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 diversity of E&S risks related to the multiple sub-projects in an inherently biodiversity rich and culturally diverse landscape in Brazil. This investment considers 12 sub-projects located in three states in Brazil, some of which are located near sensitive biodiversity receptors.

All Performance Standards, with the exception of PS 7 Indigenous Peoples, are applicable to the proposed investment. The only WPP which is located in the vicinity of an IP Reserve is the Fontes dos Ventos site. Although the temporary access to the site, currently used by the company, is through a stretch of a paved and well-maintained main state highway (PE-375), which links to an existing 2.5 km vicinal (unpaved dirt) road, both running through the IP Reserve, the company is constructing a new access road which is needed for the transport of the wind turbines and will avoid further use of the roads through the IP Reserve. The temporary access road is primarily being used for transport of materials for earthworks and the civil works ongoing to build turbine foundations. The company’s use of the temporary access road will be discontinued by year-end 2013 as the new access road (which completely avoids the reserve) will be constructed. No wind turbines will be transported on the temporary access road. The IPs do not reside near the road: large, fenced properties of non-IP landowners line the road. These properties were established before the IP Reserve was officially recognized by the State and their land demarcated in 2007. Although there is no impact on the IP community, the company has been working closely with the leadership to ensure adequate communication about the WPP and to provide support to the community. The company has also commissioned a Participatory Rapid Diagnosis, involving the tribal community, with the agreement of the leadership to develop further programs for the Pankararu (an IP community initiatives action plan is under development). When the team met with the IP leadership, the individuals present at the meeting expressed a positive attitude toward the presence of the WPP and the company’s approach.

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.

Environment & Social Management System



EGP has an integrated environmental, health, safety and quality management system in place that stems from the Policies, Organizational Procedures and Operational Instructions of the Enel Group.



EGP’s system is certified ISO 14001, OHSAS 18001 and ISO 9001 standards and covers EGP and all its subsidiaries worldwide, including EBP. External audits have been conducted in 11 countries, including Brazil, in 2013.



Policy



Sustainability is a clear priority within Enel. At the highest level, Enel is a signatory of the United Nations (UN) Global Compact since March 2012 and of the Partnering Against Corruption Initiative (PACI), sponsored by the World Economic Forum. In 2013, and for the ninth year in a row, Enel was admitted to the prestigious Dow Jones Sustainability World Index, which includes just 340 of the 2,500 most important companies in the world for sustainability. Enel has established an extensive policy framework on environmental, health & safety and CSR topics, which is applicable to EGP and all subsidiaries, including EBP.



Enel’s Policy on Environmental Management Systems sets guidelines for the development of an Environmental Management System in line with ISO 14001 to which to all companies within the Enel Group must comply. EGP’s policy on Environmental Improvement System elaborates on Enel’s overarching policy specifically for EGP subsidiaries. EGP has established its own Safety and Environmental Policy, which is applicable to EBP.



Enel’s Human Rights Policy sets out the commitments and responsibilities of all companies in the Group in relation to all the Human Rights, including a commitment to promote Human Rights respect within its business relationships and adherence to the same Human Rights standards by its contractors, suppliers and business partners. The Policy applies the founding principles of several international treaties, including the International Bill of Human Rights of the UN (Universal Declaration of Human Rights; International Covenant on Civil and Political Rights; International Covenant on Economic, Social and Cultural Rights), the core conventions of the International Labour Organization (ILO) (29, 87, 98, 100, 105, 111, 138, 182) and the Declaration on Fundamental Principles and Rights at Work; the United Nations Convention on the Rights of the Child; the ILO Conventions 107 and 169 on the Rights of Indigenous and Tribal Peoples; and, the European Convention on Human Rights.



Additional information on HR and H&S related policies and information on Enel’s Code of Ethics are covered in the section below on Performance Standard 2.



Identification of Risks and Impacts



The process of identifying risks and impacts is relatively well-structured in EGP through the presence of three “functions” (referred to as “functional units” or “units” in this document) - Business Development; Engineering & Construction (referred to as “Engineering” in thi
s document); and, Safety, Environment & Quality (referred to as the “HSE unit” in this document). In addition, the ‘Communications’ Unit is responsible for aspects associated with identifying and engaging stakeholders, undertaking stakeholder engagement, community development and investment programs. Business Development and Engineering are the primary units in charge of the risks and impacts identification process.



The Business Development Unit is responsible for the identification of new business, project selection and identification, project screening, negotiating land agreements and licensing and permitting. The company has specific siting and design criteria that inform the screening of the project sites, their layouts and their design. The Operational Instruction ‘Wind Design Criteria and Guidelines’ provides detailed guidance on information needed for the proper configuration of a wind power project including E&S avoidance criteria during project screening (e.g., sensitive habitats; protected areas and historical monuments; setback from dwellings due to noise; and consideration of impacts from shadow flicker) and requirements for identification of risks at each site (e.g. geological risks, environmental risks and assets, and archaeology). The Wind Design Criteria and Guidelines document also contains considerable guidance on the assessment of the transportability of wind turbine equipment on roads through an alternatives analysis.



As indicated in ESAP Action Item Number (#) 1, the company will be reviewing its project screening and risk assessment procedure to ensure alignment with IFC’s Performance Standards. For example, additional project screening criteria will be added for biodiversity & avifauna, cumulative impacts and reputational risks. The alternatives analysis process for the overall location of the wind site and the design of the site (e.g., layout, number and size of turbines, and operation alternatives) will be also be included. As indicated in ESAP Action Item #2, the company will also be reviewing its procedure with respect to acquisition of assets to ensure that E&S aspects are assessed and mitigations are prescribed in alignment with Performance Standards.



The Engineering Unit provides the technical oversight on the development of the environmental and social impact studies. The Government of Brazil requires an Environmental Impact Assessment (EIA) or a “simplified” EIA (called the Relatório Ambiental Simplificado – RAS), depending on the magnitude of the development. For wind development, the RAS is the legal requirement. The company has commissioned a consultant to develop the RAS for each WPP, except for Cristal where the Company voluntarily developed the expanded EIA. The EIA / RAS is developed in order to obtain the Licença Prévia, which is needed for the project to participate in the energy auction.



The identification of social-related risks and impacts within the EIA and/or RAS can be impro
ved on. Social impacts are identified less systematically than environmental impacts and the involvement of multiple units overseeing social topics requires more coverage. As indicated in ESAP Action Item #3, the company will develop a procedure on the integration of social impacts into the risks and impacts identification process to further align with the IFC Performance Standards. In terms of jobs, the company’s practice is to hire and give preference to local people. The company will continue this practice and will monitor contractors to help ensure that workforce is being hired locally. This is important as expectations for local jobs are usually high in remote and socio-economically deprived areas where economic opportunity is limited.



Regarding cumulative impacts, Cristal, Serra Azul and Curva dos Ventos are the first wind projects in the state of Bahia; others are expected to follow. As described in the section below on Performance Standard 6, the Cristal and Serra Azul WPPs are located outside of, but near, areas of high biodiversity value for birds. In light of the expected further wind power developments in the region, the company will contract an external expert to conduct a rapid assessment, using primarily existing data, on the potential cumulative impacts of current and future planned wind power developments on high-risk avifauna areas in Bahia as indicated in ESAP Action Item #4. The purpose of the assessment will be to help establish good practice in Bahia by demarcating areas were additional precautions should be taken by wind developers, if located near high-risk avifauna areas. The assessment will make results and recommendations available to the Instituto do Meio Ambiente e Recursos Hídricos (INEMA), the state-level environmental regulatory agency, for landscape planning purposes.



The area of João Câmara in which the Modelo WPP cluster is located will have 900 MW of installed wind capacity from multiple power companies. Cumulative impacts on local households, from the multiple companies operating in the area, may be related to noise, shadow flicker and land acquisition. Consistent with the company’s standards, the Modelo WPP site is located in an area which is relatively distant from the nearest residential houses; the nearest village, Quimadas, is located about 5 km from the site, and a housing area for low-income people administered by the Instituto Nacional de Colonização e Reforma Agrária - INCRA (National Institute for Colonization and Agrarian Reform) is located at about 2.5 km from the site. Considering the distance between EBP’s WPP and the human receptors in this area, the incremental impact on noise and shadow flicker is negligible to non-existent. That said, the company will continue to participate in the industry working group Groupo de Trabalho Abeeólica Transmissão Rio Grande do Norte (RN) which coordinates for the management of wind parks in the State, which includes this area. As mentioned ea
rlier, the company will also be including cumulative impacts as part of its screening procedures.



Management Programs



Once the Licença Prévia is obtained, EBP commissions a consultant to develop the E&S Management Programs (Projetos Básicos Ambientais - PBA) for each WPP cluster. The PBA consultant is recruited by the Business Development Unit and technical oversight on the development and adequacy of the PBA is provided by the Engineering Unit. Once the PBA has been developed, the Licença de Instalação could be obtained, and the project proceeds to the construction phase.



The HSE Unit is responsible for implementing the PBA during the construction and operations phases. The PBA consists of a series of E&S Management Plans that are developed from the EIA / RAS and include the E&S conditions imposed by the state-level environmental authorities as stipulated in the Licença Prévia and Licença de Instalação. E&S Management Plans include inter alia Erosion Control, Water Resources Management, Traffic Management, Temporary Construction Facility Removal and Reinstatement, Flora & Fauna Rescue, Solid Waste Management, Cultural Heritage Management, Noise Management, Air Emission Control (both dust and emissions from equipment, machinery and vehicles), Stakeholder Engagement, Community Outreach and Community Education. The PBA also includes the Emergency Response Program and Environmental Monitoring Programs, which are described in the sections below.



The PBA is implemented by EBP on-site HSE staff, an external consultant or through contractors. The company requires that all construction contractors comply with the conditions of the environmental licenses and the requirements of project-specific E&S management programs.



Organizational Capacity and Competency



EGP has established a standardized E&S managerial framework that is implemented by all of its subsidiaries, which centers around the five functional units - Business Development, Engineering, Operations and Maintenance, HSE and Communications. Within EBP, the Business Development, O&M, HSE and Communications functional units are headed by an in-country manager who reports directly to the Country Manager and indirectly to the respective EGP functional manager in Italy. Engineering, which is the primary unit responsible for technical oversight E&S assessments, is the only unit in EBP that does not have an in-country manager. The heads of the five functional units based in EGP headquarters in Italy report directly to EGP’s CEO.



Business Development, Engineering and Communications are involved during project planning, licensing and permitting and the development of the EIA and management programs. HSE is responsible for the supervision of the implementation of the E&S management programs by Engineering and O&M during construction and operations respectively. The management of socio-economic related impacts and stakeholder engagement is shared amongst a number of th
e functional units. Engagement with affected communities, land compensation and grievance management is managed by the Business Development unit. Engineering is involved with the preparation of the EIA and with public disclosure and consultation related to the EIA. The Communications Unit is involved with implementation of CSR and community outreach activities during the construction, many of which are captured as social management plans in the PBA.



During construction, each WPP cluster is assigned an on-site HSE Coordinator, under which sits an Environmental Technician and an H&S Technician (both on-site). The HSE Coordinator reports directly to the HSE Manager based in EBP headquarters. The HSE Manager and his two advisors for environmental and H&S matters are responsible for verifying the implementation of the company’s ESMS through a compliance tracker (see below the section on Monitoring) for all sites under construction and operations. In addition, a regional coordinator ensures consistency of the implementation of HSE aspects between each of the WPP clusters. The on-site HSE coordinators are responsible for managing external consultants who are often responsible for carrying out various activities under the PBA. The on-site coordinators are also responsible for verification of the implementation of relevant management plans carried out by the contractors. A similar structure exists for the on-site HSE management for the SHPs.



Given the various functional units involved in environmental and social matters at different stages of the project cycle, the company will develop a roadmap to implement a modification in the company structure so that it accommodates the establishment of an Environmental and Social Technical Management Function that works across such units, as indicated in ESAP Action Item #5. Currently, in-country staff responsible for development of the ESIA report to a Technical Manager based in Italy who is responsible for EGP technical issues worldwide. A local presence in Brazil will help early identify E&S risks in the project''s pipeline, strengthening the integration of E&S considerations in the business development decision-making process, and centrally coordinate E&S aspects across EBP’s portfolio (including holdings in hydropower and solar), helping to ensure consistency with IFC’s Performance Standards throughout the project cycle. As indicated in ESAP Action Item #6, EBP will also be contracting a senior-level Biodiversity Resource to act as an advisor to the company on this topic. This resource should ensure that biodiversity (particularly birds and bats) is assessed and managed consistently for each wind project from early on in the project screening throughout operations. Given that the company will likely continue to work in biodiversity-rich landscapes of Brazil, a senior-level presence to oversee the process with respect to this specialized topic will help ensure consistency with IFC''s PS 6.



Within EGP headquarters in Italy, a Wind Centre of Excellence Committee sits within the Engineering Unit and has an oversight function with respect to technical feasibility of each wind power asset, including the management of E&S aspects. The Committee conducts a site visit to each of EGP’s wind power projects as part of risk management and project design.



Also within EGP headquarters sits an Environmental Issues Committee, which is responsible for ensuring the consistent implementation of Enel’s and EGP’s Policies, Organizational Procedures and Operational Instructions. The Committee is responsible for data exchange and sharing lessons learnt within EGP’s portfolio of renewable assets. The Committee consists of inter alia the Heads of HSE, Operations & Maintenance, Engineering and Construction, Regional Managers, and Procurement. The Environmental Issues Committee will provide guidance directly to the country-level HSE manager with respect to project management of greenfield sites and acquisitions.



Emergency Preparedness and Response



Enel has an overarching policy (Guideline for Emergency Management) that defines its Emergency Management Structure and requires the development of an Emergency Plan for each workplace, adapted to suit local circumstances. The policy provides the relevant standards, organization and structure of the plan and requires that it includes an identification and classification of emergency scenarios. Consistent with the policy, EBP has developed and implemented an Emergency Plan prior to the start of construction of each WPP. The site Emergency Plans define roles and responsibilities for the emergency prevention and control, implementation plan of the emergency procedures, including alarm systems, training and emergency drills, fire prevention and safety procedures, first aid, accident investigations, coordination with competent authorities and external emergency response organizations, and communication procedures. As part of the PBAs, EBP has also developed specific management programs for environmental emergencies during construction. These programs are relevant to management of environmental accident scenarios, including fuel and chemical spills and leaks on soil and/or water bodies, fires, explosions, contamination by accidental discharge of waste. All personnel and contractors working at the site must be trained on emergency preparedness and response. Emergency crew and equipment were observed to be present at the sites visited by IFC.



Monitoring and Review



HSE monitoring plans for each WPP are contained within the PBA; examples include monitoring of H&S incidents, avifauna, bats, water quality and other environmental monitoring. Monitoring at each WPP is conducted through environmental consultants or through contractors who have their H&S supervisors on site. Contractors and consultants submit reports to EBP’s on-site HSE Coordinator, who in turn submits weekly monitoring report updates
to the HSE Manager and monthly compliance reports on the contractors’ implementation of PBA commitments. The HSE Manager tracks compliance at each WWP through a color-coded action-tracking system, which generates corrective measures to non-compliance situations.



EGP institutes an ‘Extra Checking on Site’ (EcoS) process through the central HSE Department at company headquarters in Italy. ECoS has been implemented by EGP worldwide with the aim of carrying out standardized reviews of the implementation of company’s HSE standards, done for each site by a team of 3 to 5 HSE experts selected from a pool of 34 specialists. It is a requirement that ECoS visits are done without warning and compliance results are reported directly to EGP’s CEO.



EGP also maintains an Audit Unit that also reports directly the EGP’s CEO and the Board of Directors. Based on a the development of a yearly auditing plan, this Unit conducts audits on any number of administrative, function and technical policies and procedures. The basic premise of the Audit Unit is to ensure that EGP’s internal control systems are being implemented on-the-ground. The Audit Unit is especially deployed for EGP’s operations in emerging markets and new countries. This process also allows the ‘regionalization’ of EGP’s policies and procedures. Both the Audit Unit and the EcoS system provides for the sharing of lessons learnt and best practices between sites and country offices.

Human Resources Policies and Procedures



EBP’s Human Resources (HR) policies and procedures are based on the Enel’s Code of Ethics and Human Rights Policy. EBP has developed a number of company level policies and procedures which lay out its approach to key HR matters, and which are aligned with Brazilian labor laws. Brazil is a signatory to numerous international conventions and treaties. Those relevant to labor rights include: the International Labor Organization (ILO) Convention 87 on Freedom of Association and Protection of the Right to Organize; the International Covenant on Civil and Political Rights; the American Convention on Human Rights; and the International Covenant on Economic, Social and Cultural Rights.



Enel’s Code of Ethics expresses the ethical commitments and responsibilities in the performance of the business activities by the employees of Enel’s companies (including direct and indirect subsidiaries). It defines Enel’s commitments in managing its employees and the fundamental employee’s rights and responsibilities. The Code of Ethics is based on 16 general principles: impartiality, honesty, conduct in case of potential conflicts of interest, confidentiality, relations with shareholders, safeguarding shareholder value, value of human resources, equitable exercise of authority, integrity, transparent and complete information, diligence, correct and fair conduct in any renegotiation of contracts, quality, fair competition, responsibility toward the community, environmental protection. The Code of Ethics is available at EGP website (http://www.enelgreenpower.com/en-GB/ela/). As part of induction in EBP, new staff are provided with the Code of Ethics translated in the Portuguese language as well as all other Health and Safety policies and procedures relevant to Brazil.



As described above in Performance Standard 1, EBP also adheres to Enel’s Human Rights Policy. As a signatory of the UN Global Compact (and of PACI), the company has a Zero Tolerance of Corruption Plan, compliant with the tenth principle of the UN Global Compact. The Organizational and Management Model adopted by the Board of Directors, pursuant to the Italian Legislative Decree 231/01, has the scope of the construction of a structured, organic system of procedures and control activities, to be undertaken to prevent the commission of crimes and offences, including the definition of the relevant non-compliance management and disciplinary systems to be applied by the companies of the Group.



Working Conditions and Terms of Employment



EBP and its subsidiaries have around 235 permanent employees. The terms of employment are established by national labor regulations, and are stated in the company’s employee contracts, in the collective bargaining agreements signed with the workers’ organizations, and in the internal procedures. Additional workers’ benefits include health insurance and medical assistance, among others. Working conditions (including heal
th, safety and security); employee termination; prohibition to employ minors; disciplinary actions; workers’ rights and obligations; employer’s rights and obligations are defined in the existing policies and procedures. A committee has been formed to review and decide on any management action and proposal, before proceeding with the dismissal of an employee, within the rights given to the employer by the legislation and in agreement with the conditions stated in the applicable collective bargaining agreement. The Human Rights Policy rejects any form of harassment; physical, verbal, sexual or psychological abuse; threats; or intimidation in the workplace.



The five WPPs do not involve the use of migrant workers, being that the construction and operation workforce are mostly national and there is no use of dedicated worker accommodation camps. If the need for workers accommodation camps is identified in future projects, EBP will review the conditions of the camps, as part of its contractual arrangements with its contractors, and will establish and implement requirements on the quality and management of the accommodation and provision of basic services, as envisaged in paragraph 12 of PS 2.



Workers’ Organizations



Freedom of association and collective bargaining in the labor sphere are promoted and respected in EBP, and they are part of Enel’s commitments to obligations assumed through signing the UN Global Compact. In June 2013, Enel signed a Global Framework Agreement with global unions Public Services International and IndustriALL.



Consistent with the corporate’s policies, EBP supports collective bargaining and signed collective agreement with unions in each state in which it operates. These agreements provide specific provisions for salary and payment, work days, contract management, benefits, rights and duties, occupational health and safety, and workers’ organization and relations. Employees may also voice their grievances through these unions. The collective bargaining agreements apply to all EBP’s employees, irrespective of their actual participation in one of the unions. The company expects all contractors, suppliers and collaborators to also uphold the rights to freedom of association and collective bargaining via signing up to implement its Code of Ethics. Compliance is checked via a system of questionnaires and audits by the both Procurement and Audit Units. Failure to comply with any of these principles may lead into contract cancellation.



Non-Discrimination and Equal Opportunity



EBP’s payroll is about 79 percent male and 21 percent female, out of which approximately 16 percent of the managerial positions with the rest of the female employees hired for technical and clerical positions.



Enel is committed to avoid all forms of discrimination against its employees, based on the age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs of its counterparties. The Group pro
motes the professional and personal development of all its employees, ensuring equal opportunities through the implementation of its policies. Per its Code of Ethics, personnel selection, management, evaluation and development are based on whether the required job profile corresponds to the employee’s characteristics and/or on considerations of merit. Access to roles and positions is also determined by considering expertise and ability. The company encourages the involvement of employees in the performance of their work and their participation in discussions and decisions on corporate goals and opportunities for their career and professional development. Individual’s privacy is respected.



Information and training instruments are available for EBP’s employees and great emphasis is given to the enhancement and opportunities for specific skills and to maintain the professional value of the company’s personnel. Induction training is provided to all newly hired workers, including technical, human resources, and occupational health and safety and environmental modules. Training plans are developed and implemented, including corporate level training. Training records are maintained in the personnel information system.



The requirements of non-discrimination and equal opportunities are extended to all contractors, suppliers and collaborators via their adoption of the Code of Ethics, as part of the contractual obligations. With respect to the workers engaged by third parties (contracted workers), including contractors and their subcontractors, their records, including proofs of contract, age, training and medical fitness among others, are collected and verified by the company. Relevant documents were observed at the site offices visited by IFC.



Grievance Mechanism



EBP uses a variety of methods to enable staff to raise internal grievances or comment on HR-related matters. Human Resources officers are located in the company’s offices and they are the first direct point of contact for employees in collecting their concerns, recommendations and complaints.



As stated in the Enel’s Human Rights Policy, there is a reporting mechanism to the Audit Unit which is open to both employees and external stakeholders, whenever stakeholders perceive an adverse impact. Means of reporting include, for the employee, the company intranet, or for all stakeholders, including external ones, by e-mail (mailto:audit.enel.codice.etico@enel.com) or by post to Enel SpA - Audit Department - Code of Ethics - 00198 Rome - 64, Via Arno. Reports can also be submitted at local level through the relevant channels of the Group’s companies. The policy requires that the reporting parties are safeguarded against any form of retaliation, and that confidentiality is guaranteed.



As indicated in ESAP Action Item #8, a grievance management procedure will be developed by EBP on the basis of the policy’s provisions, which will apply to unionized and non-unionized workers, inc
luding contracted workers.



Protecting the Work Force (child and forced labor)



Child labor and forced labor are prohibited under Brazilian laws. Enel’s Human Rights Policy explicitly rejects the use of any form of forced or compulsory labor, consistent with ILO Convention 29, respects child rights and rejects the use of child labor, as defined by the national laws where the companies of the Group operate, and in any case no less than the minimum age per the relevant ILO Convention 138. Enel requires contractors, suppliers and collaborators to abide by the same principles, via signing up to its Code of Ethics. The company verifies contracts and work documents of the workers engaged by third parties.



Occupational Health and Safety



EBP’s H&S Management System is part of the integrated system for quality, environmental, health and safety management which applies to EGP and its subsidiaries. The system is certified OHSAS 18001 in all countries where EGP and its subsidiaries operate, and therefore in Brazil as well. In addition to the Group’s Policy on Health and Safety in the Workplace, the system includes a detailed set of OHS manuals, procedures, plans and key performance indicators (KPIs). Best practice measures include: (i) implementation of periodic safety walks by management to promote the culture of safety, verify safety behaviors of staff and contractors, review conditions of all company’s construction and operation sites, and define safety walk follow up implementation plans; and (ii) the implementation of the ECoS controls as described above in Performance Standard 1.



Key performance indicators for safety include ‘upstream’ or leading KPIs (i.e., performance indicators related to safe behavior activities and ECoS observations, and including number of safety inspections, operational and structural non conformities, near misses, first aid cases, health and safety training hours, health and safety training costs, safety walks) and ‘downstream’ or lagging KPIs (based on accident events). Safety indicators are consistently collected and analyses throughout the sites visited by IFC and at central level in EBP and reported to EGP corporate level to assess the overall effectiveness of plans and procedures locally and globally within the organization. Contractor’s performance is also consistently measured.



Accident recording and communication procedures are stringent and require timely communication of all serious accidents and safety violations. Specific guidelines for measures to be taken against contractors in the event of serious violations of health and safety at work are formalized within the management system. Records of the violations, remedial action plans, and sanctions are registered by the HSE staff and made available to Procurement for actions.



In the past three years, safety performance at the construction sites and in EBP overall was excellent with no accidents recorded for their own staff and contractor st
aff. Despite the ramping up of the construction activities at WPPs in 2013, safety records continue to be good, with no severe accidents recorded and with injury lost time frequency rate and severity index of 0.70 and 0.01 respectively, for the first 8 months of the year, which compare very favorably with similar statistics both in the industrial construction sector and in Brazil.



For the WPPs under construction, safety on site is managed, supervised and audited by a team of full-time H&S supervisors, which are deployed to each construction site (as described above in Performance Standard 1). The ultimate responsibility for safety stays with the site manager, who receives support and training, as needed, from headquarters. The company makes use of safety toolbox talks, i.e. short, pre-activity H&S discussions involving all staff and contractors engaged in the tasks.



EBP builds safety clauses into its agreements with contractors and suppliers. These parties are required contractually to adopt H&S measures compliant with requirements and to provide training to their workers, in accordance with national requirements and company’s policies and procedures. The company has a very sophisticated and comprehensive series of H&S procedures and work instructions that apply to its staff and facilities and its contractors, for example road traffic safety, signage, work in confined spaces, machine safety, electrical safety and lock-out-tag-out procedures, handling of chemical substances, working at height, scaffolding safety, material handling, lifting and storage, management of personal protective equipment and collective protection systems, fire prevention and firefighting procedures, and first aid procedures. First aid is provided, including presence of medics and/or paramedics and ambulances in each WPP site. EBP provides initial safety training of contractors and their subcontractors and also requires its contractors to develop and implement a safety training plan. Each site maintains an Emergency Plan, developed according to the local requirements and following the relevant internal policy. An emergency brigade is deployed at each construction site.



As part of the specific requirements to obtain the Licença de Instalação for the four WPPs under construction, the company developed and submitted to the competent authorities project-specific Occupational Health and Safety Programs which are included in the PBA of each site. These and other programs are prepared in accordance with the requirements of the Ministry of Labor and Employment’s regulatory norms. The use of personal protective equipment and collective protection measures and procedures was observed to be adequately and consistently enforced at the sites visited by IFC.



Workers Engaged by Third Parties



EBP has established policies and procedures to manage and monitor the performance of contracted workers and uses terms and conditions included in contractual agreements to ensur
e compliance with in-country requirements. Procedures applied during the procurement process are based on Enel’s Procurement Regulation and Policy and include the requirements for the contractors to comply with the ethical principles of the Group, the implementation of an environmental management system, compliance with health and safety laws and company’s requirements. Violations of the general principles of the Code of Ethics trigger disciplinary mechanisms, including contract cancellation. Specific requirements include recognition by the contractor (and its subcontractors) of relevant social obligations, including the respect of the fundamental rights of workers, principles of equal, non-discriminatory treatment and safeguards involving child labor. EBP’s procedures include the possibility of holding inspections and audits of the contractors’ facilities to ensure compliance with the requirements.

Based on IFC’s review, EBP’s approach to resource efficiency and pollution prevention is generally consistent with IFC PS 3 requirements, including the current World Bank Group General EHS Guidelines (2007) and, for the five WPPs included in the scope of IFC review, the applicable EHS Guidelines for Wind Energy (2007). EGP as a corporate is focused on resource efficiency and environmental governance and tracks this issue globally and at country level via specific indicators and targets reported in the Group’s Sustainability Report and Environmental Report. The ‘Wind Operation Process’ procedure set out roles, responsibilities, phases and activities of WPP operation, and include efficiency performance requirements and reporting, as well as safety and environmental requirements.



Water consumption at the WPP sites is generally limited to the construction phase (200 to 300 m3/day). The company is very diligent in ensuring that adequate and sustainable water sources are identified before they are selected for use to meet construction needs. Where water sustainability studies identified water scarcity issues at Fonte dos Ventos WPP site, the company decided to purchase water from a licensed supplier. Where local groundwater sources are available, company’s policies require that water wells are fully characterized and licensed, including identification of users, well characteristics, well capacity through pumping tests, and water quality.



EGP reports that its operations worldwide avoid the emission of over 18 million tons of carbon dioxide into the atmosphere per year. In Brazil, the carbon dioxide emissions avoided annually due to the existing 21 SHP plants are reported to be over 1.2 million tons. Implementation of the five WPPs will contribute to an expected average annual emission reduction of over 600,000 tons of carbon dioxide.



Good practices implemented at the construction sites visited by IFC include dust abatement measures, such water spraying of access and internal roads, work areas and stockpiles. Ambient air quality is monitored quarterly for particulate matter and carbon monoxide at selected sites, both within the wind park construction area and outside (e.g., 21 monitoring points selected for Cristal WPP). All contractor’s equipment, machinery and vehicles are inspected by the company and need to provide evidences that they meet exhaust emission standards, in order to be allowed to enter and be operated in EBP’s project areas. Noise is mitigated through measures such as use of well-maintained and modern vehicles, equipment and machinery and speed restriction of vehicle traffic at the worksites. Ambient noise monitoring is carried out at selected locations, based on the identification of nearest sensitive receptors. Wastewater and water discharges are managed through installation of portable sewage treatment units, decanting pools to limit potential turbidity issues, oil water separators, management and reduction of discharge
s of wash water from concrete tanks cleaning through their use for spraying of roads for dust suppression.



EBP’s waste management and hazardous materials procedures are in line with PS 3. Observations made at the construction sites visited show that good practices are applied in terms of site housekeeping, waste management, storage and segregation on site for recovering and reuse. Wastes are collected and disposed of at licensed facilities and proof of transport and disposal of all waste streams are maintained by EBP.



Erosion control and sediment control measures are implemented at the construction sites. Water quality monitoring programs to demonstrate compliance with in-country standards are implemented, for example monitoring of four streams located in the proximity of Cristal WPP. A specific program for the protection of local surface water springs, including measures to prevent accidental pollution and vegetation protection and restoration measures, is implemented. Alternative bypass roads to access Serra Azul WPP site are being studied to avoid an area where sinkholes (dolines) have been detected in the proximity of Cafarnaum (Bahia).



During operation of the WPPs, the company will continue to monitor water use and quality, ambient noise, and waste management. The noise levels generated by the operation of the turbines will be contained within relatively short distance from the WPPs, and it was estimated that they will be at a level of 35dB at 450 m distance from the source. Regarding noise and shadow flicker, EGP has internal design criteria that define constraints for each WPP project, including a standard minimum set back of 500 m from dwellings to prevent potential impacts. The construction sites visited are located in rural or natural areas with no nearby dwellings.

EBP’s approach to community health, safety and security for the WPP projects reviewed is mostly consistent with IFC PS 4 requirements. Related risks are relatively low during operation, with very limited quantities of hazardous materials and substances involved or waste and emissions produced, minimal road traffic, very limited workforce, limited inherent risks for emergency situations associated with this technology, no structural elements of components that may threaten the safety of local communities or represent an obvious risk for households near the project area. As indicated in the company’s procedure, turbines cannot be located less than 500 m from dwellings. Low level flight protection measures are implemented, including daytime and nighttime signals.



During construction, community health and safety hazards are similar to those of most industrial facilities and infrastructure and mainly associated with transport of the WPP components (i.e., base, tower shaft, nacelle, blades and hub), and of construction materials, equipment, and workers to and from the construction site. The company has internal standards to be applied for transport of WPP components. The standards require a thorough analysis of the existing roads to access the site, identification and analysis of alternative accesses and critical points along the route, analysis of infrastructure, such as bridges, and geotechnical analysis of the route alternatives. A transport management / traffic control plan was developed by EBP for each of the WPPs reviewed, and the company requires its contractors to develop and submit their analysis of the transport route and their transport plan before mobilizing. As needed, existing access roads have been upgraded to meet design criteria and were observed to be adequately fenced.



Speed limits are defined and imposed to all project vehicles along the access and internal roads. Construction sites visited by IFC have prevention and control measures, such as gates, guard posts, fences along construction sites, information boards with contact information, and road and safety signage. Alternative access roads were consistently identified and assessed as part of the EIA/RAS studies. For example, the center of Cafarnaum (Bahia) will be avoided by the selected Serra Azul WPP access alternative, through the construction of a bypass to connect a main state road (BA-122) to a municipal road.



Risks of community impacts associated with the influx of temporary project labor (e.g., increase of rates of sexually transmitted and other communicable diseases) are limited, due to the relatively small size of the construction workforce (300 to 500 people at peak) and relatively short duration of the construction activities. However, these risks for the small towns within project areas of influence (for example, Bonito, Cafarnaum, Morro do Chapéu and Mulungu do Morro for Cristal and Serra Azul sites), where workers are accommodated, have been identifi
ed. As mitigation, EBP requires that contractors hire the majority of unskilled construction workers from local communities. The company also developed a set of health education programs which include communication and awareness campaigns and measures for the local communities, especially focused on education of teens, prevention and control of HIV/AID, dangers of alcohol and drug abuse as well as a program to support the local municipalities and public infrastructure.



EBP uses security personnel of licensed specialized firms to take care of site security at certain locations, including construction sites. The company generally deploys unarmed security guards/staffed check posts. Considering the scope of the business activities, use of armed security personnel is however possible at certain worksites. In the Human Rights Policy, Enel refers to the Voluntary Principles on Security and Human Rights, committing to guaranteeing that private security forces protecting Group’s personnel and properties act in a way consistent with the applicable national law and regulation and international standards, while also encouraging public security forces to act in the same manner.



Emergency preparedness and response plans for the facilities operated are available and regular training and drills are carried out.

EGP’s procedures include avoidance criteria for legally protected areas and sensitive habitats as part of project screening (described above). Surveys of flora, fauna, birds and bats are conducted for some projects as part of the EIA by external specialists. The PBA includes a number of related management plans (described above) that contain mitigation measures to minimize impacts on biodiversity and restore habitat. For example, wildlife rescue and rehabilitation is implemented at each WPP during ground-clearing. Prior to ground-clearing activities, ecologists translocate fauna species from the construction site and translocate priority flora species to an on-site nursery. A veterinarian is posted on site to attend to injured wildlife. Wildlife that have been fatally injured during ground-clearing are provided to academic institutes for research purposes. These activities are coordinated through local authorities. Native species seed collection is carried out for habitat restoration. The PBA also includes monitoring measures for flora and fauna with emphasis on birds and bats. The monitoring programs included in the PBA are more robust than the baselines included in the EIA.



Set-asides on large properties are mandated in Brazil through the Riserva Legal mechanism, which mandates that 20 percent of the landowner’s property is set aside for conservation purposes. As the WPPs are located on land that is leased (not owned) by EBP, it is the landowners’ responsibility to identify the Riserva Legal. The company provides assistance to landowners on this process. Riparian habitat protection areas, called Areas de Preservaҫão Permanente (APP), are designations created by the state; where they exist, related mitigation measures will be implemented as part of the PBA. In addition, for Fonte dos Ventos, EBP is also responsible for contributing 0.5% of total CAPEX to regional and/or local conservation actions, as determined by government authorities, as mandate by the Sistema National de Unidade de Conservação (SNUC), which is implemented in the State of Pernambuco .



As described in the section above on ‘Project Description’ the Fonte dos Ventos, Curva dos Ventos and Modelo WPPs are located in modified habitat; whereas Serra Azul and Cristal WPPs are located in caatinga natural habitat. Although none of the WWP sites of this Project are located in critical habitat, the Cristal and Serra Azul WPPs are located near to, and in some cases less than 10-kilometers from, an internationally-recognized site of importance for birds, the “Serra de Bonito”, which is designated an Important Bird Area (IBA) by BirdLife International and a Key Biodiversity Area (KBA) by Conservation International. Morro do Chapéu State Park (IUCN Protected Area Management Category II), which is also a KBA, is located some 10-kilometers north of the northernmost point of the Cristal WPP. The larger, regional-scale, Endemic Bird Area (EBA), which comprises the Cadeia d
o Espinhao mountains of interior Brazil in Minas Gerais and Bahia states runs adjacent to the eastern side of both Cristal and Serra Azul WPPs. The IBA/KBAs and the EBA are noted for a number of endemic and restricted range species, such as the Bahia Tyrannulet (Phylloscartes beckeri), yellow-faced siskin (Carduelis yarrellii), narrow-billed antwren (Formicivora iheringi) and the Bahia Spinetail (Synallaxis whitneyi).



The area of the Cristal WPP is a rugged terrain largely dominated by natural caatinga vegetation, which is semi-arid vegetation with highly erratic rainfall characteristic of Northeast Brazil. Caatinga habitat in Brazil is extremely heterogeneous with highly diverse vegetation of primarily forest (caatinga arbórea) and/or shrubland (caatinga arbustiva) including numerous endemics. The caatinga vegetation present at Cristal is a relatively undisturbed shrubland thicket which presents some elements of cerrado and seasonal dry forest vegetation. The area is regionally noted for its diversity and concentration of cacti and orchid species. The area of Serra Azul is similar to Cristal in terms of vegetation but contains a larger portion of transitional habitat between caatinga and seasonal dry forests and rocky plateaus. Both sites are situated amongst a larger landscape where a limited amount of dry-field agricultural (castor beans, corn) and animal grazing (cattles, goats) takes place at lower locations.



Flora and fauna data have been collected for the Cristal WPP sites as part of the ESIA baseline surveys, and a local environmental consulting firm has developed the Cristal Fauna Monitoring Program, which focuses on avifauna, bats and mammals and includes daytime and nighttime sampling with camera traps, mist nets, visual and acoustical detection methods. The Fauna Monitoring Program is well-designed and implemented by experienced biologists as part of the PBA. 136 bird species and only three species of bats were identified at Cristal during the initial baseline survey collection period, whereas 117 species of birds and six species of bats were identified as part of the Fauna Monitoring Program. Of these, 23 species of birds were caatinga endemics, two species were IUCN Near-threatened (NT) and one species (Zabelê - Crypturellus noctivagus) was IUCN Vulnerable. Although neither the nearby IBA/KBA nor the EBA are noted for the presence of migratory birds or for populations of raptor species or other large birds more susceptible to wind turbine impact, some vultures and other bird species were identified at potential collision height (all IUCN LC; two not yet assessed by IUCN) during the baseline survey. Of the bat species, none were reported to be threatened, endemic or migratory.



Baseline surveys have also taken place as part of the Serra Azul RAS and will be expanded upon in the PBA. 108 bird species were identified in the project area with nine species endemic to the caatinga biome. Two species of the seven serv
ed as justification for the creation of a nearby IBA, the Jack chic-chic (Red-shouldered Spinetail), Gyalophylax hellmayri (IUCN LC) and the Chorley-of-caatinga (Caatinga Antwren), Herpsilochmus sellowi (IUCN NT). Survey results for Serra Azul and Cristal indicate that, also as recommended by the company’s consultants, further surveying should take place on soaring and migratory birds given increased collision risk.



The company has agreed to conduct further assessments on avifauna and bats to bring its practices into alignment with the requirements of PS6. As indicated in ESAP Action Item #10, the company will contract external experts to collect further data on the potential use of the Cristal and Serra Azul WPPs by migratory birds and bats and those that fly at collision height (e.g., soaring birds and insectivorous bats). A collision risk model (CRM) will be developed by an ornithologist with sector-relevant experience for both Cristal and Serra Azul WPPs. This also follows recommendations made in the ESIA and RAS. Once the further baseline collection and the CRM has been conducted, further mitigation measures, such as turbine curtailment, lighting regimes, anti-perching structures, audible deterrents will be explored and, as needed, included in the mitigation strategy for fauna, as indicated in ESAP Action Item #11. The Fauna Monitoring Programs at Cristal and Serra will include a component on post-construction wildlife fatality monitoring. In the near-term, the company will install bird flight diverters on some of the above-ground transmission lines within the Cristal and Serra Azul WPPs based on an assessment, as indicated in ESAP Action Item #12. Given the potential for future WPPs to be located near high biodiversity value areas for birds, such as IBAs, the company will include engagement with relevant national and international conservation organizations for birds as part of its Stakeholder Engagement Framework.

As part of the surveys and studies carried out during the environmental permitting process, EBP retains competent cultural heritage specialists to conduct field survey and studies and meet the requirements defined by the Institute of Historic and Artistic National Heritage (Instituto de Patrimônio Histórico e Artístico Nacional - IPHAN). The studies reviewed are well documented and provide an adequate baseline for identification and protection of cultural heritage in the project areas of influence and the surrounding wider region. As required by IPHAN, the company ensures that all potential sites identified are mitigated, with avoidance and preservation as preferred strategy. The archaeological, historical and cultural heritage management plans developed as part of the PBAs includes investigative surveys, monitoring during construction, and, as needed, rescue of chance finds. Examples of avoidance actions, implemented to preserve potential archaeological finds, include an access road deviation at Curva dos Ventos WPP construction site. EBP’s treatment of cultural heritage is thus considered consistent with PS 8.

The company has a strong practice for engaging with project stakeholders. Consultation and engagement is carried out as part of site selection, during EIA development, during construction and during operations. This step-wise engagement and consultation process is described below.

After site selection, to resolve any impacts associated with land acquisition or economic displacement. Compensation is paid according to market prices, and negotiations are undertaken by local persons familiar with the (local) land laws. Legal contracts are signed, coordinated and filed by the Legal Department at headquarters. During the EIA stage, the Government carries out three public consultations for each WPP, in coordination with the company, at which time they discuss the EIA and management programs for the project. Consultations are carried out in a participatory manner and all findings (including attendees) are recorded in official acts. During the construction phase, stakeholder engagement is guided by the ‘Social Communications Program’ (SCP) found in the PBA (i.e., the environmental and social management program of each WPP). The SCP establishes a high-level process and approach for informing project stakeholders about the WPP, its impacts, mitigation and management. The SCP includes the implementation of a communications campaign, designed to keep stakeholders informed of project milestones (e.g, commencement of construction, employment opportunities, implementation of community programs, etc.). The communications campaign uses radio, television and other information mediums to inform peoples of the progress of the WPP. On some projects, a Comissão de Acompanhamento (CAE) has been formed as a means to address grievances. A CAE is a tripartite mechanism comprised of members from the company, local government and project-affected communities. The CAE facilitates communication and information sharing between the parties and creates a space where concerns and complaints can be heard and grievances resolved in a timely manner. The CAE meets on a monthly basis and is represented by members elected by the community.

Finally, throughout construction and into operations, the company hires a specialized external party to develop localized programs to address some of the specific challenges faced by local communities. Activities range from interventions in health and education to skills training and alternative livelihood creation for women. Community-based programs are initially funded for 12 months, with the possibility of scaling up activities for a second year. Total budget allocation and prioritization of activities is done by the Communications Unit.

While the company demonstrates the application of a number of good practices currently, it lacks a formal and systematic internal process at the corporate level for carrying out stakeholder identification, mapping and analysis and recording, documenting and tracking issues, particularly as it relates to sensitive issues such as land acquisition and resettlement, engaging with indigenous peoples, and addressing and resolving grievances. This will be addressed through the establishment of a formal internal policy and procedure, as indicated in ESAP Action Item #7.

Name: Alexandra Valenca
Title: Communications Coordinator
Company: Enel Brasil Participacoes
Address: Pҫa Leoni Ramos, Nº1 - 5º andar, BI 2 – São Domingos; Niterói / RJ, Brasil – Cep: 24.210-205
Tel: +55 21 2206 5600
Mail to: mailto:Alexandra.Valenca@enel.com
Website: http://www.enelgreenpower.com/en-GB/company/worldwide/brazil/

Broad Community Support is not applicable for this project

Enel Wind Brazil(33579) Supervision Disclosure Snapshot – Version 6
Description	Anticipated Completion Date	Status	Comments	Completion Date
Enel Brasil Participacoes (EBP) will review its project screening and risk assessment procedure to ensure alignment with IFC’s Performance Standards. Additional project screening criteria will be added for biodiversity and avifauna, indigenous peoples, cumulative impacts and reputational risks. The alternatives analysis process for the overall location of the wind site and the design of the site will be also included as part of the screening process of new project sites.	30-Sep-2014	Completed	Completed	10/28/2015
EBP will review its procedure with respect to its acquisition of existing assets to ensure that E&S aspects are assessed and mitigations are prescribed in alignment with Performance Standards.	30-Sep-2014	Completed	Completed	7/31/2015
EBP will develop a procedure on the integration of social impacts into the risks and impacts identification process to further align with the Performance Standards.	30-Sep-2014	Completed	Completed	7/31/2015
Through the use of an external expert, EBP will conduct a rapid assessment on the potential cumulative impacts of current and future planned wind power developments on high-risk avifauna areas in Bahia.	31-Dec-2014	Completed	Completed	7/16/2015
EBP will develop a roadmap to implement a modification in the company structure so that it accommodates the establishment of an Environmental and Social Technical Management Function that works across functional units by overseeing and coordinating E&S aspects from the project’s inception and site selection to implementation and operation.	16-Feb-2015	Completed	Completed	12/2/2019
EBP will contract a senior-level Biodiversity Resource to act as an advisor to the Company on biodiversity issues, particularly on birds and bats.	30-Apr-2014	Completed	Completed	11/1/2014
EBP will develop and implement a Stakeholder Engagement Policy and Procedure, to be applied in all new projects. The Policy and Procedure will include provisions which are consistent with PS requirements, including PS 7, and will include the requirement and process for establishing a community grievance mechanism.	30-Sep-2014	Completed	Completed	9/1/2015
EBP will develop a workers grievance management procedure on the basis of Human Rights Policy's provisions, which will apply to unionized and non-unionized workers, including contracted workers.	30-Sep-2014	Completed	Completed	7/17/2015
EBP will develop a procedure on land acquisition and involuntary resettlement consistent with Performance Standard 5.	31-Oct-2014	Completed	Completed	8/27/2015
EBP will contract external experts to collect further data on the potential use of the Cristal and Serra Azul WPPs by migratory birds and bats and those that fly at collision height (e.g., soaring birds and insectivorous bats). A collision risk model (CRM) will be developed.	30-Apr-2015	Completed	Completed	7/17/2015
EBP will include a component on post-construction wildlife fatality monitoring in the Fauna Monitoring Program at Cristal and Serra Azul WPPs. A review of additional mitigation measures will be conducted based on the outcomes of the additional birds and bat studies and included amongst mitigation measures for fauna management.	30-Apr-2015	Postponed	Changed project circumstances mandated a delay of this task
EBP will install bird flight diverters on some of the above-ground transmission lines within the Cristal and Serra Azul WPPs based on an assessment	15-Dec-2014	Postponed	Changed project circumstances mandated a delay of this task