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

The proposed investment has been assessed as an E&S Category B investment. Category B projects according to IFC’s E&S Review Procedure are those that result in a limited number of specific E&S impacts that can be avoided or mitigated by adhering to industry recognized standards, guidelines and design criteria.

While all Performance Standards are applicable to this investment, IFC’s environmental and social review indicates that the activities associated with the project must be managed in a manner consistent with the following Performance Standards:

PS1: Assessment and Management of Environmental and Social Risks and Impacts
PS2: Labor and Working Conditions
PS3: Resource Efficiency and Pollution Prevention
PS4: Community Health, Safety and Security
PS5: Land Acquisition and Involuntary Resettlement

PS7 on Indigenous Peoples does not apply at this stage of the project as no indigenous peoples are identified in the areas of company’s operations for the purposes of the application of PS7. PS6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources is also not triggered. No biodiversity sensitive areas were identified to date in the areas of company’s operations. A biodiversity assessment study will be developed for Algeria as part of the environmental and social impact assessment (ESIA). PS8 on Cultural Heritage is not triggered as no archaeological or other cultural sites were identified. However, a chance find procedure is used in all company’s operations. Archaeological assessment is going to be conducted for Algeria as part of the ESIA.

All Performance Standards will be considered during ESIA preparation for the development phase of any of the expansion projects, and will be considered during audits commissioned for existing operations.

The World Bank Group’s Environmental, Health & Safety (WBG EHS) Guidelines that are expected to be applicable to this investment are:

General EHS Guidelines,
Offshore Oil and Gas Development, and
Onshore Oil and Gas Development.


Most relevant environmental, social, health and safety risks and issues related to this investment include the company’s capacity to concurrently manage multiple projects and implement an integrated environmental, social, health and safety management system at the corporate and site levels, and management of the following onshore and offshore oil and gas aspects: i) social and environmental assessment commensurate with the impacts of the company’s projects during the exploration, construction and operational phases including the assessment of potential cumulative impacts; ii) the social, environmental, health and safety performance of its contractors in accordance with good international practice; iii) fair, safe and healthy working conditions for direct employees as well as for contractors’ staff; iv) water resources, wastewater and effluents, air emissions and green house gases, hazardous materials, non-hazardous and hazardous solid wastes; v) the impacts on local ambient air quality, blow-out and spill prevention, emergency response plans, community health, safety and security; vi) consultation and engagement with potentially project-affected communities; vii) land use / acquisition and compensation issues; viii) adverse impacts on the natural flora and fauna within a project’s area of influence; and ix) archaeological resources.

Key environmental, social, health and safety issues are included in the Environmental and Social Action Plan (ESAP) and will be addressed by the company. E&S issues relating to the investment are summarized below along with specific information on how potential impacts and risks are addressed by the company. Upon implementation of the specific agreed-upon measures, the project will comply with environmental and social requirements, namely applicable host country laws and regulations (Algeria, Bulgaria and Egypt), and recognized good international industry practice, as well as IFC’s Performance Standards on Social and Environmental Sustainability.

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.

At the parent company level, Petroceltic has committed to the development of an integrated Health, Safety, Environmental and Social Management System (HSE MS). Petroceltic is presently going through an integration process (Petroceltic – Melrose) including the development of a consistent company-wide Corporate HSES Policy and Management System Framework, which have been completed and will be presented to the Board for approval in March 2013. The HSE MS will incorporate the requirements of IFC’s Performance Standards.



Petroceltic and Melrose HSES Management systems broadly operate on consistent frameworks including the following key components:



Corporate Policy

Corporate HSES Framework Document

Corporate HSES Standard/Guidelines/Procedures

Country Management Systems

Operational Procedures

Bridging Documents to Prime Contractors



Currently, there are no major incompatibilities between the existing management systems of Petroceltic and Melrose. In practice this means the operations in Bulgaria and Egypt are continuing under the Melrose HSES Management system; however, the country managers are fully involved with the Integration Process.



At the country level, company operations in Egypt and Bulgaria have HSE MS certified in 2011 via ISO 14001 and OHSAS 18001 standards. The country level HSE MS will be reviewed and updated to address any gaps in relation to the newly approved parent company HSES MS and IFC’s Performance Standards. Operations in Algeria (new development) will be based on the newly formed integrated Corporate HSES MS.



Country-specific Issues in Egypt, Bulgaria and Algeria:



Egypt:



Petroceltic’s integrated HSE management system implementation is being monitored by an established HSE committee that holds HSE meetings on a regular (monthly) basis. Government representatives often attend these meetings.



Safety performance is closely monitored in terms of incident recording and investigation. Petroceltic management however considers that the statistics relating to near misses may not reflect the actual situation on the ground due to the limited numbers reported. Additional effort is required to make use of the existing observation system.



The company has an established HSE organization including management, technical and administrative personnel in the head office and at field locations. Petroceltic is also supported by consultants on an as needed basis. Nonetheless, the roles and responsibilities for HSE system implementation are unclear within some parts of the organization and these roles and responsibilities are being clarified as part of the corporate integration plan.



ESIAs are conducted for each project, and procedures are in place for the management of HSE and social issues. A monitoring and reporting system is established, and audits are conducted at company sites including contractors and suppliers. HSE reports are regularly prepared for management and for government authorities, and the repor
ts include company and contractor safety performance, incident records, drills carried out, audits and inspection results, waste disposal records and HSE training records. However, the management of daily records (ex. effluent quality parameters) would benefit from a more disciplined on-site record keeping. The company establishes training programs on a yearly basis, including external training (ex. for internal auditors).



Emissions monitoring is carried out by a third party acting on behalf of the government authorities. Government inspectors also visit the sites periodically (often random and/or unannounced) to inspect HSE parameters and conditions. Petroceltic in Egypt reports regularly to the government on environmental issues.



The company interacts frequently with the local communities, particularly in relation to the land use and compensation programs. The process of land lease and compensation is highly regulated in Egypt and compensation rates are established by the government. Petroceltic has a formal grievance mechanism in place and grievances are logged and addressed. The company also interacts with the local population offering preferential employment opportunities for some unskilled labor needs.

The company suffered minor operational disruption as a consequence of labor strikes in 2012 associated with the social uprising in Egypt, but was able to resolve the issues amicably and re-establish safe operations.



Social issues of operations will be integrated in the overall Management System of the company, including stakeholder – issue mapping and an appropriate consultation and disclosure mechanisms for those stakeholders.



Bulgaria:



Petroceltic is implementing its ISO 14001 and OHSAS 18001 certified (2011) Management System, which covers the operations of the current Galata offshore production facility and the onshore gas dewatering and compression facility. The HSE MS will be reviewed and updated to address any gaps in relation to the newly approved parent company HSES MS, IFC’s Performance Standards and new project requirements.



Petroceltic conducted and ESIA for the Galata field development in 2002 in accordance with Bulgarian environmental law and regulations. The ESIA included all components of the project and all offshore and onshore facilities. As a part of ESIA a baseline study was also conducted and approved by the authorities. Public hearings are a part of country’s regulatory requirements and public consultations were held in the nearby communities during the development of ESIA for the project. Additional community inquiries were incorporated and addressed in the final ESIA report that was subsequently approved by the local authorities.



Regarding ESIA requirements for the future projects to be developed by Petroceltic in the country, an ESIA is not required for exploration (i.e. Kamchia - Exploration well) as per the local environmental legislation. Further, the exploration well work program is appro
ved by the Ministry of Energy (ME) and during this process the ME seeks concurrence from the Ministry of Environment (internal government procedure).



Petroceltic submitted the Kavarna East development investment proposal indicating an extension of the Kavarna facilities (already granted an environmental license) and indicating a daily production of less than 500,000 m3 per day, which is below the threshold that the environmental regulations require for conducting an ESIA. The no requirement of an ESIA was confirmed in writing by the Ministry of Environment.



As for the tie back into the existing system of the original discovery well, the latter is within the existing production concession boundary and, unlike the Kavarna East development, no new investment proposal needs to be submitted. Petroceltic is presently submitting an amendment to the Annual Work Program to inform the Ministry of the corrective action required to deal with the changing reservoir conditions (i.e. tie back the existing well). This also falls below the threshold requiring the execution of an ESIA. Nonetheless all of the above, Petroceltic will determine the need to conduct ESIA or specific environmental and/or social studies based on the characteristics of the projects and the environmental and social context, in accordance with IFC Performance Standards.



Petroceltic developed and implements a monitoring program for its offshore operations including marine water quality and biological sampling, and ambient air. Noise and ambient air are monitored in the compression facility by independent third party contractors. Air emission monitoring (onshore and offshore) is conducted by a third party and is submitted to the government as part of the reporting. The Ministry of Environmental Affairs conducts annual inspections to the company’s facilities to ensure compliance with local regulations.



The facilities are well-maintained and staffed with highly skilled workers and engineers on site, and housekeeping is well managed. The organizational capacity at Petroceltic’s operations in Bulgaria is commensurate with the scale of its operations (40 people), and is reliant on a core group of highly skilled engineers. The HSE function is integrated into the operations and there is a high level of awareness of the HSE MS, including among administrative personnel. The Managing Director leads all aspects of operations including HSE and social, and participates in the ongoing integration process with the Petroceltic corporate HSES MS. Community grievances and community engagement are also handled by the Director.



Algeria:



Petroceltic will develop and implement a country level HSES MS aligned with the corporate integrated HSES MS and in compliance with IFC Performance Standards.



Petroceltic commissioned a preliminary ESIA for the Isarene Permit, including provisions of environmental baseline survey. The study was completed in Q1 2012 (by Sogreah Consultants), indicating
in general no sensitivity (0) to negligible sensitivity (1) to the following environmental and social aspects, including physical (landscape, air, noise), biologic (fauna, flora, protected ecosystems), and human (urbanism and activities, agriculture, and archeological sites). Only water resources (physical) received a middle sensitivity (3 of a maximum of 4) since water reserves (groundwater) in the Sahara desert are rare and very sensitive (and source renewal is very low). Groundwater is used by industries that are already present in the area. No surface water was observed at any of the 5 locations surveyed, and only 2 water wells were observed at one location surveyed (location 4). No protected areas, agricultural or oasis areas were identified inside the block. However, the permit area is a pasture transit area for herds of camels. During the field survey, no historical, cultural or religious heritage places were identified; however, a Muslim grave was discovered in the area of location 5.



ESIAs will be developed for each drilling campaign and the development project to meet local regulations and in accordance with IFC’s Performance Standards. Environmental and Social Management Plans (ESMP) will be developed consistent with the corporate integrated HSES MS for each asset in the country, detailing the procedures necessary to ensure that the environmental and social impacts associated with the construction and operation of the projects are managed in accordance with IFC’s Performance Standards and applicable world Bank Group’s EHS Guideline provisions.

Egypt:



The company has 88 staff in Egypt. Labor rights and labor organizations are governed by Egyptian law. A Human Resource policy is in place for Petroceltic employees. Mansoura Petroleum company employees (the Operator) are either government or direct employees (due to the 50% ownership of the state oil company EGPC), so the human resource policy is defined by the government. There are however, detailed policies and procedures relating to all petroleum company recruitment and employment conditions. Employees have documented contracts containing their employment terms and conditions. There is a labor syndicate in Egypt for oil workers. Workers’ grievances mechanisms are established in accordance with the local regulations and are in material compliance with IFC requirements. An anti-discrimination policy is in place and retrenchment is not planned or anticipated.



As described in PS1 above, in Egypt Petroceltic records their annual safety statistics and reports these to the regulator and management. There have been no fatalities in Petroceltic’s facilities in Egypt. Petroceltic has reached the milestone of one million person hours worked with no Lost Time Injuries (LTIs) on more than one occasion, the most recent in 2012. All incidents and major near misses are investigated. Emergency drills are conducted at Petroceltic sites, and drills cover a number of events including fire scenarios, gas leaks, site evacuations and serious injury cases. Routine workplace air quality and noise measurements are made at Petroceltic sites. There is a doctor and clinic at each site to deal with any incidents and look after the general well being of the staff.



All staff are provided with mandatory health and safety training induction. Field facilities visited (including the contractor drilling rig) demonstrate that close attention is paid to occupational health and safety. The mandatory use of personal protective equipment (PPE) is clearly followed by staff. Workplace air quality and noise monitoring is carried out by a third party on behalf of the regulatory authorities.



Fire and life safety equipment is clearly available on site including passive protection systems to prevent the ignition and spread of fire. Firewater storage tanks are on site and a site specific fire fighting system is also on standby, along with staff specifically trained in fire fighting techniques.



There is an emergency response plan in place for the workforce at Petroceltic operational locations and drilling sites and training including response drills are routinely carried out.



Contractors are managed in accordance with bridging documents. A visit to ongoing drilling operations in the field indicated a high quality operation. Petroceltic had no specific information on the other contractors and suppliers in their supply chain but none were considered a risk in terms of labor issues or poor environmental performance.



Operations in Egypt have suffered recently
(2012) from work stoppages (strikes) associated with the Egyptian revolution and subsequent political and social movements. The company has been able to manage these issues in a positive way without major incidents and re-establishing safe operations.



Bulgaria:



Bulgarian staff consists of about 40 people. Hiring, compensation and retention of workers is guided by the Bulgarian local regulatory requirements and in material compliance with IFC requirements. The terms of employment are documented, disclosed to and agreed with the potential workers. Labor union for oil and gas workers exists in the country. Workers grievances mechanisms are established in accordance with the local regulations and are in material compliance with IFC requirements. An anti-discrimination policy is in place and retrenchment is not planned or anticipated.



The safety culture among the company employees is high and the company has reported no accidents in its operations in 2012. The use of contractors in the project is minimal (waste management and logistic services), and Petroceltic only uses contractors that are certified by the government to perform their functions. The future potential use of drilling and completion contractors may require a reassessment of contractor management procedures tailored to the specific operations.



Algeria:



There are currently no operations in Algeria and no local staff. Hiring, compensation and retention of workers and workers grievances mechanisms will be guided by the Algerian local regulatory requirements and in material compliance with IFC requirements. Health and Safety processes and procedures will be implemented in accordance to the integrated corporate HSES MS to ensure safe operations and a robust safety culture. The future potential use of service contractors will require bridging documents between Petroceltic and contractors’ HSES MS and tailored to the specific operations, and environmental and social context.

Egypt:



Principal sources of pollution from Petroceltic activities in Egypt are typical of onshore oil and gas operations and related to emissions to air, waste waters, drilling wastes and other wastes.



Petroceltic has an emission and waste water measurement program in place, and the company routinely monitors stack emissions and exhausts, and effluents. Results indicate general compliance with standards, and breaches are addressed through equipment overhaul and maintenance programs.



Emissions to air originate from processing facilities discreet sources including: generators, compressors, pumps, heater units and flaring activities and additional small amounts from mobile vehicle sources along with fugitive emissions. Power is provided from the national grid with diesel fuelled generators for back-up. Emissions monitoring from each emissions stack are carried out by a third party on behalf of the regulatory authorities. The level of emissions is compliant with Egypt regulatory requirements. There is no sour gas and no emissions of hydrogen sulfide at any of the Petroceltic fields in Egypt.



Only very small volumes of gas are flared at each of Petroceltic’s processing sites (mainly purge gas), and rich gas streams are captured and converted to LPG (i.e. West Dikirnis). LPG production is transferred by pipeline to the relevant government agency (PPC) and thence to an LPG bottling plant.



Produced and process water are routed to API treatment systems and concrete lined holding tanks, and re-injected at South Batra/West Dikirnis and Tamad facilities via disposal wells (>1,000 m depth). An effluent back-up system (used if injection is interrupted) includes transportation to a common treatment and disposal stream site in the region, with the effluent collection contractor (authorized by the regulator) responsible for treatment and final disposal. At other locations the water is contained in evaporation pits.



Petroceltic has developed an asset or facility integrity program, completed an intelligent pigging program for all main trunk lines, and developed a pipe replacement program for sections approaching the critical loss levels in wall thickness. Pipe monitoring and replacement is ongoing. There have been only a small number of minor spill incidents.



There are no naturally occurring radioactive materials (NORM) found at any of the Petroceltic fields in Egypt.



Oil storage tanks at the West Dikirnis oil field are all fitted with floating roofs that reduce fugitive emissions during storage. All condensate tanks are also fitted with floating roofs.



Sewage is collected in septic tanks and collected periodically for transportation to a municipal sewage facility for treatment and disposal.



Drilling is generally carried out using water based drilling fluids which have limited toxicity. The fluids and drilled cuttings from the wells are collected in a disposal pit alongside the drilling operations. The pits are lined to avo
id subsurface contamination. These pits are rehabilitated by removing the liquids and mixing the cuttings solids with soils in accordance with standard industry practice. In some cases the dried cuttings are removed and transported to an industrial site approved by the government for disposal.



In addition to waste waters, drilling fluids, and drilled cuttings, other wastes generated at Petroceltic facilities are segregated into non-hazardous and hazardous wastes onsite. Non-hazardous refuse is collected by a licensed contractor and taken to a local authorized municipal site for disposal. Hazardous wastes (e.g. waste oils) are handled by contractors licensed by the government for treatment, recycling and/or disposal. Petroceltic is not fully aware of the final disposal of each of the waste streams generated and need to develop and follow up on improved waste management manifest/protocols to track the final disposal of all waste.



Limited amounts of hazardous materials are stored on site. Observed storage is in specifically segregated areas appropriate for this purpose. Material Safety Data Sheet (MSDS) are available on site.



There is an emergency response plan in place for Petroceltic operations in Egypt. The plan contains the procedures to follow in the event of a spill (oil or chemical), spill kits are available on site at few locations. The facilities are well designed to contain spills with secondary containment available around storage areas. Spill response is to be undertaken in coordination with the local authorities. As part of ESAP the company will upgrade its ERP procedure and, in particular, will enhance Oil Spill Contingency Procedures.



Petroceltic rehabilitates any land used for drilling or following pipeline installation. Topsoils are preserved, the area re-contoured and the topsoil replaced to previous conditions so that the original land use can be restored.



Petroceltic has confirmed that they comply with the local HSE laws and regulations, do not have any current or anticipated environmental or health and safety issues or litigation and they have complied in full with all of their obligations under any ESIA reports or management plans.



Bulgaria:



At its current stage of mature production, monitoring of ambient air emissions onshore and offshore as well as monitoring of the quality of water is routinely carried out in order to prevent environmental damage. The company confirmed compliance with local regulatory requirements.



Waste water from dewatering of gas project as domestic sewage is removed from the facility by a certified municipal contractor for further processing at the municipal water treatment plant. Solid wastes are removed by certified third party contractors for proper disposal.



Hazardous wastes are removed by certified third party contractors for proper disposal.



Petroceltic has confirmed that they comply with the local HSE laws and regulations, do not have any current or anticipate
d environmental or health and safety issues or ongoing litigation and they have complied in full with all of their obligations under ESIA reports or management plans.



Algeria:



Principal sources of pollution from future Petroceltic activities in Algeria will be typical of onshore oil and gas operations and related to emissions to air, waste waters and effluents, drilling wastes and other wastes. Petroceltic will comply with the local HSE laws and regulations, and with IFC Performance Standards, WBG’s EHS Guidelines and O&G industry sound international practices. Further, Petroceltic will comply with the requirements under any ESIA reports and environmental authorizations. The efficient use and adequate extraction of water for oil and gas exploration and development activities will be studied and particularly assessed to minimize adverse impacts, as well as the disposal of waste water and effluents, and in particular evaluating the use of waste water and effluent injection versus the use of evaporation ponds (assessment of potential cumulative impacts).

Egypt:



Community health and safety is considered in the hazards assessments conducted in planning transportation routes and in preparing for potential accidental events and emergencies. Transportation routes take into account residential areas. Ambient air quality monitoring has been carried out in a “residential area” by a third party on behalf of the regulatory authorities and results indicate no deterioration in air quality.



Petroceltic staff on site is composed of Egyptian nationals and many are from the nearby communities, consequently there is minimal risk of cultural conflict while at the same time enhancing community acceptance.



Oil spill contingency plans are reviewed and updates are made to the oil spill emergency response system. The company will ensure that HAZID and HAZOPS are conducted and results incorporated in the designs, Emergency Response Plans (ERP) and Oil Spill Response Plans (OSRP).



In Egypt, Petroceltic facilities are of modern designs and in line with good international industry practice. Facilities are sited and operating procedures are designed to prevent any exposure to the communities from operational hazards. Further, facilities are designed to withstand natural environmental hazards in the locations that they are constructed and designed for the life of the project. Adverse impacts to the surrounding environment from routine activities are minimized through design and through good industry operating practices.



The ERP described in PS2 above also includes the potential for an emergency to impact local communities for each of the locations in Egypt. Community response measures are defined and will be directed by the authorities and the authorities are aware of the response measures to be taken to protect the communities.



Security arrangements are made through the employment of local people. Petroceltic has contracted security specialists to train their security personnel. Security personnel are not armed at Petroceltic facilities.



Bulgaria:



In Bulgaria, Petroceltic facilities are of modern designs and in line with good international industry practice. Facilities are sited and operating procedures are designed to prevent any exposure to the communities from operational hazards. Facilities are designed to withstand natural environmental hazards and designed for the life of the project. Adverse impacts to the surrounding environment from routine activities are minimized through design and through good industry operating practices.



Emergency plans are in place and emergency training is conducted for the employees. No local communities are located around project’s installations. Local authorities are informed and have approved of the plan. The company committed to conduct HAZIDs and HAZOPSs and incorporate their results in the project designs, ERP and OSRPs.



The gas processing plant is guarded by two unarmed guards. The Galata is an unmanned offshore rig and it is not guarded. The fa
cility is monitored remotely by the use of cameras via internet. No incidents or conflicts with the local population have been reported.



Algeria:



There are no communities or housing inside the permit area, the nearest community is located about 80 kilometers away from project site. The population inside the block is composed of operators’ living quarters.



A Security Vulnerability Assessment (SVA) will be conducted for the block (people and assets) and an action plan developed prior to starting any related activities in the area.

Egypt: The company engages with the communities on HSE and other operational issues on a regular basis. Petroceltic maintains a good relation with the nearby communities, also optimizing local employment through hiring preferences, and by using local goods and services where possible. It also focuses on promoting employment opportunities amongst local communities affected by land acquisition associated with exploratory seismic surveys and drilling, and the establishment of long term/ permanent facilities.

Petroceltic offers financial assistance to a number of local social programs, including contribution towards building new schools to serve the communities near its operational areas (example West Dikirnis, Mansoura). The company also supports a variety of community development activities (e.g. improvement to access roads, religious facilities, and skills training, etc). Local authorities assume financing of day to day operations of the schools. Petroceltic continues to face the challenges related to social investment; specifically the sustainability of these investments and managing local stakeholders’ expectations (the company receives numerous demands for a wide number of community support projects).


Bulgaria:The company has engaged with the communities throughout the ESIA process. Social investment by Petroceltic in Bulgaria to date consisted mainly in supporting a center for children with special needs (Karindom) and contributing to rebuilding of a local church.

Algeria:

The company will engage with the communities (located outside the block) and with identified nomads throughout the ESIA processes.

For all its assets in Egypt, Bulgaria and Algeria, as part of the new corporate and revised country level integrated HSES MS, and future project activities and operations in the countries, the company will develop as part of the corporate HSES MS a Stakeholder Engagement Plan that will define a consultation and disclosure strategy.

The Stakeholder Engagement Plan will inform interested parties and maintain an open and active communication with all stakeholders. The Stakeholder Engagement Plan will also include provisions for the disclosure of major ESIA documents associated with the project and include a defined grievance mechanism.

Furthermore, the company will prepare specific corporate and local level Community Development Plans (CDP) which will enable a more structured approach to community development initiatives to optimize contributions to longer term local sustainable development.

General information concerning the company''s environmental, health and safety performance can be obtained for review from the following locations in Dublin, Egypt, Bulgaria and Algeria:

Dublin (Corporate Head Office)75 St Stephen’s GreenDublin 2Ireland
Telephone:   +353 1 421 8300Fax: +353 1 421 8301Email: mailto:info@petroceltic.ie
Contact: Peter Dunne (Managing Director, Finance)


Melrose Resources Egypt Companies
3/C Lasilky ZoneAhmed Kamel STreetNew MaadiCairo 11431
Telephone:   +202 2520 3835Fax: +202 2517 2529
Contact: Said el Salmy (General Manager & Country Manager)

Bulgaria

Melrose Resources Sarl
32 Marko Balabanov StreetVarnaBulgaria
Telephone:   +359 52 699 556Fax: +359 52 601 195
Contact: David Archer / Dorieta Angelova (Managing Director)

Algeria

Petroceltic International plc
Grove House
2 Orange Street
London WC2H 7DF
Contact: Geoff Probert (Managing Director)

Broad Community Support is not applicable for this project

Task Title/Description	Completion Date
1. Assign Health, Safety, Environmental and Social Affairs Corporate Manager. Designate an appropriately qualified individual supported by adequate financial and professional resources with overall Health, Safety, Environmental and Social (HSES) corporate responsibilities or retain a qualified consultant to fulfill role in a full time capacity until permanent hire is completed.	4/01/2013
2. Prepare Environmental and Social Impacts Assessment (ESIA) ToR for all Projects under development by the Company in Algeria, Bulgaria and Egypt. Specifically, for Isarene Block projects (including Ain Tsila Field development) include in the ESIA ToR the following additional supporting baseline surveys and alternatives analysis for: a) Water source management and waste water/effluent disposal feasible options. b) Cumulative impacts throughout the anticipated field development program cycle	4/01/2013
3. Develop and approve by the Board an Integrated Corporate Health, Safety, Environmental and Social (HSES) Policy and Management System (MS) Framework consistent with the IFC Performance Standards.	4/30/2013
4. Develop Integrated Corporate HSES MS Procedures and Guidelines consistent with the IFC Performance Standards and applicable World Bank Group EHS guidelines, for application at all Petroceltic portfolio assets in Algeria, Bulgaria and Egypt. These to include as a minimum: (i) Process to conduct HAZIDs and HAZOPs; (ii) Emergency Preparedness & Response Plans, including events that may impact the environment and communities and the roles and responsibilities of Petroceltic; (iii) Oil Spill Contingency Procedures; (iv) Acquisition / Farm-in screening mechanism for compliance with Petroceltic HSES MS and IFC Performance Standards, identifying any potential material non-compliances; (v) Framework Public Consultation and Disclosure Plan, Framework Land Acquisition and Compensation Plan, Community Development Strategy; (vi) Grievance Mechanism for potentially affected communities, including an inquire/complaints procedure defining who is responsible for receiving inquires/complaints, processes followed for recording and acting on inquires/complaints and process for following through, communicating and closing inquires/complaints; (vii) Chance Finds Procedure to address impacts to, and protection of cultural property encountered during project activities; (viii) Waste Management Plans identifying the type and quantity of waste streams generated at Petroceltic operated and co-operated assets along with available disposal routes, treatment and reuse, manifests and protocols for determining ultimate treatment and final disposal of wastes; (ix) Contractor HSES management; and (x) Training protocols and plans for Petroceltic staff and contractors undertaking activities at Petroceltic operated or co-operated assets. Complementary training plans will be developed for office based staff.	7/30/2013
5. Roll out and communicate to all Petroceltic locations and personnel (including direct contractors) the integrated Corporate HSES MS, including Policy, Framework, Procedures and Guidelines, Roles and Responsibilities.	8/30/2013
6. Update country / site level HSES MS to ensure consistency with the revised corporate integrated HSES MS.	10/30/2013
7. Update (and develop as necessary) Environmental and Social Management Plans (ESMPs) consistent with the HSES MS for each asset in the Petroceltic portfolio. The ESMP will detail the procedures necessary to ensure that sites are managed in accordance with IFC Performance Standards and applicable WBG EHS guidelines. ESMP will contain, at a minimum, an emergency response plan, a spill control plan, a waste management plan and a stakeholder engagement plan.	10/30/2013
8. Roll out and communicate to all Petroceltic locations and operated assets (including Melrose and Mansoura Companies) and personnel (including direct contractors) the updated country/site level HSES MS, including Roles and Responsibilities.	11/30/2013
9. Prepare and initiate execution of Environmental and Social Audit programs (external) for all existing Petroceltic assets: Agree ToR for qualified independent third party consultants to undertake HSES audits against national regulatory requirements and IFC''''s Performance Standards and WBG EHS Guidelines for operated and co-operated producing assets.	03/30/2014
10. Complete Environmental and Social External Audits for existing Petroceltic assets against national regulatory requirements and IFC''''s Performance Standards and WBG EHS Guidelines for operated and co- operated producing assets.	12/15/2014