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 IFC's 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

This is a category A project primarily due to the likelihood that potentially significant and diverse impacts could be associated with some of Delonex activities.

The key environmental, social, health and safety risks associated with this proposed investment include: the Company’s management capacity to acquire and develop oil and gas projects, including how environmental and social consequences (including cumulative impacts as appropriate) are taken into account in planning, design, construction and operation. The key issues to be considered are an appropriate corporate environmental and social management system that ensures adherence to IFC’s Performance Standards; development of ESIAs that meet IFC’s Performance Standards, applicable guidelines, and Good International Industry Practice (GIIP); development of stakeholder engagement and consultation plans with affected communities, land acquisition and compensation associated with all project elements; potential E&S impacts from associated facilities; fuels/hazardous materials storage and handling; emergency response planning and preparedness; and labor and working conditions, including employee retrenchment and health and safety. Delonex has committed that, upon implementation of the specific measures detailed below, their activities will meet the requirements of the IFC Performance Standards.

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.

Delonex’s commitment to manage environmental and social performance is embodied in the following strategic goals:

Proactive safety culture focused on continuous improvement and the best-in-class processes and procedures supported by strong visible leadership;

Minimize the impacts of Delonex activities on the surrounding environment and communities, through a well defined process based on “plan-do-act-check”;

Ensure human rights are respected by Delonex employees; and

Mitigate adverse social impacts and make a positive difference in the daily lives of the communities residing near their assets.





Policy



To achieve these directives, the Company adopted separate corporate policies: (i) Health and Safety and Security; and (ii) Environment and Community. Each policy reflects best practices across relevant areas.

Delonex, as part of further development of its internal policies will develop and implement an integrated HSEC Policy to identify, assess and adequately manage existing Environmental, Social, Health and Safety (ESHS) risks and impacts from exploration and development activities. The HSEC Policy will be developed to integrate IFC’s Performance Standards and GIIP, the current versions of the IFC EHS General Guidelines and Oil and Gas Onshore/Offshore Guidelines.To ensure compliance with the above referenced policies, Delonex does not partner on projects with third parties where such party is not willing or unable to comply with these Principles.

The HSEC Policy will be communicated directly to employees when they are hired, and through regular training events at regional offices and project sites.



Identification of Risks and Impacts



The Delonex process for identifying risks and impacts of prospective projects begins with the early stage screening process. This initial review involves the preliminary identification of key risks and impacts associated with the project, as well as historic environmental or social issues. Delonex also considers their capacity to manage these expected risks and impacts and the role of third parties in achieving compliance with the Principals in deciding whether to pursue the opportunity.



Once a project’s feasibility is ascertained, Delonex will rely upon a variety of available assessment tools and approaches to identify the detailed environmental and social impacts and risks of projects before it decides to proceed with development or acquisition. For the development and construction of greenfield projects (if any), Environmental and Social Impact Assessments (ESIAs) will be prepared. Following the principles of international best practice for ESIAs development, this will conform to the requirements of the host country’s laws and regulations, as well as those of IFC’s Performance Standards.



When considering acquisition of existing assets, the Company will conduct reviews or audits of prospective assets benchmarked against Delonex policies and standards to determine areas of concern
and identify necessary mitigation measures to ensure compliance with relevant requirements.



Management Programs



The findings of the project-specific ESIAs or acquisition audits essentially will detail a program of mitigation and performance improvement measures and actions necessary to effectively manage the E&S risks and impacts of each of its projects in line with corporate policy. Project-specific assessments, audits, and goals will be used to establish action plans and metrics for project construction and operation. EPC contracts for each project will incorporate the relevant project-specific mitigation measures and actions during the assessment/audit process and appropriate standards to ensure compliance with host country requirements, as well as the IFC Performance Standards.



Delonex will complement the project-specific mitigation measures described above, with the development of a set of environmental and social corporate standards and requirements that will help ensure consistent application of Delonex Policy on Environment and Community, Health, Safety and Security. This will involve development of standard operating procedures (SOPs) and/or management plans tailored to Delonex’s business and address mitigation of the following impacts and risks covered in the Policy’s principles and consistent with PS3 through PS8. The principles guiding the SOPs should be suited to avoid, or where avoidance is not possible, minimize adverse impacts on human health and the environment. A key feature of these SOPs will be the use of ongoing ambient environmental monitoring throughout the life of the project to inform any necessary corrective actions that might need to be taken should unanticipated impacts arise – commonly known as “adaptive management”:



PS3 (Pollution Prevention). SOPs should apply appropriate and relevant recommendations of applicable World Bank Group EHS Guidelines (i.e., General, Oil and Gas Onshore/Offshore). To address impacts related to PS3 Delonex will take into consideration the application and implementation of technically and financially feasible and cost effective measures for improving the Project’s consumption of energy, water as well as other resources and material inputs, and the reduction of Delonex activities Green House Gases (GHGs), with a focus on areas that are considered core business activities. Additionally, Delonex will develop a Pollution Prevention Plan to set specific procedures for the storage, handling and transportation of fuel products and requirements in case of accidental spills.

PS4 (Community Health and Safety). SOPs should anticipate and avoid adverse impacts on the health and safety of the Affected Community during the project life from both routine and non-routine circumstances. Additionally, the SOP should consider safeguarding of personnel and property maintaining high levels of human rights principles and avoidance or minimization of impacts to affected communities. Key componen
ts for the Community Health and Safety SOP:

Delonex will develop and implement as part of the SOP a driver and traffic safety program proportional to the project activity according to the principles outline in the General EHS Guidelines (Section 3.4 Traffic Safety). Where transport-related activities are performed by subcontractors, Delonex will use commercially reasonable efforts to influence the safety of these service providers, contractually requiring traffic safety risk analysis and adoption and implementation of driver safety programs.

Delonex will develop an SOP addressing emergency preparedness and response, based on the risk to the health and safety of the Affected Communities and other stakeholder from their activities. The plans will be developed in close collaboration and consultation with potentially Affected Communities and other stakeholders and should include detailed preparation to safeguard the health and safety of workers and the communities in the event of an emergency.

Delonex as part of its Management Systems will develop a Security Policy and a Code of Conduct for security personnel and public security forces consistent with the requirements of PS 4 and incorporating the relevant guidelines of the Voluntary Principles on Security and Human Rights. The Code of Conduct shall set clear objectives for the work of security personnel and permissible actions, and be based on applicable law and professional standards. These instructions will also be communicated as terms of employment and through periodic training.

Delonex will prepare a framework for the preparation and implementation of a labor influx management plan, including procedures to minimize the risk of incremental/accidental community exposure to disease and other potential host community impacts due to influx of labor.

PS5 (Involuntary Resettlement) and PS7 (Indigenous Peoples). Delonex will

Develop procedures to ensure compliance with requirements for the management of land acquisition, resettlement and rehabilitation of project-affected people;

Develop a Stakeholder Engagement Plan (including a Grievance mechanism) that takes into consideration a process of consultation with Affected Communities to allow them to express their views on project risks, impacts and mitigations. If Indigenous Peoples are identified within the area of influence of the project, Delonex will conduct an Informed Consultation and Participation (ICP) process and obtain their Free, Prior, and Informed Consent (FPIC). As part of this stakeholder engagement process, Delonex will also ensure that the local communities are aware of potential development pathways by clearly explaining the possible outcomes of the project activities including their potential impacts and mitigation measures.

PS6 (Biodiversity Conservation). Delonex will develop a flora and fauna management plan/procedure in line with PS6 as part of the development of its HSEC Policy. Additionally, Delonex will incor
porate a biodiversity screening/assessment process as part of its risk and impacts identification process within its corporate Management System.

PS8 (Cultural Heritage). Delonex will develop and implement a chance find procedure including for finds of archaeological, paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves; put in place procedures to protect and enhance sacred sites (e.g., ponds, forest groves, etc.) in consultation with community members.



Organizational Capacity



Delonex current organizational structure includes a CEO, Executive Director for Exploration and Subsurface, Director for Engineering and Operations, a CFO and a Regional Director for Africa. In turn, the Director for Engineering and Operations oversees the work on environmental, safety and security and the Regional Director for Africa will oversee the community relations staff. Delonex senior management values a relationship with IFC to assist the Company carry out its activities in line with GIIP.



In terms of Health, Safety, Environment and Community (HSEC) personnel, Delonex has one dedicated staff at the senior management level as well as one person directing the social and community development programs. Additionally, Delonex will hire an experienced HSEC consultant to support the initial development of the various plans and procedures as part of the HSEC Policy, as well as to support their project activities as needed.



Emergency Preparedness and Response



As part of IFC’s investment, Delonex will develop a robust Emergency Response Plan (ERP) outlining emergency scenarios and response actions, key contacts, and responsible staff. The Company will also conduct training to employees and contractors on the information within this Plan.



Monitoring and Review



As part of the development of the HSEC Policy, a monitoring, inspection and audit program will be developed together with key performance indicators (KPIs) to track information on environmental, health and safety and social management, training, incidents and spills, etc. The Company will also develop an Environmental Monitoring Plan to establish monitoring requirements for each type of activity (i.e. exploration, development and/or production) for the acquisition program.

Currently Delonex has a Human Resources (HR) Department and this function is managed by the Manager-Business Services and overseen by the CFO.



Delonex is a small Company that has been recently established and is in the process of assessing potential projects, thus the number of employees is limited. Delonex is committed that in their future operations their Human Resources policies will reflect good industry practices including: terms of employment; immigration, reference and background check; the work environment (including health, safety and security); payroll; travel and expense reporting; holidays; vacation; sick leave; maternity and paternity leave; other leaves of absence; benefits (insurance, retirement, health); employee terminations; and special local requirements.



Occupational Health and Safety



As detailed in the Delonex HSEC Policy, a safe working environment and a proactive safety culture are a priority in Delonex operations. Delonex is committed to establishing and to implementing secure systems to protect their employees, contractors and assets from risks of injury, property loss or damage.



Delonex expects each member of the team working either directly or indirectly for the organization, to understand, promote and actively assist in the implementation of its health and safety policy.



As part of the HSEC Policy, specific Health and Safety documents will be developed including detailed procedures consistent with GIIP to minimize accidents and incidents associates with Delonex activities. The procedures will include provisions for worker health and safety training (including contractors), emergency preparedness and response and contingency planning.



It is important that procedures be formalized within the HSEC Policy to manage existing risks to workers and communities. This in relation to use of PPE, safe working practices during the operation of drill rigs and other equipment, response activities in case of emergencies, etc.



Grievance Mechanism



As part of its Management System, Delonex will establish a grievance mechanism through which employees may raise their workplace concerns. The mechanism will establish the procedures for handling grievances, i.e., logging a grievance and mechanisms for resolution. Delonex will inform and train the employees on the availability of this mechanism. The procedure will recognize the rights of employees to access the national system for labor complaints and disputes of the Ministry of Labor or any other equivalent authority.

Delonex, in its various policies, recognizes the importance of stakeholder engagement, particularly with the communities where they operate. Engagement will be practiced commensurate with the identified risks and impacts to the affected communities through a process of information disclosure of assessment documentation, and consultation and informed participation. Currently, Delonex has not conducted any stakeholder engagement as they are in the process of identifying assets. However, a Corporate Social Responsibility office will be established to implement the Company’s direct work with communities.

Delonex will develop a corporate Community Engagement Framework (CEF) based on Delonex corporate policies and guidelines, local requirements, relevant experiences with existing operations, and IFC’s Performance Standards. For each greenfield or existing project with potential impacts on local communities, Delonex will develop and implement an appropriate Public Disclosure and Consultation Plan (PDCP) based on the CEF, to ensure that project-affected communities are provided with information and consulted on the risks, impacts and opportunities presented by each project and remain engaged on ongoing basis and provide a grievance redress mechanisms. For projects with potential significant E&S impact on local communities the PDCP will be designed to ensure their free, prior and informed consultation with regard to the risks and benefits of each project, and way in which those risks and benefits will be managed. If the proposed project affects communities of indigenous peoples (IPs), the PCDC will be aligned with the requirements of IFC’s PS7. The CEF will also include guidelines to ensure that the E&S audit process for the acquisition of existing assets also includes an assessment of community engagement activities and identification of gaps and corrective actions, if any.

Delonex considers voluntary community investment activities an integral part of its operations and overall corporate social responsibility. Every business will develops its own social responsibility plan based on the nature of the project and an assessment of community needs. Activities typically focus on community health and safety, environmental awareness and education, and employment.

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date
1. Environmental and Social Management System Sign on to a Corporate and Project-Specific Health, Safety, Environment and Community (HSEC) Policy that defines how the Company’s projects will be operated in line with the requirements of IFC’s Performance Standards, EHS Guidelines and country of operations legislation appropriate to the level of activities.	Within 2 months of subscription.
Retain an experienced international ESHS consultant / institution to satisfaction of IFC to support the company with a. Develop the necessary Elements/Programs and ESHS Management Plans/SOPs of the Corporate and Project Specific HSEC Policy	Within 3 months of the HSEC Policy completion
Develop the necessary Elements/Programs and ESHS Management Plans/SOPs of the Corporate and Project Specific HSEC Policy (as outlined in the ESRS) which are aligned with GIIP to address existing environmental, social and health and safety risks form current exploration activities.	Within 4 months of entering a new asset
Disclose the HSEC Policy on Delonex website.	Within 2 weeks of IFC’s approval of the HSEC Policy.
2. Environmental and Social Impact Assessment (ESIA)/Audit of Existing Assets For development of greenfield projects – prepare an ESIA align with IFC Performance Standards, GIIP and host country regulations	Publically disclosed for a minimum of 60 days prior to start of construction/operation.
For existing assets – conduct an audit of prospective assets against Delonex policies and standards, IFC Performance Standards and GIIP to determine areas of concern and identify necessary mitigations (that may include further impact assessments) to ensure compliance with relevant requirements	As part of due diligence of asset acquisition.
3. Stakeholder Engagement and Communications Develop a Corporate Stakeholder Engagement Framework, a Grievance Mechanism and Procedure and a Communications Program to identify/map key stakeholders and engage and communicate with the affected community and stakeholders in a frequent and effective manner. Reference: Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets (May 2007); “Addressing Grievances from Project Affected Communities: Guidance for Projects and Companies on Designing Grievance Mechanisms”, IFC, 2009.	Within 6 month of subscription
Develop a Corporate and Country-Specific Stakeholder Engagement Framework, a Grievance Mechanism and Procedure and a Communications Program to identify/map key stakeholders and engage and communicate with the affected community and stakeholders in a frequent and effective manner.	Within 3 months entering a new asset
4. Land Acquisition and Compensation Develop and implement a Land Acquisition, Compensation and Resettlement Framework (including land use and temporary access) to outline the principles, guidelines and approaches that will be followed for land acquisitions and compensation activities in accordance with PS5 requirements.	Within 6 months of subscription
5. Indigenous Peoples If Indigenous Peoples are identified, retain services of a qualified expert to ascertain whether there are Indigenous Peoples in their area of influence.	Within 3 months of entering a new asset
If Indigenous Peoples are identified in the area of influence develop an Indigenous Peoples Plan (IPP) in accordance to requirements of PS7.	Within 6 months of IP study completion.