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
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria as is described in the following sections.

Key environmental and social issues identified during the due diligence include: environmental and social management capacity; compliance with local permits and licenses, including construction and operation permits; initiatives for energy, and water conservation; management and planning of life and fire safety in the campuses; labor and working conditions including occupational health and safety; screening procedures during leasing and land acquisition for expansion activities; and protection of cultural heritage.

The project is not expected to operate or include development in indigenous lands; or affect biodiversity; therefore, PS7: “Indigenous Peoples” and PS6 “Biodiversity conservation and Sustainable Management of Living Natural resources” do not apply to this project. PS8: “Cultural Heritage” might apply only to specific cases, and the company has well defined policies to address and manage protection of potential cultural heritage. The findings of the project due diligence indicates that there are no impacts related to PS5: Land Acquisition and Involuntary Resettlement given that Maurício acquires land under a willing buyer-willing seller transactions without physical or economical displacement.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Social and Environmental Assessment: Maurício operates in owned and leased facilities. Construction of new facilities and renovations of existing buildings are designed and managed internally by Maurício through its civil engineering department. The company has well defined planning processes to design and construct new facilities. Before the development of a new building Maurício obtains the construction licenses according to the local regulations, which include the city permit, firefighter’s certificate and environmental permits when applicable. According to local legislation, usually Maurício does not require Environmental Impact Assessments for the new developments. During the planning process the Company also considers technical and environmental specifications, such as seismic conditions and local life and fire safety requirements.



Maurício designs and operates the buildings in compliance with local requirements; internal and external audits are performed; although its focus is mainly on quality aspects, infrastructure is also assessed. Maurício has developed a procedure to screen facilities/sites to be leased or acquired. The screening provides a timely identification and review of the potential risks particularly in terms of (i) land acquisition to ensure that involuntary displacement is avoided or minimized, (ii) cultural heritage toensure it is managed according to Brazilian requirements, and (iii) life and fire safety and structural conditions so that they are addressed properly according to local requirements.



Social and Environmental Management Program: Maurício has a quality assurance department overseeing the operations; environmental initiatives throughout the campuses have been implemented including for example, identification of environmental impacts; segregation of solid waste in some buildings, and training of internal quality and environmental auditors. Maurício has implemented internal procedures during the design, construction and operation of the facilities aimed to control basic social and environmental impacts. Elements updated in recent years included: screening and assessment of new facilities; implementation of solid waste management programs; reinforcement of OHS in construction sites; and enhancing lab safety.



Organizational Capacity and Competency: Responsibilities for social and environmental aspects are shared among several positions throughout the company. For the development of new buildings the civil engineering chief ensures compliance with technical requirements including life and fire safety provisions of buildings. During the operational stage the administrative manager ensures proper maintenance, housekeeping and efficient use of resources. The company has an OHS engineer, in charge of local compliance regarding fire safety procedures, including emergency response plans. In addition, there is a Human Resources (HR) Manager at corporate level and HR coordinators in all the campuses. Environment
al and Social responsibilities are shared with the local coordinator at each campus.



Training is provided to all the employees. There is an initial institutional training (induction) for all new employees and thereafter training is provided based on specific needs and skills required for the job. Regarding environmental and social aspects the company has provided training on accident prevention, use of Personal Protective Equipment (PPE), first aid, and emergency response. The company has in place a training plan that includes environmental protection, safety elements and fire protection.



Monitoring and Review: Maurício monitors basic environmental and social aspects of the operations such as water consumption, potable water parameters, OHS events, and extinguisher inspections. The company, through the review of its E&S management system, will enhance its monitoring and reporting system to define periodicity of monitoring and collection of data on the relevant parameters such as energy use, effluent discharges and updated fire safety information. Maurício will define and monitor Environmental and Social indicators, aligned with targets in order to identify areas of improvement and to benchmark performance among campuses.



Emergency Preparedness and Response: Maurício provides basic training on first aid and emergency response to its employees. Maurício developed emergency response plans at each campus; including mechanisms to inform students, visitors to the campuses and surrounding communities about the procedures in case of emergency. Maurício performs annual fire drills and fire safety inspections as required by local law; Maurício will maintain and test periodically its emergency response plans for all campuses.



External Communications and Grievance Mechanisms: As part of the current quality management system Maurício has a formal mechanism to address third party concerns; which includes community grievances. Grievances are recorded and processed by the relevant unit. As part of the previous transactions with IFC, the Company publically disclosed the ESRSs. Maurício indicated that there have not been complaints regarding the presence of the campuses or building of new facilities. Maurício will make available a contact number and e-mail to the public, in order to provide access to address concerns, such numbers will be communicated to local communities where new campuses will be built.



Land Acquisition: Maurício acquires land through commercial transactions directly with the land owners on a willing buyer-willing seller basis. Land and buildings acquired by Maurício up to now have been all in urban settings with no associated economic or physical displacement. As part of the current assessment prior to acquisition the Company screens for potential economic and physical displacement associated with all land acquisition. Involuntary resettlement is not expected from the project, and in any case Maurício will not acquire land that
might cause involuntary resettlement, unless resettlement and income restoration are managed in a manner compliant with IFC’s Performance Standard 5.



Cultural Heritage: Maurício follows local requirements regarding protection of cultural heritage. When applicable the company has modified buildings and has retained facades or structural parts as required by local legislation. In the current screening criteria for the selection of sites/buildings the Company is considering potential implication of preservation of cultural heritage aligned with the requirements of IFC’s Performance Standard 8.

Working Conditions and Management of Workforce Relationship: Maurício has 5800 employees, of which approximately 45% are female employees. Maurício’s HR team is headed by a HR manager with support team at headquarters and at each one of the campuses. Maurício has an ethics code applicable to all the employees, which includes statements regarding non-discrimination, equal opportunities and protection of the workforce. In addition the HR department has documented procedures for hiring, selection, disciplinary measures, transfer of employees, payment of benefits, among others. Maurício has a formal internal grievance mechanism which has been communicated to all the employees and it is made available at the time of hire for new employees. Conditions of employment are defined in the contracts Maurício signs with the employees and in the list of benefits, both of which are communicated to the employees during induction.



Maurício complies with local regulations regarding HR management, all the employees are paid at least the legal minimum salary. Minimum age of employment is 18 years and no child labor or forced labor is allowed by the company.



Workers Organizations: Maurício adheres to collective agreements with labor unions for teachers and administrative employees in the campuses of Campina Grande, Salvador, Joao Pessoa and Maceio among others. Collective agreements further define the benefits and conditions of employment. For the other campuses the management team of Maurício expressed that there has not been requests among the employees to have additional collective agreements and indicated that they would not prevent employees from organizing or participating in workers organizations.



Non-Discrimination and Equal Opportunity: Maurício has explicit statements in its HR policies, manuals and procedures regarding non-discrimination and equal opportunity. Fair treatment is observed in the company, including processes of hiring, promotion and termination of employment. Maurício has a well-defined selection process, an annual performance assessment and leadership programs to promote personnel with defined skills.



Retrenchment: The Company’s workforce has increased significantly over the last years and although it fluctuates based on the courses offered per academic cycle, it is expected to keep growing. Retrenchment is not expected from this project. If Maurício becomes responsible for retrenchment activities it will conduct them in a manner which complies with IFC requirements including development of retrenchment plans which are based on the principle of non-discrimination, reflecting consultation with employees, their organizations and, where appropriate, the government.



Occupational Health and Safety (OHS): Maurício provides OHS training to the employees and provides Personal Protective Equipment (PPE) for those employees working in the laboratories. The company has implemented procedures to manage the required programs under local l
aw such as the occupational medical monitoring program (PCMSO) and the internal committees for accident prevention (CIPA). The OHS engineer is in charge to promote and reinforce OHS practices though safety procedures, and assess building safety and fire protection. As part of the review of the current management system the company has identified the main risks of the operations, including activities of the students and has established basic programs to control and monitor such risks.



Maurício handles small amounts of chemicals and biological material for practical training of the students. Use of such products is limited to students’ practices, held few times during the academic period. The company provides PPE and training to the employees. Maurício has implemented a Lab safety program.



Workers engaged by Third Parties: Workers engaged in the construction of the campuses are third party workers. Maurício has defined clauses in the contracts regarding compliance with local law regarding labor conditions, including workers compensation, payment of salaries and occupational health and safety.

Resource Efficiency: Maurício has a strong orientation to optimize the use of the resources including the use of electricity and water. Hallways in most of the buildings are equipped with movement sensors to reduce the use of electricity and classrooms maintain the lights off when vacant. The design of new buildings has incorporated the use of natural lighting to reduce the use of electricity. The company will continue to identify opportunities to conserve resources in its operations, in particular the selection of air conditioning units will consider technologies that are energy efficient and aligned with proper environmental practices.



Greenhouse emissions of the project are associated mainly with electricity consumption and air conditioning, but also with the use of fuels for daily operations such as vehicles and for emergency generators.



Pollution Prevention: Waste generated in the campuses is mainly domestic waste, office waste and small amounts of hazardous waste from the labs. Adequate segregation was observed on the sites where containers were provided. The company is in the process of expanding the recycling program to all the campuses and will generate a program to identify mechanisms to reduce the amount of waste generated, as well as reuse, recycle and dispose properly the waste. The program should include hazardous waste generated throughout the facilities, including those from the labs. The company contracts the collection and disposal of waste with the municipality and with authorized companies to ensure disposal of material according to local legislation. Proper waste handling practices will be implemented in the new campuses.



The use of hazardous materials is restricted to the laboratories where small amounts of reactants, solvents, preservation agents and biological agars among other products are used. Maurício has included provisions for handling, storage and disposal of hazardous materials in the lab safety program.



Maurício generates mostly domestic effluents, which are usually discharged to the municipal sewage systems; however, for some buildings Maurício has its own septic tanks and infiltration systems Maurício follows local guidelines for the design and operation of the septic tanks. The Pernambuco’s environmental agency (CPHR- Agencia estadual de meio ambiente e recursos hidricos) has granted the respective operation licenses to the company. Maurício complies with the conditions defined in the licenses, including the collection of the sludge by authorized companies. Mauricio will adhere to the requirements of the WBG General EHS Guidelines regarding discharge of liquid effluents.

Infrastructure and Equipment Design and Safety: Maurício follows local building safety requirements during the construction and operation of its facilities. The buildings have the required firefighter’s licenses and Mauricio keeps close records of local requirements and permits. The buildings located in Pernambuco have been assessed by the local authorities (secretaria de defesa social, corpo de bombeiros militar de Pernambuco) and have obtain their clearance. In addition, the company has specialized personnel to verify compliance with local regulation regarding Life and Fire Safety during the construction and the design phase.



New buildings or those currently scheduled for construction or renovation will be designed, constructed and operated in full compliance with the local life safety code and an internationally accepted life and fire safety (L&FS) standard. The design shall include assessment of fire prevention; means of egress; detection and alarm system; compartmentation; fire suppression and control; emergency response plans. In order to confirm compliance with IFC requirements, Maurício will engage the professional services of a qualified Life and Fire Safety Engineer acceptable to IFC to prepare a Master Plan (engineering design) and post construction inspections to verify that the systems were installed as designed for new buildings constructed after IFC’s engagement with the Company. Life and fire safety design and operation shall be responsive to one internationally recognized life safety code, and the Brazilian/local life safety code. The design shall comply with the Life and fire Safety requirements of the WBG General EHS Guideline.



New buildings will be designed to be consistent with the principles of universal access, including ramps for access.



The company obtains potable water from various sources which include on site wells, private providers, and the municipality. Maurício has verified local compliance of the quality of the water supplied to the facilities from the wells and private companies. Cafeteria services are provided by third parties in the facilities of the company; Maurício de Nassau performs an initial assessment of the capacity of such vendors.

Maurício has a strong community focus, which is reflected in the existence of the Instituto Maurício de Nassau. The Institute aims to support local initiatives, such as alphabetization of local communities, creation of local libraries and provision of technical assistance to small enterprises. The Institute researches topics relevant to the local community. The Institute, in alliance with local partners, has participated in local campaigns to reduce violence, to create capacity for female entrepreneurs, and to achieve the millennium goals in Pernambuco. Such initiatives are recognized locally and frequently cited in press releases.

In addition Maurício offers some services to the community such as legal counseling, physical therapy and psychological support among others at very low costs.

Maurício disclosed locally the Environmental and Social Review Summary and Action Plan of the previous transactions with IFC (projects#28755 and #32648). The company indicated that there has not been complains regarding the presence of the campuses or building of new facilities. Mauricio will make available a contact number and e-mail to the public to address concerns, such numbers will be communicated to local communities where new campuses will be built.

Rua Fernando Lopes, 778 - Graças - Recife - PE – Brasil
CEP: 52.011-220

To contact the project company, or request additional information about the project please write to:
Nazareno Habib Ouvidor Bichara
E-mail: mailto:habib.bichara@sereducacional.com
Phone: + 55 (81): 3413-4605
Rua Fernando Lopes, 778 - Graças - Recife - PE – Brasil
CEP: 52.011-220

Maurício de Nassau will make adequate public disclosure of this transaction in the Brazilian business and trade press.

Broad Community Support is not applicable for this project

#	Task Title/Description	Anticipated Completion Date
1	Mauricio de Nassau will complete the implementation development of its environmental, Occupational health and Safety (OHS), and fire safety management system, the scope will include all campuses. Deliverable: Submit manuals and policies demonstrating full implementation of the management system.	New Units – One year after acquisition. Current Units – 12/30/2014
2	The company will expand the recycling program to all the campuses and will identify mechanisms to reduce the amount of waste generated, as well as reuse, recycle and dispose properly the waste. The program should include hazardous waste generated throughout the facilities, including those from the labs. Deliverable: Solid waste program implemented: records by site and type of waste	6/30/2014
3	New buildings or those currently scheduled for construction or renovation will be designed, constructed and operated in full compliance with the local life safety code and an internationally accepted life and fire safety (L&FS) standard. For each building the company will provide a certification by a qualified professional acceptable to IFC that its design complies with the Life and Fire Safety requirements of the WBG General EHS Guideline. Deliverable: Formal opinion by a qualified fire protection engineer that the design meets the life and fire safety (L&FS) requirements.	As Projects develops
4	A qualified fire protection engineer, acceptable to IFC, will perform post construction inspections to verify that the system was installed as designed. Deliverable: Professional certification by a qualified fire protection engineer affirming that facility faithfully incorporates all elements of the life and fire safety design previously agreed with IFC.	As Projects develops