, and of the 200 contractor workers, live at worker camps set up by Nam Khang at construction sites, some together with family members from out of town. Nam Khang requires contractors to adhere to its standards on worker accommodation e.g. on cleanliness, the use of inflammable construction materials, and the provision of toilet facilities. IFC notes during a visit to two project construction sites that worker camp conditions are very basic. The Company will review its corporate policies on the quality and management of worker accommodation on site (applicable both to its own workers and to contractor workers) and on the provision of basic services i.e. requirements on minimum space per person, supply of clean water drinking and washing, adequate sewage and garbage disposal system, appropriate protection against heat, cold, humidity, noise, fire and disease-carrying animals, adequate sanitary and washing facilities, ventilation, lighting, and cooking and storage facilities.



Protecting the Workforce: All Company full time employees are covered by social insurance as required by national labor laws, while part time workers are provided accident and third-party liability insurance coverage. The Company requires its contractors to insure workers against work accidents, to retain and update worker registration records, and to provide the list of workers at least 24 hours before they
start working on site. IFC finds no signs of the use of child and forced labor by the Company and contractors.



Occupational Health & Safety: Nam Long has in place H&S policies as part of its corporate HR policies, and Nam Khang has procedures for managing health and safety on site e.g. requiring all contractors to provide OHS training and appropriate protective equipment to employees, and to submit to Nam Khang a safety management plan before commencing their work on site. In the last two years there have been no fatalities and LTA’s (including traffic incidents involving the use of company vehicles) at construction sites involving the Company’s own workers or contractor workers. Nam Khang tracks near misses as part of its H&S monitoring. During a visit to one construction site, IFC noted that all workers were wearing personal protective equipment and the sites were well maintained and clean overall. At the same time some contractor workers were seen using wooden panels as a temporary means to elevate themselves to work at heights, and several of them were not wearing protective work boots. The Company is aware of this and will be reviewing its contractor H&S management procedures with a view to reducing any potential risks of injury from working at heights and from other work situations.

There are no boilers used at construction sites and no resulting air emissions. All wastewater from the construction site and finished apartments are discharged through the site sewerage system to on-site septic tanks for initial treatment, which then goes into the city sewerage system and is treated by the city sewage treatment plant. There are rain water catch basins throughout each site to collect run-off which then discharges into the municipality storm water system, separate from the waste water sewerage system.



Hazardous materials such as heavy machine oil are used in small quantities and are stored in a secure storage area at construction sites. On-site foremen and supervisors regularly check to ensure that hazardous materials are handled, and wastes disposed of, in a safe manner and any excess returned to the safe storage area, as per Company policies on the management of hazardous materials which are also applicable to contractors.



Solid construction wastes such as excess building materials and other normal building waste are collected and trucked daily to designated municipal waste disposal or landfill areas; some wastes such as wood chips are collected for re-use as building materials. Once the apartments are inhabited, solid waste will be removed by companies designated by the local city council.



The Company has approval to connect to the mains water supply which runs nearby property development sites. About 2,200 m3 of water is consumed per month at each construction site and worker temporary housing areas. During construction and once inhabited, electricity will be supplied from the local grid, with diesel generators providing back up power. The average grid electricity usage at each Company construction site is estimated to be 14,000 kWh per month.



The Company adopts resource efficiency measures in its building designs such as the use of energy efficient lighting; double glazing for windows; water saving toilet double flushes and shower taps; and low carbon materials for roofs, flooring, floor surfaces and walls.



Greenhouse Gas Emissions: The GHG footprint for this Project, arising mainly from grid electricity consumption, will be in the order of 1,300 tCO2e.

Contractor agreements contain clauses such as the following in relation to community and worker safety and security: contractor workers are not allowed to stay overnight at construction sites for safety and security reasons; workers are not to wander outside the defined site area; and individual vehicles need to be kept in designated parking lots. Nam Khang’s project management documents includes on-site Emergency Preparedness and Response plan, and similarly for Nam Long Service (the Property Management arm of the Company) such a plan is in place as part of its property management manual.



Nam Khang employs unarmed security guards to patrol project construction sites. Once residential units are occupied, security guards employed by Nam Long Service will be engaged to patrol the premises. There have been no security incidents at construction sites other than some cases of petty thefts.



Life and fire safety aspects of building construction adhere to Vietnamese fire code requirements. Nam Khang specifies Life & Fire Safety (L&FS) design requirements in its agreements with contractors e.g. installation of fire alarms and fire-fighting equipment on each floor of each apartment building; installation of exhaust fans, staircase pressurization, and fire resistant doors at each building corridor. Protective equipment against lightning (e.g. lightning conductive rods and earthing electrodes) are installed. For multi-storey buildings, two separate escape routes (e.g. staircases) are always put in place accessible to all floors.



While Nam Long’s core business is in residential project development, the Company’s commercial development subsidiary may possibly engage in future development projects involving public access buildings (e.g. shopping malls). If and when this happens, the Company will ensure the following: i) for all public access buildings to be constructed, or existing public access buildings to undergo major renovations, the Company will commission a qualified L&FS professional to prepare a Master Plan (i.e. a set of L&FS design specifications, applicable codes and regulatory requirements, identification of key risks, and mitigations), which when adopted will cause fire safety aspects of building design and operation to comply with local requirements and also one internationally recognized L&FS standard (e.g. U.S. NFPA). The Sponsor will also commission a post-construction audit of the constructed/renovated facilities by a qualified L&FS engineer to confirm that the works were completed in accordance with Master Plan specifications. The L&FS engineer enlisted by the Company will need to be familiar with and experienced in both the Vietnamese Fire Code and at least one internationally recognized L&FS code.

The Company regularly communicates with local Government and commune representatives on various issues such as local road improvement and other local infrastructure projects. IFC’s visit to two project sites confirms that Company personnel have maintained regular and ongoing interactions with local communities, including during land acquisition, and afterwards with resettled PAPs at the Waterpoint Project location on matters related to livelihood restoration. The Company has supported community activities such as mid-autumn festival events. Interviewed local community members and Government officials expressed a positive view of efforts by the Company to regularly communicate with them, and there was no indication by local communities of any negative impacts arising from the project or concerns. Local community members are aware of grievance channels set up by the local commune and Government should they wish to voice any concerns.

The Company will include, as part of the new or revised corporate E&S policies and procedures to be developed (refer to PS1 and PS5), procedures and requirements on stakeholder engagement and consultation, so as to formalize this approach in its day to day work. Again application of these procedures will be appropriate to the scale and impact of each project.

The following Sponsor representative will be able to provide further information on the Project:

Mr. Tran NGUYEN
Nam Long Investment Corporation
Capital Tower, 11th Floor, 06 Nguyen Khac Vien, Tan Phu Wd., District 7, Ho Chi Minh City, Vietnam
Tel: +848 54 161718
Fax: +848 54 171819

The Sponsor will place a local language advertisement in a major newspaper in Ho Chi Minh City to inform the public that results from IFC’s environmental and social review are available for access. It will also post a summary of the local language version of the environmental & social review summary (ESRS) and environmental & social action plan (ESAP) in a conspicuous location (e.g. front gate) at each of the project sites which are currently under development and/or construction. The Sponsor will also post the local language ESRS and ESAP on its corporate website (http://www.namlongvn.com), and provide a web-link to IFC’s disclosed English-version ESRS and ESAP.

Broad Community Support is not applicable for this project

No.	Action	Completion Date
1	Establish and implement a corporate environmental & social management system consistent with IFC Performance Standard requirements by: (i) developing or refining corporate policies and procedures, monitoring mechanisms and indicators, reporting relationships, and roles & responsibilities of assigned personnel. Policies and procedures will include but not be limited to: labor and occupational health and safety (OHS) including the compliance status of contractors and sub-contractors; minimum standards for worker/contractor worker/sub-contractor accommodation; emergency preparedness and response; land acquisition, resettlement and livelihood restoration; stakeholder engagement, and grievance mechanisms; energy and water efficiency; and waste management. (ii) assigning an appropriately qualified E&S coordinator at the corporate level responsible for ensuring implementation of the corporate E&S management system, with a direct reporting line to the COO or CEO. Specifically, land acquisition, resettlement and livelihood restoration policies and procedures will include elements such as but not be limited to: i) a mechanism to look at minimizing resettlement during a project''''s site selection and design stage; i) conducting socio-economic baseline surveys of affected persons, census and asset registration procedures; ii) developing/implementing Resettlement Frameworks, Resettlement Action Plans or Livelihood Restoration Plans as appropriate; iii) developing/implementing project stakeholder engagement plans including formal grievance mechanisms; iv) undertaking monitoring of ongoing land acquisition activities and post-resettlement livelihood restoration monitoring; and v) commissioning a completion audit where a project is anticipated to result in significant adverse social impacts.	(i) Full list of corporate policies and procedures approved by the CEO of the Company available by 2013-11-30 (ii) Letter of commitment to develop full set of corporate policies and procedures - by 2014-1-10; Full set of corporate policies and procedures approved by the CEO of the Company available by 2014-2-28 (iii) Letter of appointment by 2013.11.30
2	For all projects whereby public access buildings are to be constructed, or existing public access buildings are to undergo renovations, the Company will: (i) commission a qualified Life & Fire Safety (L&FS) professional to prepare a L&FS Master Plan (i.e. fire safety design specifications, applicable codes and regulatory requirements, identification of key risks, and mitigations), which when adopted will cause fire safety aspects of building design and operation to comply with local requirements and one internationally accepted L&FS standard (e.g. U.S. NFPA); (ii) commission a post-construction audit of the buildings/facilities by a qualified L&FS auditor/engineer to confirm that the works were completed in accordance with Master Plan specifications.	(i) Master Plan available 1 month before start of project pre-construction (ii) Post-construction audit report available within 2 months of completion of construction
3	(i) Implement the following parts of Table 5.1 of the Land Acquisition and Resettlement Assessment - Final Report - Nam Long Investment Corporation dated 2013.5.17 as prepared by the external PS5 consultant (in a manner consistent with corporate land acquisition, resettlement, and livelihood restoration procedures and with corporate stakeholder engagement and greivance mechanism procedures - refer to Action 1): Under Category 1 - Waterpoint project: Actions starting with the words "Conduct a post-resettlement..." (Action 3a) Actions startnig with the words "Conduct a detailed pre-resettlement..." (Action 3b) Action starting with "Develop and conduct a regular..." (Action 3c) Action starting with "Implement on-going..." (Action 3d) Action starting with "Develop and conduct a monitoring..." (Action 3e) Action starting with "Develop and implement a Supplemental..." (Action 3f) Under Category 1 - Nam Long Residential Area I, II, III, Tan Thuan Dong projects and Category 2-North Saigon Project (Note - for projects such as Tan Thuan Dong for which resettlement activities have been completed more than one year ago, the focus of the following actions will be to monitor the livelihood restoration status of affected persons and implementation status of any resettlement action plans or corrective action plans): Action starting with "Arrange and conduct..." (Action 3g) Action starting with "Implement the Corrective..." (Action 3h) Under Category 3 and 4: Action starting with "Develop and conduct an internal..." (Action 3i) (ii) As part of corporate procedures for ongoing monitoring of land acquisition activities (refer to Action 1 above), provide an annual report of all ongoing and new land acquisition (and resettlement where applicable) activities, to verify their consistency with PS5 requirements.	(i) Letter of commitment from CEO on implementation by 2013.11.30 (ii) Action 3a - report available by 2014.3.10; Action 3b - survey results available by 2014.3.10 and before start of actual resettlement Action 3c - first monitoring report by 2014.06.30 and thereafter annually included as annex of Annual Monitoring Report (AMR) submitted to IFC; Action 3d - Records of first stakeholder consultation/engagement session by 2014-6-30 and thereafter annually included as annex to AMR; Action 3e - first grievance mechanism monitoring report and database records by 2014.5.31 and thereafter included as annex to AMR; Action 3f - supplemental resettlement plan by 2014.06.30; Action 3g - final review report by 2014.06.30 Action 3h - first corrective action plan implementation report by 2014.09.30; thereafter for 3 years as annex to AMR Action 3i - for 3 years as annex to AMR starting with the first AMR submitted to IFC (iii) Report template developed by 2014-1-8; report - annually as annex to AMR