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 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 Project due to the potentially significant, diverse, and irreversible environmental and social risks and/or impacts inherent to a project of this nature and scale operating in Mozambique. Although E&S risks and impacts would be expected to be localized and largely predictable, the geographic scale of the Project is sizeable; therefore, the Project''s impacts on local populations and ecosystems will be extensive. In addition, Mozambique''s regulatory environment remains incipient, and the land law and allocation systems are imperfectly implemented. The principal biophysical risks and impacts include (1) conversion and modification of natural habitats and loss of biodiversity; (2) changes in surficial water balance and groundwater recharge; (3) increased risk of forest fires; and (4) visual impacts from changes to landscapes. In the socioeconomic realm, the following were identified as the principal risks and impacts: (1) conflicts arising from the land access process; (2) loss of access to agricultural areas; (3) risk of under- or malnourishment of residents in the DUAT areas; and (4) loss of ecosystem services for the population. Additional risks and impacts – beyond these principal ones – were catalogued and analyzed extensively in the ESIA.

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.

Please refer to the attachment "Amendment to the Environmental and Social Review Summary (ESRS) Portucel Mozambique" located under the tab “Availability of Full Documentation”

Working Conditions and Management of Worker Relationship - Portucel’s Corporate Community Policy states that it will comply with labor legislation and respect human rights and that it will provide employment opportunities to people living in the regions where the Group’s mills and forest areas are located. Senior regional forest supervisors are direct line officers representing the company’s interests. Generally speaking the forest supervisors are expatriates with prior experience in Portucel’s operations in Europe. They are assisted in their broad range of responsibilities by small teams of skilled Mozambican and expat staff trained in forestry and related areas. The Company''s estimate, as reported in the ESIA, is that approximately 80 full-time staff will be hired for the Project in Zambezia and 80 in Manica. In addition, P/M’s business model relies heavily on the use of locally-recruited day labor for a variety of tasks, starting with felling light vegetation from wooded areas (which are then cleared mechanically of larger trees by P/M’s contractors – see below), proceeding to planting and maintaining seedlings, and then continuing with routine maintenance and fire prevention tasks in later years. P/M’s intention is that community-level labor will also be integral part of the harvest process, although the exact modalities for such have yet to be defined, given the seven-year growth cycle for eucalyptus. In the ESIA it was estimated that by the third or fourth year of the Project, P/M could potentially employ up to 9,000 casual laborers per year, including 6,500 in Zambezia and 2,500 in Manica.



P/M has adopted this model for a series of reasons. Short-term employment during the first year of establishing new plantations is seen as an indispensable component of the package of benefits that the Company is offering communities over time in exchange for their land (see more below under PS5). As of July 2014, P/M had engaged a total of 7,500 employees in short-term labor organized at local levels, ensuring that employment benefits are shared widely. Of these day laborers roughly 10 % were women due to their primary responsibilities in field agriculture. This large-scale, rotating involvement of residents in casual labor increases local ownership of and support for the Project and minimizes the risk that its benefits are seen to flow disproportionately to “outsiders.” Extensive use of local labor also creates a pipeline of promising candidates for work-crew foremen, supervisors, local guides and guards, and potentially more demanding semi-skilled positions. Local traditional and/or administrative authorities are essential components of the worker recruitment process, which constitutes both Project strength in terms of aligning with and leveraging local leadership and a risk, in the event that local authorities do not recruit and select day laborers transparently. Workers are paid at the end of the month on the basis of an oral contract (which i
s consistent with Mozambican labor law) at a pre-established daily rates (currently MT 120/day, which is above the minimum wage for agricultural work and reportedly higher than local market rates for casual day labor).



While this labor recruitment system constitutes an important strength of the Project design and a concrete form for delivering material benefits to local residents, there are risks inherent in this approach that P/M will need to guard against. For example, survey work during the ESIA revealed that a significant number of respondents raised concerns about the transparency with which casual day laborers are recruited and managed. Also, day laborers have to date not been hired on the basis of formal contracts in which the terms of employment, working conditions, and recourse to grievance mechanisms are clearly spelled out. In addition, as discussed below, P/M has not employed a systematic approach to communicating standard terms of employment and working conditions, safeguarding against employment of underage workers or forced labor, orienting workers on health and safety concerns, providing appropriate personal protective equipment, and avoiding contact with potentially hazardous substances (herbicides, pesticides) for workers, such as pregnant women, whose health status requires greater precautions. Consequently, in line with P/M''s commitment to operationalize the Environmental and Social Management Plan (or Plano de Gestão Ambiental), as proposed in connection with the ESIA, the Company will be required under the ESAP to implement a series of labor-related measures. As a matter of utmost priority, the Company will engage in dialogue with the Ministry of Labor to receive guidance on how to standardize terms of employment and working conditions for the large numbers of day laborers it seeks to employ from the communities for assistance in establishing and maintaining plantation areas. In addition, with the recruitment of a qualified Human Resources Manager, the Company will establish appropriate staffing support in order to develop HR policies, training programs and communications structures for the Company, its primary contractors, and its community-based workforce.



For improving existing roads, opening up smaller tracks for Company use, and the mechanized clearance of larger trees, the Company also relies on contractors, who are paid on the basis of production (e.g. number of ha cleared). IFC reviewed a standard contract used with third-party contractors involved in land clearance. It contains general requirements that the contractor agrees to respect and comply with Mozambican labor, taxation, OHS, and environmental laws, that its machinery, equipment, and vehicles have been properly registered according to local requirements, and that the contractor is able to demonstrate compliance with Mozambique''s social security system. However, contracts do not specify the means for P/M to verify and if necessary audit complian
ce with these provisions. Under the ESAP, the Company needs to ensure that contractors have appropriate safeguards in place to guarantee that Mozambican labor law provisions are respected, including those regarding minimum wages, maximum workdays and workweeks, and OHS protections. The Company also needs to create a system to monitor contractor practices and provide contracted and subcontracted workers access to a worker grievance mechanism if one is not available to them through their employers.



Workers’ Organizations, Child Labor, Non-Discrimination and Equal Opportunity – Mozambique’s constitution and labor law provide that all workers are free to form and join a trade union of their choosing, except for specific job categories deemed essential for public order and safety. The rights to engage in collective bargaining and to strike are also guaranteed. While there are reports that some private employers have sought to discourage unionization and/or dismiss workers active in such efforts, Portucel has stated its unequivocal commitment to respecting labor rights. The minimum wage in the agricultural sector is 80 Meticais per day which some do not consider being a living wage. Portucel pays 120 meticais per day for community-based day laborers. Mozambique’s standard workweek is 40 hours, but it can be extended to 48 hours, after which overtime is to be paid at 50 percent over the base hourly wage. Mozambican law requires one hour of rest per day and limits overtime to two hours per day and 100 hours per year. Social security payments by employers are required for all workers in general, except for casual laborers who work less than 20 days a month which is often the case of Portucel workersPortucel is seeking Ministry of Labor approval to be able to pay Social Security for casual laborers working less than 20 days/month. Portucel intends to establish or if necessary upgrade its standard contracts to ensure compliance with IFC requirements on working conditions and terms of employment for its employees, community day laborers, and contractors, and it is committed to paying all of the necessary social security charges required under the law. It is also seeking to identify a health insurance provider prepared to underwrite the health insurance needs of its workforce, including temporary workers. Finally, as Mozambique is cited by the International Labour Organization as one of the countries with the highest rates of child labor, Portucel will create and use checklists for forestry staff to supervise the labor recruitment practices of the régulos in order to prevent underage workers from participating in casual day labor.



Worker Grievance Mechanism - There is not yet a well-established mechanism for direct employees, contractors, or contractor employees to register OHS or labor-related complaints. (It is proposed that grievances arising from P/M''s use of casual day laborers recruited from the community be handled via the Company''s commun
ity relations and external grievance mechanisms.) Observations during appraisal suggest that there is an informal system with the work crew leader as the “go to” person for grievances, but no explicit system for recording issues or developing appropriate responses. Under the ESAP, P/M will establish a worker grievance mechanism in compliance with the requirements of PS 2 and that will be accessible and communicated to workers and contractors. The grievance mechanisms should be appropriate to the localities and shield workers from retribution, allow for timely response and feedback, be gender sensitive, and be developed in close consultation with relevant labor authorities. The information captured by the grievance mechanism should be considered an important input for management to make adjustments in the Company''s labor practices.



Occupational Health and Safety – Mozambique''s Labor Law (No. 23/2007) contains well-developed sections covering OHS. These require that employers assure safe working conditions, inform them of any occupational hazards, and provide appropriate personal protective equipment (PPE). Companies operating in sectors presenting exceptional OHS risks are supposed to establish workplace safety committees, work closely with relevant workers'' unions to manage these risks, and inform local OHS authorities of any OHS-related accidents, injuries, or illnesses as well as the results of root-cause investigations into such incidents. Large employers are also required to make available first-aid services in the event of a medical of OHS emergency involving the workforce.



Mechanized site preparation and planting is conducted by contractor-managed employees. During the IFC''s first appraisal visit, it was noted that uniforms were provided to these third-party workers, and there was acknowledgement of some of the safety risks associated with various operations. Training of contractors who operate dangerous equipment or handle hazardous materials such as pesticides needs to be developed in appropriate forms, and responsibilities for the assessment of risks to life, property, and the natural environment must be improved. In addition, given that the vast majority of labor involved in clearing, planting, weeding, and maintaining P/M''s plantations comes from local residents engaged temporarily, P/M has a significant responsibility to equip and train casual laborers in appropriate work techniques and occupational health and safety (OHS) procedures. The Company is currently seeking to procure personal protection equipment (PPE) appropriate for the Mozambican agricultural context, and it has undertaken to establish a robust OHS system. Under the ESAP, the Company is required to meet specific deadlines with regard to operationalizing such systems.



The ESIA confirmed that currently such a system is lacking. No assessment had been conducted of OHS risks associated with standard forestry operations (surveying, clearing, planting, weeding et
c.), particularly for the hundreds of day laborers drawn from community workforces. There were no specified procedures for evaluating risks available for IFC review, and the technical specifications included in contracts with contractors included only requirements to observe applicable national labor and safety laws. There are no checklists or oversight mechanisms in place to ensure that contractors and day laborers abide by minimum safety standards. During the first appraisal visit, unsafe practices were observed at various operations indicating a need to improve awareness and active risk reduction through training of workers and contractor team leaders. Portucel routinely uses composite fertilizers for growth and post-emergent herbicides to control competing vegetation. It also uses pesticides for spot treatment of termites and leaf cutters. The list of agrochemicals provided by the company during the ESIA indicated the use of chemicals approved for use in forestry and compliant with WHO and FAO requirements. One noted exception – Fipronil – is a broad-use pesticide categorized as a WHO Class-II “moderately hazardous” pesticide. It is very acutely toxic to aquatic organisms and requires a derogation for use by FSC.



The most significant risk is that plantation workers are not properly aware of the hazards associated with pesticide application and that workers, particularly those drawn from among residents near the Company’s forests, are inadequately trained and not using appropriate protective equipment. The Environmental and Social Management Plan proposed under the ESIA (and known by its Portuguese acronym, PGA, for "Plano de Gestão Ambiental") requires that P/M hire an Occupational Health and Safety Officer as part of its Environmental Management Team and develop a specific plan for OHS. In addition, as part of the ESAP, the Company will conduct an OHS risk assessment to identify and reduce workplace risks in forestry operations, and it will develop an internal action plan for creating an OHS system appropriate to the size, geographic dispersion, and risks of their operations. Approximately one year after the IFC''s investment is committed, the Company will commission a third-party audit of their labor and OHS practices, including use of community-based day laborers, with a view to improving them and identifying gaps to be addressed when seeking OHSAS 18001 certification.

Resource Efficiency and Green House Gas Emissions – Current land clearing practices include the windrowing and burning of bush, stumps and roots which emits significant Green House Gasses. Intentional and natural wild fires are the largest single source of carbon emissions in Mozambique. Land clearing practices also result in a significant loss of soil carbon which results in a knock-on effect where the ecosystem reduces its ability to retain moisture stimulating infertility and allowing the propagation of invasive species. Reducing emissions from fire and retention of carbon on-site through erosion control measures are arguably both an important mitigation measure as well as a key element of any adaptation and resiliency program. While forestry operations will be significant sinks for atmospheric carbon (estimated to be 1.2 million eCO2t/year upon completion all pilot plantations* ), current site preparation methods which include burning of stumps and roots are a significant contributor to gross GHG emissions. Communities now have free access to this biomass for domestic needs but the quantities, size and species mixes -- and the urgency of site preparation -- are not conducive to allowing charcoal production. The ESIA confirmed that fuelwood and charcoal from traditional slash-and-burn farming systems are a primary source of household energy** and an important income source for local residents. Establishment of forest plantations through the investment will negatively affect the abundance of Miombo regeneration used for charcoal production. The Company should maximize the use of site-clearing residuals as is recommended in the Company’s Forest Code. Improvements in the sequencing of operations use of improved charcoal production technologies, and consideration for use of mobile chippers prior to disking will be developed as primary mitigation measures. Under the ESAP, the Company shall develop a system for measuring the GHG emissions associated with its forestry operations and establish clear procedures which will avoid the use of fire in clearing operations.



Pollution Prevention - The most significant source of pollution is sediments arising from soil erosion associated with site preparation. There may be some related localized water contamination caused by fertilizer drift when site preparation is not conducted along contours as was observed in several sites. Portucel’s Corporate Forestry Code indicates that plantations should be established along contours on all slopes greater than 3 % although this has not been fully established in Mozambique operations yet. The Code also establishes grade limits for road construction, another important source of sedimentation, which were generally respected. Most of the equipment observed was reconditioned and not properly equipped for clearing in Mozambique causing unnecessary site disturbance and erosion. Development of Standard Operating Procedures for site clearing, plowing and
planting, and road construction should be more generally understood and field operations staff and contactors trained accordingly. Contractors will be required to have appropriate equipment including brush rakes, protected cabins, closed engine compartments and spark arrestors on exhaust systems. Contractors should have clear instructions and adequate supervision to ensure that road construction and soil conservation requirements in site preparation are strictly followed. Under the ESAP, the Company will establish specific guidelines and procedures to minimize erosion during road construction, site preparation, and anticipated harvest activities which are included requirements in the ESAP.



Pesticide and Herbicide Use and Other Hazardous Materials - The Company uses significant quantities of registered and approved pesticides for termite control, fertilizers and mineral amendments for growth, and herbicides to manage weed competition. Risks associated with the use of all pesticides and fertilizers include localized contamination of surface water from overuse and spills, worker exposure during application, depletion of pollinating insects, and potential misuse by local inhabitants and workers. Overall the Company uses a needs-based approach for the use of chemicals: pesticides for termites are spot-used after identification; fertilizer prescriptions are determined by soil analysis and mapping; and the application of expensive herbicides is timed for efficacy. Beyond smart general application practices the appraisal team observed, and the ESIA confirmed, inadequate awareness about the hazards of pesticide and herbicide use and familiarity with protective equipment. PPE use is inconsistent and application equipment is not well maintained. The procurement, storage application of agrochemicals, and recovery of pesticide containers, for plantations can be better controlled to minimize potential misuse by local communities. Inventories should be better maintained at each site and emergency procedures in the event of contamination or poisoning must be integrated into standard procedures and used to train those working with such chemicals. Beyond agrochemicals the Company’s roading and site preparation activities require proper management and disposition of fuels, lubricants and other hazardous materials associated with heavy equipment. The Company will develop and implement comprehensive operational policies and procedures and guidelines for the appropriate procurement, storage, application and disposal of all hazardous materials and agrochemicals. Clear guidelines on the use of all petrochemicals associated with heavy equipment and rolling stock will also be made available to staff and contractors as indicated in the ESAP.



* Net sequestration when 40,000 ha have been planted using IPCC guidelines for biomass conversion, root-to-shoot ratios, and biomass expansion factors.

** In Mozambique fuelwood and charcoal accounted “for approxima
tely 83% of the total energy consumed,” according to the National Directorate of Energy.

Despite average annual economic growth rates of 8 percent between 1993 and 2009 in Mozambique, the country remains extremely poor with Human Development Index (HDI) levels still well below the average Sub-Saharan African level. Third-party Information verified during the ESIA baseline indicate that poverty levels in Manica and Zambezia Provinces are very high making residents exceptionally vulnerable to natural disasters and resultant food insecurity. Mozambique has suffered acutely from natural disasters in the past, notably tropical cyclones, floods and droughts, and locust infestations*. During the past 50 years, the country has suffered from 68 natural disasters, which have killed more than 100,000 people and affected up to 28 million. Several cyclones made land fall in Manica (Eline, 2000 and Filao in 1988) and Zambezia (Hudah, 2000) where as many as 25 percent of the population is believed to be at risk from these natural hazards**. The Project would address these natural risks to some extent through establishing emergency preparedness and response teams but more importantly building the transportation infrastructure (forest roads) which will improve access to remote area dwellers and allowing pre-positioning of food and first responder support by appropriate authorities.



Community Health and Safety – The Company plantations will be interwoven in a mosaic pattern within rural dwellings and food crop parcels. This pattern will pose special challenges which will bring the local population closer to important agriculture inputs and markets as well as the dangers that are inherent in forestry including use of chemicals and the potential for forest fires. Other risks to community safety include exposure to the transportation of equipment and workers and the extraction of wood at harvest, which is cumulatively the most significant source of fatalities in Projects of this type. As all labor is anticipated to be of local origin, exposure to disease or foreign cultural practices is likely to be minimal. However, greater traffic flows prompted by the Project, including the process of opening up lands, upgrading access roads, and harvesting timber, is likely to bring with it greater exposure to communicable infections, including HIV/AIDS.



Infrastructure and Equipment Design and Safety - P/M operations use heavy equipment for road construction and site preparation. Clearing teams should have appropriate communications for reporting accidents, fires, and hazards inherent to forestry operations in sub-tropical regions such as the possibility of snake bites and encounters with poisonous insects. Conflicts with local communities are of particular concern given the isolation of some operations and recourse if clearing teams wander onto contentious lands or other conflictive situations. Equipment protection teams should also have proper accommodations, access to food and potable water and ability to routinely communicate with the contract
or foremen and forestry supervisors. Lastly, routine service of equipment must be governed by clearly established procedures – as required by the ESAP – to ensure that fuels and lubricants are properly managed and disposed of in accordance with laws and best practices in order to reduce contamination of local water sources and downstream communities.



Ecosystem Services - Regulating ecosystem services are likely to be impacted by the Project, i.e. changes in surface water flows and possible changes in the abundance of pollinating insects or natural predators which keep some pests in check. Provisioning ecosystem services may also be impacted including changes in drinking and irrigating water availability, shifts in access to timber and non-timber forest products (medicinal plants, thatching, fuelwood, forage and game). Expanding plantations are also likely to impact availability of wood for charcoal product which is a major source of income in the identified provinces. The ESIA contractor identified only the relative importance of income and subsistence value of these services. Follow-up survey work is expected to provide a more localized and quantitative assessment of the impacts on of plantation establishment on priority ecosystem services and the HCVF procedures (described in PS6, below) will be key in identifying mitigation tools for ensuring continued access to these priority ecosystem services.



The ESIA identified and assessed the potential impacts and risks to ecosystem services focusing largely on local watersheds and community access to Non-Timber Forest Products derived from natural forests. The ESIA concluded that there would be impacts on water quality (sedimentation from run-off and contamination from herbicides and pesticides) which could be mitigated through plantation set-backs from water courses and strict oversight on the use of pesticides. The ESIA also concluded that the impacts of plantation on surficial water balance could be more significant amounting to as much as a 5% reduction in base flow rates during the long dry season. The hydrology models used during the ESIA were derived from data and models from South Africa and could not be calibrated to the conditions in Mozambique which lacks good meteorological data for most areas. Mitigation measures for changes in water quantity will be similar to those for water quality and the Company will develop an appropriate monitoring system to detect changes in the surface hydrology and peak flow water balance, and adjust management practices (silvics, set-backs, species choices etc.) to address such impacts on community water resources. Recognizing this is long-term and operational research the Company will seek the involvement of appropriate academic institutions and land management authorities.



Emergency Preparedness and Response - As noted above under PS1, there was no observed system for responding to operational accidents or emergencies which may be of a direct
result of operations or those that may occur in adjacent communities. The remote areas in which the Company operates and limited support from distant first responders indicate that the Company should be better prepared to respond to serious accidents that may or may not be related to the Project. The Company has made strides in their establishing SOPs for emergencies and the communication systems between field staff, contractors and forestry supervisors will be further improved. As required under the ESAP, the Company will operationalize an emergency preparedness and response system across its forestry operations, particularly concerning standard first-aid kits, training, field orientation materials, and communications protocols for workplace accidents. This effort will include staff training and collaboration with local authorities, government agencies, affected communities, and other, relevant third parties to facilitate response to accidental and emergency situations, including fires and workplace accidents.



Security Personnel - The Company and designated contractors employ security staff directly. If and when the Company considers contracting services from a specialized security firm the Company’s labor and EHS policies should be included in all contracts P/M has no intention of hiring armed private guards to provide security at its facilities or for its operations at the present time. Should the Company decide otherwise for high value assets (e.g. nurseries, equipment depots etc.) the Company will carry out a self-assessment regarding security risks and, if necessary, develop appropriate policies and procedures for managing the Project’s use of and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in light of IFC Performance Standard 4. If any armed guards are envisioned in providing security for Company personnel, assets and/or installations, the risk assessment and resulting procedures should reflect appropriate measures (e.g. human rights vetting of personnel, a written code of conduct, evidence of training, investigative procedures in the event of any incident or alleged violation) to ensure effective oversight and accountability for the guard force.



* The World Bank. 2010. Economics of Adaptation to climate change – Mozambique. Washington. The World Bank Group.

** ibid.

The FAO estimates that only 10% of total arable land in Mozambique is cultivated and an extremely limited area is irrigated. Farming systems are basic and sources indicate that basic staple yields in Zambezia and Manica are typically less than one ton per hectare – just 1/3 of what can be produced using improved varieties of seed and as little as 1/6 of yields using a combination of improved varieties and fertilizers. Agriculture lending outside of large estate systems has declined in the past 10 years and infrastructure spending has also declined (when large extractive industries are excluded from the data.) Access to inputs, necessary finance and agriculture markets are all extremely weak making food security a significant concern and major opportunity. Low tillage and low-carbon agriculture practices are indicated given the importance in maintaining and improving soil organic matter for production and resiliency to climate change. Beyond the cultivated landscapes the sustainable management remnant and regenerating Miombo forests will play a crucial role in protecting watershed functions and enhancing landscape resilience to climate change in both Project areas. Sustainable management and conservation of forests provide environmental services ranging from improved water quality to creation of micro-climatic conditions that maintain agriculture productivity. Moreover, sustainable management of Miombo forests which will be supported through Company efforts, has great potential to strengthen social resilience, by offering a diversification of revenue sources and product supplies, and building the capacity of local institutions.



Protection and Conservation of Biodiversity and Habitats - It is estimated that about 70% of Mozambique has some type of forest cover and that roughly 2/3 is “Miombo”. Manica and Zambezia Provinces remain sparsely populated due to the Mozambique Civil War, weak infrastructure, and continuing pockets of tsetse fly limiting cattle ranching. These Provinces contain a convergence of the Eastern and Southern Miombo regions predominated by several species of Brachystegia and Baikiaea. Most of Manica and Zambezia Province have been modified through agriculture practices including extensive plantations of field crops and tree crops under colonial periods and an historic use of fire to control tsetse and wildlife. Most of the upland areas are now managed under varying intensities of shifting cultivation typified by 1-2 years of cultivation followed by 3-4 years of fallow during which low Miombo returns if the area is not too heavily burned. Observations from the appraisal, confirmed during the ESIA, indicate that most of the areas included in the DUATs have been under extensive shifting cultivation for some time. Lowlands and river bottoms are largely farmed and recessional agriculture practiced extensively in both Provinces.



Legally Protected and Internationally Recognized Areas and Critical Habitat - The geomor
phology of the Project areas provide a wide range of altitudes and soil types which explain the high degree of biodiversity and endemism in the region. While there are only a few National Parks established in either province much of the area remains classified as Hunting Reserve (IUCN category VI). Extensive areas of forest are managed by communities and most of both provinces have experienced serious illegal logging of a handful of species. The Miombo woodland provides an extensive array of species used for subsistence and commercial extraction (fruits, honey, insects, fodder, thatching and fuelwood among others). There has been no critical habitat identified within the DUAT’s apportioned to the Company. During appraisal IFC staff reviewed the footprints of the provisional DUAT’s with information available through the Integrated Biodiversity Assessment Tool (IBAT) to determine the presence and proximity of protected areas and biodiversity assets. Several DUATs in Manica are close to established Hunting Reserves (IUCN Cat VI) and one DUAT is approximately 40 km from Gorongosa National Park. In Zambezia Province Mt Namuli is recognized as an Important Bird Area (IBA) and Key Biodiversity Area (KBA) north of Gurue and roughly 20 km from the closest planned site. Review of the IUCN Red Book and other sources indicates there are 16 species of bird and one species of mammal that are Threatened or Vulnerable and may occur within the broad Project areas. However, the ESIA consultants conducted reviews of each DUAT area through remotely sensed data and very limited field surveys and were thus unable to confirm the presence of any of these species. The National High Conservation Value Area Working Group has not identified particular habitats in Manica or Zambezia where these species are likely to occur. Careful review of each new plantation area will be required to ensure that any Critical Habitat is identified and set-aside for preservation should it be found.



The most significant threat to biodiversity is conversion of the remaining and already-fragmented natural habitat. There is evidence of more intact mature Miombo (defined by with structure and species mixes) can be found in some of the DUATs which; these were mapped during the ESIA process. The analysis, which relied upon use of trained satellite imagery, concluded that areas with structurally mature Miombo should be consolidated and protected from further fragmentation through community-based management. The ESIA concluded that several DUAT’s in the northern part of Zambezia had large areas that should be set-aside. The Company has consistently indicated that it will not convert any natural habitat or High Conservation Value Forests or Areas (HCVF) and will comply with IFC’s PS as well as the FSC requirements. The Company estimates that less than 10 percent of the area in its DUATs (32,000 ha) has significant biodiversity or ecosystem values which will be set-aside and managed under th
e High Conservation Value System the Company plans to install based on satellite information and consultation with affected communities and NGOs. However, there is not yet a clear taxonomy on such vegetation to guide the Company’s identification and management of HCVF in the Project areas. Portucel has provided support and leadership within the National HCVA Working Group which is helping to define methods and tools for conducting such assessment although, at present, no complete guidelines are available although the HCVF. Development and testing of an HCVF assessment methodology and management practices are the primary mitigation measure to ensure that critical habitat is protected and that the boundaries of natural habitat is well defined. The Company will complete an HCVF strategy and Field Guidelines for HCVF protection which it will submit to the National HCVF Working Group as ESAP items. The Company is developing an agreement with the World Wide Fund for Nature (WWF) to support its HCVF methods and field implementation tools.



Management of Ecosystem Services - Provisioning and regulating ecosystem services will be impacted by the Project. These include the regulation of the local hydrologic cycle, pollination due to impact on the population of pollinating insects, a reduction of the availability of fuelwood, thatching grass, construction wood, forage and a reduction of biodiversity including potential sources of protein such as mammals, reptiles, fish and edible insects. The ESIA provided a comprehensive list of ecosystem services and helped to prioritize those services of highest value to the communities in each area through its baseline socioeconomic survey work. That said, the ESIA looked most carefully at either hydrological functions or biodiversity issues and did not fully integrate them into an ecosystems services perspective that would help the Company work with affected communities to make actual management decisions. Appropriately, the ESIA placed high value on developing appropriate monitoring systems to ensure that the Company is capturing changes in priority ecosystem services (water and biodiversity, in particular) and we able to adaptively manage plantations to minimize observed risks and impacts at the more local level. Because of the long-term nature of calibrating meteorological events and surface water flows it is recommended P/M engage with a suitable university or research institution in the region to adopt and customize hydrology models appropriate for its operations which are included in the ESAP.



Sustainable Management of Living Natural Resources - Portucel has a strong corporate commitment to the use of recognized best forestry practices and the use of independent certification systems to verify their use. The Company’s operations in Portugal are an appropriate blend of small and privately owned forests which are certified to FSC and PEFC standards (certificates FSC C010852 and PEFC/13-23-001, resp
ectively). That said, FSC is nascent in Mozambique with only a single certificate in place and very little market incentive or implementing experience. Portucel has played a significant role in the Mozambican FSC National Standard’s development and is fully aware of both its drawbacks and potential to ensure that sustainability is built into Company activities. The lack of an agreed-upon national standard is as much a symptom of the forest sector’s immaturity within the country. It is worth noting that this process was only completed in South Africa in 2013 and is also ongoing in Tanzania. Regardless, the company will establish an Action Plan for obtaining FSC certification of its forests and make FSC certification an explicit element of its policy which is included as an ESAP Item.

Protection of Cultural Heritage – The ESIA identified several types of areas important to communities for cultural heritage purposes: those areas that have a representative place in the spiritual life and sacred common grounds for communities which can be forest areas or often areas adjacent or on top of inselbergs; and common forest areas where medicinal plants are sourced. The latter have been addressed above within the context of PS5. Information available during appraisal and the ESIA indicated that the Company has respected the spatial area where these cultural assets occur thus far and the GIS system affords the ability to carefully map and monitor the condition of these sites. While it has respected the physical integrity of cultural sites, it has not yet formally and systematically consulted with communities to ensure that all such sites are captured and that local views have been fully used to determine the best ways to conserve such assets. The PGA and Forest Management Plans should ensure that all locally significant cultural sites, such as communal cemeteries (often located in wooded areas) and sacred forests, be identified during consultations with local populations and establishment of boundaries and access to such areas are preserved and included as ESAP Item 8.1. The grievance mechanisms as referenced elsewhere in this document should be well understood by local communities and particularly sensitive to complaints of reduction in access or damage to sites of cultural heritage. The Project area, particularly in Zambezia is host to many granite inselbergs where rock caves exist. Local authorities maintain that no pre-historic sites have been found in the area. However, given the possibility that culturally important and heritage sites exist in the Project area, the Company must develop procedures for managing chance finds and ensuring that staff and contractors alike are effectively able to minimize any risks to cultural heritage.

Various aspects of the client''s approach to stakeholder engagement, community relations, and grievance resolution are mentioned in preceding sections, including with regard to the community consultations held in 2009 under the DUAT-granting process. Stakeholders surveyed in course the ESIA highlighted the lack of systematic communication channels with the Project, including for residents in or near P/M''s DUATs and local authorities, both formal and traditional. P/M''s formal community engagement has thus far been focused on the consultative process used during the identification and granting of the Company’s DUATs and in the context of establishing trial plantations (including negotiation of access to land). Importantly, the Company has recently articulated a "Mechanism for Management of Community Relations," including channels for receiving and processing grievances. This mechanism is currently being operationalized. The Company has also established a state-of-the-art GIS/mapping capacity that can be used to compile key characteristics of communities and households into an interactive database, which can serve as the basis for real-time community engagement.

The ESIA process itself has also afforded a number of opportunities for community engagement. As Mozambican environmental regulations characterize this as a Category A project, a public consultation process was required for the ESIA, under a 2006 general directive for public participation in environmental licensing. The scoping and fieldwork phases of this process – carried out in 2013 by an external consulting firm called Impacto – comprised nearly 1,200 household interviews, and focus groups, and community consultations in close to half of the hamlets and settlements located within the DUATs. During the final presentation of the ESIA on July-August 2014 P/M conducted 35 village meetings in Manica which reached 99 communities and another 26 village meetings in Zambezia which included another 98 communities. In addition, five District-level meetings were held in Manica and two more in Zambezia. Provincial-level meetings were held in both Manica and Zambezia and a National public hearing was conducted in Maputo. During the ESIA process as a whole, it is estimated that out of a total population of some 120,000 in the DUAT areas, more than 15,000 residents and local authorities participated in different events that allowed for community engagement with the Project.

Ministério da Agricultura
Praça dos Herois, CP 1406
Maputo, Moçambique

Ministério para a Coordenação da Acção Ambiental
Rua Kassuende, 167
Maputo, Moçambique

Portucel Moçambique LTDA
Rua de Sussundenga, Ed. Castelo Branco,
Chimoio, Manica, Moçambique

Portucel Moçambique LTDA
A/C: Herminio Jorge Cardoso Amaral
Bairro do Cimento (junto à Escola Primária Montes Namúli)
Gurué, Zambézia, Moçambique

The appraisal findings indicate the business activity to be financed is likely to generate potential significant adverse impacts on communities. IFC expects the Company to engage in a full process of Informed Consultation and Participation (ICP) during the ESIA. IFC will complete its environmental and social due diligence after Board approval based on the documentation and evidence of Broad Community Support consultation. The outcome of the due diligence will inform IFC's decisions going forward and disclosure of activity-related information post-Board commitment will be done in accordance with the requirements of the Access to Information Policy. *ICP - Information Consultation and Participation **BCS - Broad Community Support

S.no	Description	Anticipated Completion Date	Status
1	ESIA: The Company will secure approval by relevant Mozambican authorities of a complete and fully-disclosed Environmental and Social Impact Assessment, including documentation and assessment of the level of informed consultation and participation by communities where Portucel has started or intends to start its proposed plantation activities.	09/30/2014	Completed
2	Influx Management: The Company will complete a supplementary study on potential project-induced in-migration so as to better understand (i) the dynamics around reported influx of new residents into the Portucel Mozambique land-use concessions (DUATs), (ii) what impacts and risks such an influx might pose for the project as such, for local health services and other social infrastructure, and for social relations in the project area, and (iii) key elements of an Influx Management Plan to assist Portucel Mozambique and local authorities to best manage these issues. The management plan should clearly identify the Company and public sector responsibilities and operational policies to guide Portucel in the event government is unable to assume its anticipated respective role.	01/31/2015	Completed
3	ESMS: Portucel Mozambique shall establish an Environmental & Social Management Systemwhich responds to the E&S risks and impacts identified during the ESIA. The program shall be applied across the Company’s forestry operations including contractors and primary suppliers over which the organization has control or influence. The ESMS shall include at least the following items: (i) policy, (ii) identification of the risks and impacts, (iii) management programs, (iv) organizational capacity and competence requirements, (v) emergency preparedness and response mechanisms, (vi) approach to stakeholder engagement, and (vii) monitoring and review of system performance on at least an annual basis.	09/30/2014	Completed
4	Organigram and Recruitment: The Company shall, as a matter of priority, develop clear requirements for the full organizational capacity and competences necessary for organizing and implementing its Environmental & Social Management System (ESMS) and accelerate recruitment of qualified, full-time personnel for these functions at the Company and operational levels.	09/30/2014	Completed
5	Forestry Good Practices Code: The Company shall issue a version of its corporate Forestry Code (Código de boas prácticas florestais) suitable for its Mozambican operations.	01/31/2015	Completed
6	SOPs: The Company shall finalize and ensure full implementation of all Standardized Operating Principles and Procedures related to environmental and social issues, particularly concerning land acquisition and livelihood improvement measures.	07/31/2015	Completed
7	Emergency Preparedness and Response: As part of the ESMS, the Company shall operationalize an emergency preparedness and response system across its forestry operations, particularly concerning standard first-aid kits, training, field orientation materials, and communications protocols for workplace accidents. This effort will include staff training and collaboration with local authorities, government agencies, affected communities, and other, relevant third parties to facilitate response to accidental and emergency situations, including fires and workplace accidents.	12/31/2014	Completed
8	Monitoring and Evaluation: Involving representatives from Affected Communities and other stakeholders as appropriate, the Company shall establish procedures and systems to monitor the effectiveness of its ESMS and management programs, compliant with applicable regulations and consistent with third-party verification systems with which the Company anticipates conforming, when appropriate. This M&E system should be fully integrated the Company’s geographic information system (GIS) and forestry planning and management systems, and among its numerous tasks, the system should be capable of tracking, monitoring, and evaluating the impacts of land acquisition and the effectiveness of livelihood improvement measures in particular.	06/30/2015	Completed
9	Stakeholder Engagement Plan: Based on advice from the IFC, the Company shall develop and implement a Stakeholder Engagement Plan scaled to project risks and impacts identified in the ESIA and baseline surveys and tailored to the characteristics and needs of the Affected Parties and local government authorities. Such a plan will include differentiated measures to allow the effective participation of those identified as disadvantaged or vulnerable.	10/31/2014	Completed
10	First Annual E&S Public Report: The Company will begin reporting publicly to all stakeholders, particularly local authorities and Affected Communities, on an annual basis regarding Portucel Mozambique’s full E&S performance. Among other performance indicators, the Company will report publicly on its land access practices, livelihood improvement measures, and grievance management (including the numbers and types of grievances received, by location, and measures taken to address them).	04/30/2016	Completed
11	Community Development Plan: Based on IFC advice, the Company shall develop an approach to strategic partnerships for community investments aligned with relevant plans organized by local authorities, the Company’s own Forest Management Plan, and the Communicable Diseases Prevention Program (see below), including the resources required to ensure its implementation.	10/31/2014	Completed
12	Community Grievance Mechanism: Based on the first six months of functioning of Portucel Mozambique's grievance mechanism (September 2014-March 2015), the Company will analyze the effectiveness of its procedures and identify and implement any necessary improvements to them.	04/30/2015	Completed
13	Communications Plan: In conjunction with the Stakeholder Engagement Plan, Community Development Plan, and Community Grievance Mechanism, Portucel Mozambique will develop a corporate communication strategy, elaborate a plan at the sub-national, national, and international levels for dialogue, and create operational capacity and internal coordination mechanisms for ensuring appropriate communication with Affected Communities and other interested parties.	09/30/2014	Completed
14	Human Resources Policy (Direct-Hire Employees/Contractors): The Company will adopt and implement human resources policies and procedures appropriate to its direct-hire workforce and those of its contractors, including provision of understandable information appropriate to their employment circumstances regarding workers’ rights under Mozambican labor and employment law including rights related to hours of work, wages, overtime, compensation, freedom to associate and form worker organizations, occupational health and safety, non-discrimination, grievance mechanisms, retrenchment, and benefits upon beginning the working relationship and when any material changes occur.	09/30/2014	Completed
15	Human Resources Policy (Temporary Workers/Casual Laborers): In light of the large-scale mobilization of unskilled labor at the community level during land clearing and planting processes, Portucel Mozambique will provide temporary workers mobilized at the local level with understandable information appropriate to their employment circumstances regarding workers’ rights under Mozambican labor and employment law including rights related to hours of work, wages, overtime, compensation, freedom to associate and form worker organizations, occupational health and safety, non-discrimination, grievance mechanisms, retrenchment, and benefits upon beginning the working relationship and when any material changes occur. Due to the need for consultation with and clarification from the Ministry of Labor on many of these issues (see below), this item's due date may be subject to modification.	12/31/2015	Completed
16	Standardized Orientations for Temporary Workers: The Company will develop and begin providing temporary workers with standard orientations on terms of employment, working conditions, and occupational health and safety on a regular basis and in understandable terms.	10/31/2014	Completed
17	Checklist for Temporary Workers: The Company will develop a checklist of evaluative criteria for its field supervisors to assess the degree to which local traditional authorities responsible for the recruitment and mobilization of temporary workers are meeting Company principles and goals, including non-discrimination, equal opportunity, livelihood restoration and support for vulnerable households, and prohibitions on child labor.	10/31/2014	Completed
18	HR Dissemination Strategy: The Company shall develop a strategy for how all employment-related information is communicated consistently amongst all employees, contractors, temporary workers, and interested parties in accessible, understandable terms.	06/30/2015	Completed
19	Third-Party Labor Audit: The Company will conduct a third-party audit of its labor practices and make appropriate adjustments in its policies and practices, particularly with regard to protections for temporary/casual laborers.	07/31/2016	Completed
20	Standardized Contracts and Working Conditions for Temporary Workers (First Quarterly Report): The Company will consult with the Ministry of Labor and report to the IFC on efforts to develop and begin providing standard written contracts and working conditions for temporary/casual laborers.	12/31/2014	Completed
21	Standardized Contracts and Working Conditions for Temporary Workers (Second Quarterly Report): The Company will consult with the Ministry of Labor and report to the IFC on efforts to develop and begin providing standard written contracts and working conditions for temporary/casual laborers.	03/31/2015	Completed
22	Standardized Contracts and Working Conditions for Temporary Workers (Third Quarterly Report): The Company will consult with the Ministry of Labor and report to the IFC on efforts to develop and begin providing standard written contracts and working conditions for temporary/casual laborers.	06/30/2015	Completed
23	Standardized Contracts and Working Conditions for Temporary Workers (Fourth Quarterly Report): The Company will consult with the Ministry of Labor and report to the IFC on efforts to develop and begin providing standard written contracts and working conditions for temporary/casual laborers.	09/30/2015	Completed
24	Standardized Contracts and Working Conditions for Temporary Workers (Fifth Quarterly Report): The Company will consult with the Ministry of Labor and report to the IFC on efforts to develop and begin providing standard written contracts and working conditions for temporary/casual laborers.	12/31/2015	Completed
25	OHS Self-Assessment and Development of an OHS Management System: Based on a self-assessment of its OHS risks, the Company will develop an occupational health and safety (OHS) management system, begin the use of personal protective equipment (PPE) for temporary workers, and track and investigate all OHS incidents. The plan will identify training needs and specify the resources, including staffing, necessary for an effective OHS management system, and the Company will establish and implement policies and procedures for managing and monitoring the OHS performance of all workers, including contractor employees and temporary/casual laborers.	11/15/2014	Completed
26	PPE Procurement Plan: As part of its overall OHS plan, the Company will source and begin the use of PPE appropriate for risks and work tasks, including for temporary workers.	11/15/2014	Completed
27	Third-Party Audit of OHS Systems and Practices: The Company will commission a third-party audit of its OHS systems and practices with a view to improving them and identifying gaps to be addressed when seeking OHSAS 18001 certification.	07/31/2015	Completed
28	Worker Grievance Mechanism: For its permanent and contractor workforces (grievances arising from casual day laborers recruited from the community be handled via the Company's community relations and external grievance mechanisms), the Company will establish a worker grievance mechanism in compliance with the requirements of PS 2 and that will be accessible and communicated to workers and contractors. The grievance mechanisms should be appropriate to the localities and shield workers from retribution, allow for timely response and feedback, be gender sensitive, and be developed in close consultation with relevant labor authorities.	06/30/2015	Completed
29	Measuring GHG Emissions: The Company will develop a system for measuring the GHG emissions associated with its forestry operations. This system will have clear procedures to guide its assessment and reporting of GHG emissions within the Company's Forest Management Plans and Code of Good Forestry Practices, specify clear responsibility for the accounting process, and communicate effective procedures to appropriate personnel and contractors, including the disposal of residual wood waste.	12/31/2014	Completed
30	Soil Erosion Control: The Company will establish specific guidelines and procedures, communicate them to staff and contractors, and ensure their implementation in order to minimize soil erosion and loss of soil fertility in forestry operations, including measures to reduce erosion during road construction, site preparation, and anticipated harvest activities. Fertility guidelines will outline the Company’s methods for soil mapping, assessing pre-plantation fertility, and ongoing use of amendments.	11/15/2014	Completed
31	Hazardous Materials: The Company wil develop comprehensive operational policies and procedures and guidelines for the appropriate procurement, storage, application and disposal of all hazardous materials, including fuels, lubricants, and agrochemicals. These procedures and the determination of agrochemical permissibility will be approved by Senior Management and shall be compliant with applicable Mozambican regulations, the IFC Performance Standards, and the FSC Principles and Criteria	11/15/2014	Completed
32	Fire Risk Management Plan: In conjunction with the Emergency Preparedness and Response Plan (see above), the Company will develop and implement a fire risk management plan that addresses an assessment of all associated risks and impacts of wild fire and arson and that involves community-based approaches and the use of temporary workers in fire prevention efforts. The plan will identify fire prevention, detection and suppression practices and establish the necessary budgetary and human resources and management responsibilities for implementing procedures which reduce effectively the frequency and severity of fire incidents.	10/31/2014	Completed
33	Transportation Safety Procedures: The Company will establish transportation safety procedures as part of the Company's SOPs, make them routinely available to employees, contractors and Affected Communities, and implement appropriate training (e.g. defensive driving) and control mechanisms (e.g. tracking excessive speed via GPSs) to ensure compliance with its procedures.	10/31/2014	Completed
34	Self-Assessment on Security and Human Rights: The Company will carry out a self-assessment regarding security risks and, if necessary, develop appropriate policies and procedures for managing the project’s use of and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in light of IFC Performance Standard 4. If any armed guards are envisioned in providing security for Company personnel, assets and/or installations, the risk assessment and resulting procedures should reflect appropriate measures (e.g. human rights vetting of personnel, a written code of conduct, training, investigative procedures in the event of any incident or alleged violation) to ensure effective oversight and accountability for the guard force.	10/31/2015	Completed
35	Land Access Procedure (First Report on Land Action Plan): On the basis of the Company's new land acquisition procedure, Portucel Mozambique will begin updating land acquisition documentation for areas planted prior to September 2014 and new areas to be planted by December 2014.	12/31/2014	Completed
36	Land Access Procedure (Second Report on Land Action Plan): On the basis of the Company's new land acquisition procedure, Portucel Mozambique will complete land acquisition documentation for all areas planted as of December 2014.	03/31/2015	Completed
37	Land Access Procedure (Third Report on Land Action Plan): On the basis of the Company's new land acquisition procedure, Portucel Mozambique will begin land acquisition documentation for areas to be planted in 2015.	07/31/2015	Completed
38	Land Access Procedure (Fourth Report on Land Action Plan): On the basis of the Company's new land acquisition procedure, Portucel Mozambique will complete land acquisition documentation for all areas to be planted by December 2015.	12/31/2015	Completed
39	Strategy for Livelihood Restoration Measures: In lieu of a formal Livelihood Restoration Plan, the Company will design a written strategy for developing and implementing livelihood restoration measures in response to the economic displacement experienced by individuals and communities ceding land to the project. To be developed by the Company on the basis of IFC advice, the strategy should define eligibility criteria for Affected Persons and Affected Communities and describe the component measures that together will seek to restore livelihoods, including short-term employment and the provision of improved agricultural techniques and other forms of technical assistance for land-based livelihoods and special measures to improve the livelihoods of economically vulnerable households.	10/31/2014	Completed
40	M&E Plan for Livelihood Measures: As part of the measures to restore if not improve livelihoods, the Company will develop monitoring and evaluation plan based on collecting and analyzing data for household-level livelihood outcomes among Affected Persons and Affected Communities over a three-year period after economic displacement in a given area, including yearly third-party monitoring reports that will be made public.	10/31/2014	Completed
41	Ecosystem Services: Based on the ecosystem services assessment carried out as part of the ESIA, the Company shall incorporate appropriate measures into its Forest Management Plan to fully mitigate the reduction/degradation of identified ecosystem services, particularly watershed functions, and others that may be exacerbated by climate change.	02/01/2015	Completed
42	Methodology for Identifying High Conservation Value Forests & Action Plan for Protecting Such Areas: The Company will develop a methodology for identifying and mapping HCVFs, including through community participation, and implement an Action Plan to ensure that intact natural forests and other HCV areas are not converted during project implementation. The Company shall include all legally-established protected areas, including hunting reserves and registered community-based lands, in geographic and management information systems.	11/30/2014	Completed
43	Pre-Assessment for Forest Certification: Six months prior to the elaboration of an Action Plan for obtaining third-party certification of forests under its management control, the Company will carry out a pre-assessment to identify gaps and prepare a draft action plan to be reviewed by a competent FSC or PEFC auditor or other certifying body to ensure that it is realistic and achievable.	07/31/2016	Completed
44	Action Plan for Forest Certification: The Company will finalize an Action Plan to identify what reasonable measures and controls Portucel Mozambique will use to assess conformity with third-party certification systems (e.g. FSC or PEFC) and at what time it shall pursue third-party verification of compliance with these standards.	12/31/2016	Completed
45	Water Balance Protocol: Based on a review of expertise available in Mozambique and the region, the Company will establish protocols and tools and select appropriate methods and equipment to identify and monitor impacts of plantations on surface water, both in terms of quality and quantity.	12/31/2016	Completed
46	Cultural Heritage Risk Identification and Protection Program: Based upon results of the ESIA and other information gathered during its operations, the Company will carry out a self-assessment of the procedures necessary for ensuring that Portucel Mozambique has a cultural heritage risk and identification assessment and protection program that complies with applicable Mozambican law on the protection of cultural heritage and the Country’s obligation under the Convention Concerning the Protection of the World Cultural and Natural Heritage, including with regard to chance finds.	12/31/2014	Completed
47	Updating SOPs to Protect Cultural Heritage: Based on its self-assessment on identifying and protecting cultural heritage, including chance finds (see above), the Company will develop and include relevant procedures its Code of Good Forestry Practices and its SOPs and ensure that such procedures are effectively communicated to field staff and transferred to contractors.	04/30/2015	Completed
48	Initial Areas to be Returned: Provide IFC the list of initial areas in Manica province to be returned to previous owners/users, including a registry of the company’s outstanding commitments or promised benefits to such owners/users under the Land Access Procedure so that these commitments can be completed and tracked accurately. Additional Areas to be Returned: Provide IFC a finalized list of additional areas in Manica province to be returned to previous owners/users, including a registry of the company’s outstanding commitments or promised benefits to such owners/users under the Land Access Procedure so that these commitments can be completed and tracked accurately. MITADER Support: Provide IFC evidence of MITADER support for the company’s proposed approach to bringing all Portucel areas currently outside of DUATs within formally authorized DUATs within a reasonable period of time.	08/15/2016	Completed
49	Communications Plan for Land Returns/Regularization Process: Prepare a communications plan for informing and consulting with key stakeholders, including local communities, on measures to return lands in Manica and to regularize areas outside of existing DUATs.	06/30/2016	Completed
50	ESIA/EMP Gaps: Submit to IFC a plan for how the company will address gaps in its ESIAs and EMPs as identified during the Impacto review. Regularization of off-DUAT areas: Provide a quarterly update on regularization of the areas the company has acquired outside of the DUAT’s provided by the GoM in 2009 and 2011.	07/31/2016	Completed