While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The area (200 ha) occupied by the fertilizer plant is a portion of the broader Lekki Free Trade Zone which has been subject to a land acquisition and resettlement process by the Lagos State Government. The fertilizer plant site was previously used for subsistence agriculture with some residential usage, though generally only on a seasonal basis given the high water table in the area. Thus the site was a modified habitat, although the extent of this cannot be ascertained given that the site has been cleared of any vegetation. As such, and due to limited available information and the current state of the land, PS:6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply to the project. There are no indigenous people in Nigeria, thus PS:7 Indigenous People is not applicable. During the land acquisition process the identification and compensation / mitigation for cultural artefacts was addressed and the process for this described under PS5 below. Taking this into account and that the site has been cleared and leveled and no further excavation is required, it is determined that PS:8 Cultural Heritage also does not apply to the project.

This is Category A project according to IFC’s Environmental and Social Review Procedure. The project has the potential for significant adverse environmental and social risks and impacts that are diverse, irreversible and unprecedented. The project is located within the Lekki Free Trade Zone, a new development area with limited infrastructure at present, and thus the Group needs to ensure that for the most part, all ancillary facilities required for the fertilizer are developed by the company itself.

Key environmental and social issues relate to; i) land acquisition, the management of this process by LWIL and support by Dangote to communities affected by establishment of the LFTZ, and specifically the area where the fertilizer plant is located; ii) contractor compliance with the environmental and social management system for the construction phase, notably aspects related to occupational health and safety, pollution prevention and community safety; iii) effective control of solid and liquid wastes including materials handling (non-hazardous and hazardous) during construction and operations so as to limit the potential for pollution and impacts on public safety; iv) implementation of an appropriate Environmental, Health and Safety system during operations and internal capacity to ensure adequate implementation of the system; v) effective emergency response procedures and infrastructure to support such response including the involvement of communities if required; vi) energy efficiency; vii) management and monitoring of emissions to air and water; viii) traffic and transportation of final product; ix) active stakeholder engagement during construction and operations including the provision of sufficient resources to support this; and x) operation of the gas pipeline in accordance with accepted industry practices.

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.

Policy
The Group has an Environmental, Health, Safety and Social (EHSS) policy signed
off by Mr. Dangote that is applicable to all activities and will equally apply
to the fertilizer plant. The extent to which EHSS issues are adequately
managed and integrated into the various company activities varies with, for
example, the approach in the sugar operations being fairly robust, whereas in
some of the cement activities it is somewhat limited. However, this is well
recognized by the company and remedial actions described below, the road map
and the precursor to this i.e., the short action plan, are initiatives by the
Group to address these shortcomings.

The Group has also in the process of finalizing EHSS standards that will apply
to all operations and these relate to; i) undertaking Environmental and Social
Impact Assessments according to best international standards; ii) EHSS risk
identification and assessment; iii) stakeholder engagement; iv) land
acquisition and resettlement; v) occupational health and safety; vi) security
management and; vii) social investment. The intention is for these standards
to be applied as a benchmark across all the Group operations and they will be
used as a basis for EHSS management at the fertilizer plant during construction
where relevant, and operations.

Risk and Impact Identification
In accordance with the national Environmental Impact Assessment (EIA) Decree
No. 86 of 1992, an EIA is required for the fertilizer plant. Following
completion of the EIA, this is then submitted to the Federal Ministry of
Environment (“FMENV”) for review and approval; this process includes a
Technical Panel review meeting. Dangote commissioned a local consultant to
undertake the EIA in early 2014 and this was made available in draft form in
November 2014 and currently under review by FMENV. The approval process
involves the EIA report being made publicly available and then the Technical
Review Panel Meeting is convened, subsequent to which the project can be
formally approved. Currently it is anticipated that the review meeting will be
convened in January 2015 and on this basis the project should be approved in
February 2015. Once the gas supplier has been confirmed, an EIA will be
undertaken for this project component and the associated route in accordance
with national legislation. Further, the consultants will engage with IFC to
confirm the assessment addresses key issues such as land acquisition and
biodiversity if applicable in accordance with the Performance Standards; this
requirement is defined in the ESAP.

Cumulative impacts associated with the refinery being located adjacent to the
fertilizer plant have not been assessed at this stage given that the project
concept for the refinery is not as advanced as the fertilizer plant which is
under construction. Recommendations to address key cumulative issues are
however provided below. None of the other developments as envisaged in the LFTZ
master plan have as yet been confirmed e.g., the airport, and there are
currently only a few small scale industrial operations as noted. Thus the
fertilizer plant and refinery will dominate environmental and social impacts in
the short to medium term and the focus of cumulative impacts is therefore on
these activities.

Management Programs and Operational Capacity
At the request of the company and sponsored through initiative of Mr. Dangote
the Group CEO, IFC has been involved in assisting the company to design and
implement existing environmental health and safety (EHS) management systems and
structures including those related to community relations; the latter includes
development of internal capacity as outlined below. A key component of this has
involved appointment by the Group of Environmental Resources Management (ERM),
an internationally recognized consultancy, who reviewed the Group’s approach to
EHSS management across all activities, and defined a 3 year “road map” and
specific related EHSS actions to facilitate implementation of a robust and
consistent EHSS management system for all operations including the fertilizer
plant. This review allied to the road map was completed in February 2014.
Subsequent to this and to ensure ongoing momentum in implementation of the road
map, ERM, in consultation with Dangote, defined a short term action plan to be
implemented. This was done to allow the Group a period of time to develop
internal capacity and thereby be able to implement the road map itself. This
short term action plan is largely complete with specific tasks associated with
the plan, including: i) review of new projects the Group is initiating against
best practice in EHSS assessment; ii) mentoring of Dangote leaders on EHSS
issues; iii) capacity building which included an ERM specialist being on-site
at existing Group operations in Nigeria to review EHSS performance and develop
the capacity of individuals at the respective sites; iv) development of key
Group EHSS standards; and v) recruitment of individuals for a corporate EHSS
Directorate with the latter including an EHSS Director and respective
Environmental, Health and Safety and Social Managers. This Directorate will
function at the Group level and have oversight for all activities within the
Group, with the EHSS Director reporting directly to Mr. Dangote.

Recruitment for the EHSS Directorate as described above is essentially the only
outstanding task in respect of the short term action plan. In September 2014
Dangote appointed a recruitment company specializing in EHSS postings to assist
in identifying suitable candidates for the Directorate. The company has
identified and engaged a qualified candidate to fill the Group EHSS Director
role and is in the process of interviewing suitable candidates and a short list
has been identified for several of the other positions. Based on the current
status, it is envisaged that the EHSS Directorate will be staffed by mid 2016.
For purposes of the fertilizer plant, Dangote will ensure sufficient capacity
to implement the EHSS system, as referenced in the attached ESAP.

Management Programs
For purposes of the fertilizer plant, Dangote will be required to develop and
implement an EHSS management system aligned with the requirements of this
Performance Standard consistent with ISO 14001 and OHSAS 18001 (accredited
environmental and occupational health and safety systems respectively) to
enable the plant to comply with Nigerian laws and regulations, IFC Performance
Standards and the applicable World Bank Group EHS Guidelines. This system will
define Key Performance Indicators (KPIs) to mainstream EHS parameters such as
those related to; i) safety e.g., Lost Time Incidence Frequency Rate; ii)
resource efficiency e.g., tons of CO2 emitted / gas consumed per tons produced;
and iii) waste water and air emissions parameters. The plant will also compile
an EHSS report on the KPIs as outlined above including compliance with
regulatory requirements, community engagement activities and the like and make
such information publicly available including to IFC on an annual basis. The
requirements as outlined above are included in the project ESAP.

Dangote has appointed an experienced team to support the Group internally in
development of the fertilizer plant. Tata Consulting have been appointed as the
owner’s engineer and to provide oversight on behalf of Dangote and ensure the
project is constructed in accordance with the original design specifications.
As noted, Saipem is the EPC contractor, and Onshore Construction Limited
Liability Company (Onshore Construction), an Abu Dhabi based company with
experience in large scale projects such as this, the primary construction
contractor. Any sub-contractors on the project will be hired directly by
Onshore Construction.

Saipem is accredited against ISO 14001 and OHSAS 18001 and have a dedicated EHS
Manager for the project who will be supported by several staff, including
safety officers. All construction activities will comply with Saipem’s
management systems and structures and this is defined as a contractual
requirement with Dangote as well as Onshore Construction. Saipem has a Health,
Safety and Environment (HSE) Manual that applies specifically to the project
and this is supported by various other procedures and related processes as
outlined in subsequent sections below. The manual also includes an emergency
response procedure specifically for the construction phase.

To support Saipem’s approach to HSE and ensure issues related to community
safety and security are adequately addressed, Dangote will commission a
suitably qualified consultant to develop an Environmental and Social Management
System (ESMS) for the construction phase. This ESMS and the associated plans
and procedures will be compiled in consultation with Saipem and, where
necessary, incorporate and complement their HSE management system. The ESMS
will also address issues related to labor and security management (as outlined
below), in order to ensure a consolidated approach to the management of HSE
issues during the construction phase.

Emergency Preparedness and Response
A Quantitative Risk Assessment (QRA) has also been undertaken for the project
to identify the risk and impact of a worst case scenario associated with the
plant, namely a leak from the ammonia plant and inter plant ammonia transfer
lines; further information on the findings is provided in subsequent sections
of the report. Given the nature of the operations and the location of the plant
it will need to be largely self-reliant in respect of emergency response. Thus
the plant will have a dedicated fire department and supporting personnel and
equipment such as emergency response vehicles. Emergency response procedures
have already been developed for the plant which is being designed according to
international standards including that of US National Fire Protection
Association. The emergency response procedures will ultimately be integrated
into the EHSS system referenced above.

Monitoring and Review
As defined in the ESAP and referenced in subsequent sections of this document,
the company will monitor and review environmental and social performance on an
ongoing basis and notably in relation to the KPI’s as part of the ESMS. Doing
so will allow the company to assess performance so as to ensure ongoing
improvements in operations, and benchmark performance. This information will
be reported on internally within the company and at the corporate level.

Relative to the ESMS for the construction phase and to ensure it is effectively
implemented, aside from monitoring by Saipem, there will be independent
monitoring and review as defined in the ESAP. The findings will be regularly
reported on such that corrective actions can be implemented accordingly.

Stakeholder Engagement
Apart from the consultation process undertaken as part of the EIA, engagement
with stakeholders has been through the LWIL at the level of the LFTZ. For
purposes of community consultation and negotiation around land acquisition and
community development, a Central Working Committee was established for each
affected community. Relative to the fertilizer plant site these included the
Epe Lagoon Central Working Committee and the Lekki Coastal Central Working
Committee. Each of these committees is comprised of representatives from each
village associated with the respective affected communities (30 villages
associated with the Epe community and 10 related to the Lekki community).
These committees meet on a monthly basis with the objective of identifying
latest issues and grievances, as well as strategic planning for development of
the land that has been vested to them as part of their Memorandum of
Understanding (MoU) with the LWIL (see section ‘Land Acquisition and
Involuntary Resettlement’). The meetings are facilitated by the LWIL and
committee members are paid sitting fees to encourage attendance at meetings.
Each committee has a Chairman, Vice-Chairman, secretary, treasurer and
individual members.

For the purposes of resettlement and compensation for establishment of the
LFTZ, community meetings were also held as part of the official Government
compensation process. These were advertised on local radio and television and
held prior to the valuation process. These meetings were in the form of
information provision to communities regarding the excision, evaluation and
compensation process rather than consultation exercises to elicit information
from those affected by the acquisition. Further engagement in this regard was
during the asset inventory and valuation exercise to ensure that all crops,
economic trees, structures, shrines and burial grounds had been identified and
would be part of the compensation process.

Disclosure and consultation was undertaken as part of the EIA process. This
was conducted in order to disseminate information about the fertilizer project
to the host communities and stakeholders and to gain information for the
specialist studies undertaken as part of the EIA. In particular, consultation
was held as part of the social specialist study, including: in-depth interviews
with youth leaders, women leaders, Chairmen of Community Development
Associations, resident teachers, health officials and community leaders; group
discussions with people representing different socio-economic characteristics;
and focus group discussions with people with particular areas of expertise.
The EIA does not indicate whether general disclosure or consultation was
undertaken as part of the EIA process itself, or prior to project activities on
site taking place. During the EIA process and prior to the Technical Review
Meeting, the EIA documentation will also be made available for public review.

In going forward and as defined in the ESAP, the Group will be required to
develop and implement a Stakeholder Engagement Plan (SEP) for ongoing
engagement with the affected communities. This will focus in particular on
those affected by the land acquisition and compensation process, and link
closely with the Community Development Plan (CDP) as referred to in the section
below entitled ‘Land Acquisition and Involuntary Resettlement’. An important
stakeholder in this exercise will be the LWIL, to ensure alignment and
integration (where possible) with the overall consultation process as
undertaken for the LFTZ. The SEP will align with the Group EHSS standard on
Stakeholder Engagement which provides for the development of cooperative and
collaborative relationships with groups and individuals that have an influence
or are impacted by development projects, and ensuring that engagement is a
two-way process. It will also include an appropriate grievance mechanism to
facilitate and address concerns and complaints that may arise in relation to
the construction and operation of the fertilizer plant.

Working Conditions
The company employs over 16,000 individuals across its various operations and
this is continually increasing as the Group expands its operations in Nigeria
and abroad.

In Nigeria the minimum age for employment is 18 years and Dangote employs no
individuals under this age and this will similarly apply to the fertilizer
plant. The Group has a Human Resources Policy and a Staff Induction Manual and
this, allied to a signed contract with each employee, details the associated
employment procedures and employment conditions for workers. This
documentation defines the approach to leave requirements, compensation,
grievance mechanism, disciplinary procedures amongst others aspects. Further
and in accordance with national requirements, the company allows for collective
bargaining and workers to join unions.

The number of employment positions during the construction phase is still to be
defined, however it is envisaged this could peak at 3,000 workers. Onshore
Construction will provide the majority of the construction staff who will be
sourced from Asian countries, and locally. Subcontractors will be sourced
internationally and locally with staff equally being either from abroad or
Nigeria. As defined in the ESAP, via the ESMS for the construction phase the
management of sub-contractors will be in accordance with the requirements of
this Performance Standard.

Some 800-900 permanent employment positions will be created for operation of
the fertilizer plant. The current Dangote team overseeing development of the
plant will assume responsibility for management of the plant once operational
and the intention is to maximize local employment and develop capacity to
operate the plant such that the reliance on expatriate staff is minimized in
the long term. For purposes of operations, Dangote will apply its existing
approach to human resources which is largely aligned with this Performance
Standard. As defined in the ESAP, the approach to human resource management
for the fertilizer plant will be reviewed by Dangote in consultation with IFC
against the approach to labor management as required by the Nigerian Export
Management Zone Authority in free trade zones and the Performance Standards to
ensure alignment respectively.

Occupational Health and Safety
During operations occupational health and safety will be managed via
implementation of the EHSS system as described under PS:1 with staff equally
dedicated to implementation thereof.

As described above, Saipem are OHSAS 18001 certified and all construction
companies including the primary contractor and subcontractors need to comply
with Saipem’s approach to occupational health and safety (OHS). Saipem’s EHS
Manager is experienced and has previously undertaken oversight of similarly
large construction projects. This manager will be supported by several site
specific safety officers still to be appointed. In addition, every company
involved in construction is required to have one full-time safety officer for
every 50 individuals employed. All safety officers will be trained by Saipem,
construction personnel will undergo a two day induction training program
covering all EHS aspects, there will be job specific training for workers
involved in specific high risk tasks and visitors to site will also be required
to undergo a short induction course.

Saipem applies a job safety analysis to all tasks to minimize risks and there
are 34 safety work procedures and instructions that apply to activities
including those related to working at heights, safety signs, working at night,
scaffolding, working in confined spaces etc. There is a defined approach to
incident reporting including that related to near misses and corrective actions
to be taken. Equally, there is also a manual on EHS monitoring and reporting.
All workers will be required to undergo a medical screening exercise prior to
work and there will be a medical facility on-site staffed with appropriate
personnel.

Given the above, it is considered that there is sufficient oversight of OHS
during construction and thus the construction specific ESMS will just need to
incorporate the EPC contractors safety systems into the broader system to be
applied.

There will be a workers camp on-site and accommodation off- site for more
senior expatriate staff. All local staff will reside in the surrounding
areas. In accordance with the ESAP, the design for worker accommodation will
be reviewed in accordance with IFC’s guidance note for such to ensure alignment
in practices.

The project design is based on established and recognized technologies whose
performances are both predictable and well proven in operation such that no
significant variations are expected between predicted and actual performance.
In addition, the project has been designed to comply with the national
requirements and applicable World Bank Group EHS Guidelines.

During construction, potential pollution related issues will relate primarily
to siltation of adjacent water bodies i.e., the Lekki lagoon; air pollution
(e.g., dust generation and that associated with equipment); material spills;
incorrect disposal of liquid wastes e.g., sewerage from the housing colony; and
offsite discharge of contaminated stormwater. These impacts can be adequately
managed via implementation of the Saipem EHS Manual allied to the broader ESMS
to be developed and applied to the construction phase.

During construction, water will be provided via boreholes and treated prior to
use as potable water, sanitary requirements and for general construction
requirements e.g., concrete mixing. During operations the facility will require
60,000 m3 of water per day which will be sourced from the adjacent Lekki
lagoon. The water will be treated via a reverse osmosis plant and used
primarily as cooling water make-up, service water, demineralized water, potable
water and fire-water. There will be a treated water storage tank on-site with
a capacity of 5,800 m3 half of which will be dedicated to fire water. Ongoing
monitoring of water quality following treatment will be undertaken and, where
applicable, this will also include monitoring to compliance with potable water
quality requirements.

Waste water generated by the facility during operations will primarily include
cooling tower blowdown, sanitary water, process water, washings and
contaminated stormwater. All water will be discharged to an on-site waste
water treatment facility which has been designed to treat the water to national
discharge water quality requirements and those associated with the WBG sector
specific and General EHS Guideline requirements. This is included as a
contractual requirement between Saipem and Dangote. Treated waste water will
be discharged to the ocean through a dedicated pipeline and there will be
ongoing monitoring to ensure compliance with the discharge requirements. The
monitoring requirements for the in-take water allied to waste water discharge
are defined as a requirement under Performance Standard 1 requirements in the
ESAP.

The site has been designed so as to separate potentially contaminated
stormwater from clean stormwater with the former being treated as per above and
clean stormwater discharged to to the Lekki lagoon; the latter will also be
monitored as set out in the ESAP.

Energy use is dominated by energy consumption of the ammonia manufacturing
plant whose specific energy consumption falls within the Best Available
Techniques range defined in the relevant European Union Integrated Pollution
Prevention and Control Reference Document (the IPPC BREF). Once operational,
Dangote will review the plant to confirm compliance with design specification
and identify any additional areas where efficiencies can be realized,
particularly in the utilities areas.

An air quality study was undertaken as part of the EIA, and Saipem also
undertook a separate air quality study. The air quality study for the EIA
included baseline air quality sampling for ammonia (NH3), sulfur dioxide (SO2),
nitrogen dioxide and particulate matter (PM); these are the parameters of focus
in both air quality studies undertaken. Aside from PM, the monitored baseline
results at all monitoring locations were below the detection limit. Both
studies used recent versions of AERMOD, a recognized air quality modelling
program to predict the ambient air quality for NH3, SO2, nitrogen oxides (NOx)
and PM during normal operating conditions at the fertilizer plant.

Continuous point source emissions included in the studies are the primary
reformer, granulation towers, vent stack separator and boilers. Other than the
point source NH3 emissions on the granulation towers which are defined as 105
mg/Nm3 per which is just over double that defined in EHS Guidelines (50
mg/Nm3), all the other emission concentrations for the four parameters defined
are aligned with the applicable sector specific guidelines as per the
contractual requirements applicable to the project. When modelled, all the
concentrations predicted for the respective air quality parameters are well
below internationally recognized air quality standards e.g., World Health
Organization (WHO), US Environmental Protection Agency, on and off the site. In
respect of NH3, the maximum modelled concentration over a 24 hour period is 41
µg/m3 versus the accepted guideline value of 100 µg/m3 for this period;
similarly the modelled concentrations over 30 minutes and 1 hour are also below
guideline values for such. The studies did not identify potential receptors
e.g., communities, including those that may be sensitive e.g., schools and
hospitals. Given the location of the facility within the LFTZ, however, no
communities are in direct proximity of the plant, therefore the impacts
associated with air quality are considered to be of limited significance.

However, taking into account that; i) the studies only assessed routine
operating conditions i.e., not start up and upset conditions; ii) there was no
focus on sensitive receptors; and iii) the cumulative impacts of emissions from
the refinery were not assessed. Thus as set out in the ESAP the company will
undertake an updated air quality study including a cumulative assessment of air
quality impacts. On this basis the study will assess the impact of emissions
during routine and non-routine conditions at both the fertilizer plant and
refinery (and other reasonably anticipated large developments in the LFTZ),
define impacts on sensitive receptors, and where necessary make recommendations
to mitigate any potential adverse impacts identified including a monitoring
program for both facilities.

The facility will use 210 million standard cubic feet of gas per day to be
provided via a supplier (still to be defined) and a pipeline some 50 km that is
to be constructed. Gas will be used in the process and for energy for the
three 40 MW steam turbine generators. There will also be a 4 MW auxiliary
diesel generator that will be used during plant shut down and for start up.
Total CO2 emissions from the plant are estimated at 1.65 million tonnes per
annum and once operations commence, this figure will be updated to include fuel
usage associated with vehicles.

The QRA undertaken for the plant defined worst case scenarios, the likelihood
of these occurring and the consequences in such an event. The primary toxic
substance utilized in the process is ammonia and the worst case scenarios were
defined as leaks from transfer piping between the ammonia and urea plants. Two
classes of leak were assessed i.e., a minor leak characterized by a hole size
of 10 mm in the transfer line from the ammonia plant to the urea plant, and a
major leak characterized by a hole size of 50 mm also within the transfer
line. The findings of the assessment for the two scenarios considered were
evaluated against accepted risk criteria for workers (i.e., on the plant) and
the public (i.e., off-site) as utilized in the United Kingdom. In respect of
workers who would generally be on-site for 8 hours a day the risk was defined
as “tolerable”, while in relation to the public it is considered “acceptable”.
Tolerable risk is defined as the potential for an occurrence once a year,
whereas acceptable risk is defined as the potential for such an occurrence
every 114 years which is beyond the envisaged life span of the facility.

Given the potential for off-site impacts though and as referenced below, the
emergency response plan for the facility will need to accommodate the potential
for off-site impacts and thus where applicable, timely notification and
evacuation within the Free Trade Zone and beyond as defined in the spatial
analysis of impacts in the QRA.

Baseline noise monitoring was undertaken as part of the EIA and Saipem
undertook preliminary noise modelling to determine potential impacts on ambient
noise due to plant activities. As per the design parameters with which the EPC
contractor is to comply, the plant will be required to comply with the WHO
noise guideline levels for residential and industrial areas as defined in the
WBG General EHS Guidelines; based on the noise modelling completed, the plant
will align with the Guidelines. Following plant commissioning, noise monitoring
will be undertaken to assess compliance and this requirement is integrated into
the broader requirement for the plant ESMS for operations. Taking into account
the plant location and that there are no residential structures in close
proximity to the site, the impact of noise is considered to be of limited
significance.

Construction waste will be managed via the ESMS for this phase and Saipem have
a specific waste management plan. During operations, general non-hazardous
waste including domestic waste will be collected in designated areas and
disposed of by the Lagos State Government at the local municipal waste disposal
sites. The latter will include sludge from the treatment plant. Hazardous
wastes such as oils, paints and resins and the like, will also be collected in
designated areas and disposed of by registered waste disposal companies. Spent
catalyst will be stored in the drums received and returned to the supplier.
The company will, however, develop a comprehensive solid waste management plan
as part of the ESMS for the operational phase which will define the approach to
the various waste streams.

The plant is being constructed in accordance with internationally recognized
design and building codes and standards and the design documentation details
respective codes and standards being applied to every aspect of design,
construction and equipment. With reference to wind and earthquakes, the design
standard being applied is that associated with the British Standards Institute,
while the ASME standards will be applied to all pressure vessels including the
ammonia tank which will be a double walled tank. Although the findings of the
QRA indicate the risks to the public are acceptable, the plant’s emergency
response plan will need to incorporate the need for potential notification of
individuals off-site and evacuation thereof.

Based on the plant’s production capacity, some 250 heavy vehicles will access
the plant on a daily basis aside from vehicles associated with the delivery of
goods and services, and personnel. The transport of urea will be undertaken by
Dangote and private contractors. The current site design will be amended to
include a designated vehicle staging area.

As part of the LFTZ masterplan, the intention is to construct new major access
routes from the zone directly into Lagos and elsewhere. Development of these
access routes is the Lagos State Government’s responsibility and there is no
confirmation as to when these will be developed. Via Lagos the LFTZ is accessed
via the Lekki Expressway and the coastal highway from which the LFTZ is
directly accessed. Road access within the zone is good and the Expressway also
provides good access as it is a dual carriageway. The highway is however a
single carriage road traversing through various busy residential and commercial
areas. Taking this into account, as well as the need to define a staging area
and that the refinery will be located adjacent which will also generate
significant traffic, the company will develop and implement a Traffic
Management and Safety Plan for the refinery and fertilizer plant. This will
include traffic staging areas inclusive of amenities such as ablution
facilities required to accommodate drivers. This requirement is defined in the
ESAP.

A workers’ accommodation camp is being constructed on-site to accommodate
expatriate workers from India primarily, though other workers will also be
housed at the camp. Given the location of the site which is in one of the more
remote areas of the LFTZ towards it eastern extremity, allied to the site being
within the LFTZ which is a secure area, potential interactions with the local
communities will be limited. Further, the site locality will also limit the
potential for an influx of job seekers. Nonetheless, the latter are likely to
congregate at the entrance to the LFTZ and equally the entrance to the site
itself. In addition, informal trading will also arise in the proximity to the
site. Thus the ESMS for the construction phase will include measures to
formalize these aspects for example by designating specific points where local
workers will be hired from, and defining areas where trading activities may be
established.

Saipem has a Security Manager and for purposes of security during construction,
an outside agency has been contracted to provide security. As is standard in
Nigeria, mobile police (Mopol) and Military Police will also provide support
during the construction phase and will be armed. This will similarly be the
case during operations in that there will be a Security Manager and security
for the plant will be outsourced with support also being provided by Mopol and
the Military Police. One of the EHSS Group standards is “Security Management”
and in compilation of this, one of the aims of this has been to ensure the
approach aligns with the requirements for security management as defined in
this Performance Standard. As defined in the ESAP, Dangote will align the
approach to security during construction and operations with the Group standard
for this activity and include monitoring measures to ensure this is
implemented. Thus this will include an initial risk assessment to identify
potential risks associated with operations and, defining a security plan which
details the approach to training and competency of workers, communication and
consultation and incident reporting. Taking into account the use of government
security personnel, Dangote will aim to influence the practices of such
personnel such that they align with the security plan as referenced and notably
their approach to use of armed force as a last resort, and the manner in which
such forces interact with the community.

Broad Community Support is not applicable for this project

Dangote Ind.(33744) Appraisal Disclosure Snapshot – Version 2
Description	Anticipated Completion Date
Develop and implement an Environmental, Health, Safety and Social (EHSS) management system aligned with the requirements of this Performance Standard consistent with ISO 14001 and OHSAS 18001. This system is to: • Include Key Performance Indicators for mainstream EHSS parameters such as those related to; i) safety; ii) resource efficiency; iii) community engagement and iv) monitoring parameters relative to the plans defined below; • Develop and implement monitoring plans for point source air emissions, intake water, potable water, waste water and stormwater aligned with the World Bank Group sector specific and General Environmental, Health and Safety Guidelines; • Define a solid and liquid waste management plan to be implemented accordingly; • Include structures and systems to facilitate implementation of the air quality monitoring program referred to below; • Include an ambient noise monitoring program and procedure to facilitate implementation; • Include procedures and plans such that the approach to security management is aligned with the Group standard for this activity; • Include an emergency response plan that accounts for the findings of the quantitative risk assessment (QRA) and specifically accommodates the need to notify and, where applicable, evacuate individuals located off-site as may be impacted by emergency scenarios evaluated in the QRA; and • Define roles and responsibilities for effective implementation of the EHSS management system.	31-Jan-2021
Appoint adequately experienced individuals to implement the EHSS management system prior to plant commissioning and ensure adequate resources are available to support implementation of the Stakeholder Engagement Plan and Community Development Plan (as referenced below) .	31-Mar-2021
In accordance with national legislation undertake an Environmental Impact Assessment for the gas pipeline. Engage with IFC to ensure key environmental issues e.g., land acquisition / biodiversity, are assessed and associated mitigation measures comply with the Performance Standards. 3 (a)Full reinstatement of the RoW of the NGC gas pipeline 3( b)a) Finalize and implement the Farmer Support Program. b)Provide periodical monitoring reports of the implementation of the Farmer Support Program 3(c) a) Hire a competent external resettlement expert to undertake an independent assessment of the resettlement process and outcomes of those households that were physically displaced and/ or those who lost structures (including businesses) for the NGC pipeline RoW. b) Implement any corrective actions identified to address any significant gaps and to achieve positive outcomes for the affected households	31-Jul-2021
Commission a suitably qualified consultant to develop an Environmental and Social Management System (ESMS) for the construction phase. This ESMS is to; i) integrate with Saipem’s existing environmental, health and safety management system; ii) include measures to manage the influx of job-seekers and informal trading; iii) define a procedure such that sub-contractors are managed according to the requirements of Performance Standards 2: Labor and Working Conditions, and there is monitoring to ensure compliance; and iv) define the approach to security management in accordance with the Group EHSS Standard: Security Management.	30-Jun-2017
Develop and implement a Stakeholder Engagement Plan to be applied to construction based on the Group EHSS Standard for Stakeholder Engagement.	30-Jun-2017
6.(a)DFL to commission a suitably qualified consultant to undertake a process safety management review of DFL project prior to commissioning. 6.(b)DFL will develop and implement a detailed operational readiness and process start-up program prior to commissioning/ before start of operation phase	31-May-2021
Review the approach to human resource management for the fertilizer plant in consultation with IFC against the approach to labor management as required by the Nigerian Export Management Zone Authority for free trade zones and Performance Standard 2: Labor and Working Conditions. Based on the review findings, update the fertilizer plant human resources documentation as applicable.	31-Dec-2017
Review the design for worker accommodation on-site relative to IFC’s guidance note on such to ensure alignment. Based on the review findings, amend the design of the worker accommodation	30-Jun-2017
Commission a suitably qualified consultant to undertake an air quality study against agreed Terms of Reference to: • Assess the cumulative impacts as a result of the fertilizer plant, the refinery and other reasonably anticipated large developments in the LFTZ operating simultaneously and under routine and abnormal (start-up and upset) conditions; • Define recommendations if necessary to ensure impacts on air quality are in accordance with internationally acceptable levels; and. • Develop an air quality monitoring program for both the fertilizer plant and refinery aligned with accepted and recognized criteria for such.	31-May-2021
Commission a qualified specialist e.g., traffic engineer, to develop a Traffic Management and Safety Plan for the fertilizer plant and refinery that includes the requirement for dedicated vehicle staging areas of adequate capacity, and includes sufficient amenities such as ablution facilities. Thereafter, implement the plan accordingly.	31-May-2021
Commission an independent consultant to develop a Community Development Plan aligned with the Group EHSS Standard on Community Investment. This Plan is to focus on livelihood development and restoration for communities in Section A and align with existing initiatives by Lekki World Wide Investment Limited. It is to include; i) stakeholder mapping, ii) a social/ livelihoods survey; and iii) facilitation of development and prioritization of community projects to be developed (focusing in particular on the 750 ha of land); and iv) provision for ongoing monitoring and evaluation of implementation.	31-Dec-2017