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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The environmental, social, health and safety, labor (ESHS) impacts and risks associated with the construction and operation of CMSA are expected to be incremental to existing ones and manageable with readily available industry practices. However, the CMSA concession area was covered with secondary mangrove forest. Mangrove forests are considered protected habitat under Mexican environmental law. Therefore, even though the land was cleared by APIMAN before the concession was granted to CMSA, this has been classified as a Category A project, given the near complete conversion of the mangrove forest cover was performed in anticipation of the project.
As noted above, PS 1-4 and 6 are considered applicable to this investment. PS5: Land Acquisition and Involuntary Resettlement is not considered applicable because there are no land acquisition issues or physical or economic displacement involved. There are no indigenous peoples or territories in the project’s direct or indirect area of influence, hence PS 7: Indigenous Peoples is not considered applicable. There are no historical, cultural, or archeological sites within the project direct or indirect area of influence, thus PS 8: Cultural Heritage is not deemed to be applicable; however during construction CMSA implemented a standard Chance Find Procedure that required a certified archeologist to be present on-site during all construction excavation activities, and no archeological findings were reported.

 IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System: In 2004, APIMAN
performed an Environmental and Social Impact Assessment (Manifiesto de Impacto
Ambiental - MIA) for the Manzanillo Port Complex expansion, including the CMSA
terminal. In 2009 the original expansion master plan and MIA were modified to
mainly address an increase in the amount of dredge material considered in the
original MIA. This MIA was developed in compliance with Mexican laws and
regulations, it was aligned with good international industry practices, and
adequately addressed the most relevant environmental and social risks and
impacts associated with the proposed terminal. The final MIA was approved in
June 12, 2009 by the Environmental Authority (SEMARNAT – Secretaria de Medio
Ambiente y Recursos Naturales) via environmental license No
SGPA/DGIRA/DG/3467/09.
Identification of Risks and Impacts: The Manzanillo Port is located within a
highly modified coastal habitat where ecological functions have been disturbed
for over 40 years by human activity. The key EHS impacts and risks associated
with the project’s construction are (a) clearance of a total of 15.7 ha of
mangrove forest, which is protected under Mexican Law – NOM-022-SEMARNAT-2003,
(b) impacts associated with the dredging of new channel (7,743,600, m3) and the
berth (275,179 m3), and additional impacts typical of any civil construction
such as: (c) increased air emissions and dust, noise, and vibration from earth
movements and construction works, (d) generation of solid and hazardous waste
from construction activities and/or accidental spills, (e) liquid effluent from
construction activities (f) increased risks from transportation of heavy
equipment and machinery in peri-urban and urban roads, and (g) potential health
and occupational risks to construction workers including the risks associated
with handling and operating heavy equipment and machinery.
Once in operation, the key EHS impacts and risks are incremental to those from
the existing port activities, and include: (h) impacts and risk from increased
ship traffic (e.g. pollution risks from fugitive and/or accidental spills from
vessels, increased turbidity) and road traffic in peri-urban and urban roads,
(i) impacts associated with maintenance dredging and disposal of dredged
material and increased generation of operational solid and hazardous waste, (j)
treatment and disposal of ship effluent and ballast waters, (k) increase
generation of air, dust and noise emissions and (l) occupational health and
safety of port and shipyard employees.
Since CMSA is within an existing operational port complex, none of these
impacts and risks will be new, and will essentially be incremental to existing
ones. All these impacts and risks can be managed with existing pollution
prevention and control technologies and with standard environmental and social
management practices.
Management Program: CSMA hired a specialized company for the construction of
the terminal, named China Harbour Engineering Company (CHEC). At the time of
IFC involvement and site visit, CHEC was no longer at the site, construction
was essentially finished, and the project was commencing operations. Even
though the IFC did not have the opportunity to review the Environmental, Social
and Health and Safety (ESHS) Management plans for construction, independent
ESHS consulting firms were hired on behalf of CSMA to supervise EPC’s
compliance with ESHS requirements – mainly pollution prevention and control
measures as well as occupational health and safety. At the time of the visit,
there were no reported non-compliances or liabilities.
Commissioning and initial operation of the project began in August 2013, with
operation ESHS plans and procedures still under development. Full operations
are expected to start 1Q2014. As per the concession agreement, CMSA has 18
months to develop, implement, and certify under ISO 9001, 14001 and CMSA has
decided to also certify under OHSAS 18001 and ISO 28001 as an integrated
quality, environmental, health and safety and security for the supply chain
management system (QEHSMS) for the Project. As a requirement for IFC’s
financing, CMSA will ensure that this QEHSMS and associated Environmental,
Health and Safety Management Plans (EHSMPs) are aligned with IFC requirements
including good international industry practices (GIIP).
Organizational Capacity and Competency: CMSA has developed its organizational
structure, defined roles, responsibilities, and authority to implement the
QEHSMS and operational ESMPs. Currently, CMSA has a staff of two professionals
who, with the support of external consulting firms, ICTSI’s corporate team, and
EHS specialists from other ICTSI terminal ports in Ecuador and Brazil, are
working on certifying the QEHSMS.
Emergency and Response: CMSA is responsible for handling any localized
emergency at the terminal but APIMAN is responsible for providing emergency
response at the Port level. Since APIMAN is responsible for hiring contractors
to handle fueling activities, they are also responsible for responding to any
spills.
A large emergency operations center located just outside of the project’s gate
is staffed and run by APIMAN. This operations center maintains full
fire-fighting and medical equipment to address full-scale emergencies,
including a 24-hour fire-fighting crew, two fire trucks fully provisioned with
spill control equipment, ambulances and medical and paramedical personnel. This
center operates 24 hours a day, 7 days per week and serves local community
needs as well as port emergencies.
CMSA does not keep spill control equipment in their terminal and they depend on
APIMAN to provide spill response and cleanup services for any major spills.
However, CMSA does have an Emergency Response Plan (ERP) that contains a
description of the relationship and command structure with APIMAN’s emergency
response services, and includes a vulnerability assessment, an inventory of
resources that are available for deployment in case of an emergency, a risk
analysis, and general procedures for different emergency scenarios. This ERP
provides procedures for the following scenarios: earthquakes, tsunami, fire,
explosions, bomb disposal, demonstrations, heavy rains, flooding, and
hurricanes. The Terminal is served by a fire brigade distributed over four
shifts. Available equipment includes 12 complete firefighting suits in
conformance with NFPA requirements, 8 HAZMAT level “A” suits for chemical
releases, absorbent material, 20 hydrants distributed throughout the container
yard, maintenance shop and administrative offices. In addition, a trained
paramedic or doctor is available to attend to medical needs during each of the
shifts. The risk evaluation document states that an ambulance is available with
a 10-minute travel time to the terminal.
Monitoring and Review: CMSA’s operational EHSMP will include effluent, air
emissions and noise monitoring, as well as ambient quality monitoring program
to address physicochemical water quality and aquatic ecology condition around
the project’s area of influence. This monitoring plans and programs have the
objective of verifying the effectiveness of the proposed impact mitigation
measures, and include procedures to assess air, noise, soil, water and marine
sediment quality.

Human Resources and Labor: As part of the concession with APIMAN, CMSA is
committed to comply with all applicable national laws and regulations. Mexico
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 Collective Bargain; the
International Covenant on Civil and Political Rights; the American Convention
on Human Rights; and the International Covenant on Economic, Social and
Cultural Rights. Mexican laws require that the employer take all measures
necessary to effectively protect the lives and health of workers, maintain
adequate safety and health conditions, and provide the necessary tools to
prevent occupational accidents and diseases. Therefore, CMSA has a legal
obligation in accordance with the Federal Labor Law and through their contract
with APIMAN against any type of forced labor or hiring candidates under 18
years old. CMSA requires that contractors be in compliance with applicable
Mexican labor laws.
Construction involved a total of 150 Chinese nationals, who were temporarily
located in a workers camp within the project’s site. As stated before, during
appraisal all the worker camps had been dismantled, and there was no trace of
CHEC at site. The operation has just begun, and it is anticipated that
approximately 799 employees will be needed, out of which 66% are unionized.
All CMSA manual laborers belong to the port workers and stevedores union (Unión
de Estibadores y Jornaleros del Pacífico - CROM), who are covered under a
collective agreement, which qualify position levels and task descriptions, and
specifies responsibilities, benefits and salaries scales. The contract between
CMSA and the CROM has been reviewed and approved by the relevant labor
authority (Secretaria de Trabajo y Previsión Social - STPS) and has been found
to be compliant with all applicable Mexican laws and regulations. The
composition of this workforce is 100% male, and there are no women who belong
to the CROM. This gender imbalance seems to respond more to the nature of port
workers and stevedores occupation (which requires significant upper body
physical strength) and to local cultural and historical factors than to
discriminatory gender policies. At any case, the Inter-American Development
Bank is in the process of providing Technical Assistance to APIMAN to evaluate
opportunities to increase female participation in overall port activities.
For management, technical and other non-unionized positions, CMSA hires both
men and women, which are currently distributed in 23% females and 67% men. CMSA
has a policy against any type of discrimination in hiring and promotion
process, and also against any form of harassment.
The nature of the terminal facility is one that does not anticipate termination
of operations in the short to mid-term time frame. In the event that CMSA’s
operational plans result in the need to reduce the workforce, the company will
develop and implement a retrenchment plan, in consultation with the trade
unions, and in alignment with IFC PS2 requirements.
A grievance mechanism between CMSA and CROM has been established as part of the
existing union contract. Grievances for non-union workers must be provided
personally to the head of human resources.
As part of IFC financing CSMA will develop a written HR policy in alignment
with the Mexican requirements and IFC PS2, including specific
non-discriminatory policies and the development of an accessible and
well-advertised internal grievance mechanism that includes opportunities for
anonymous feedback, assures no retaliation, and provides accountability for the
resolution of grievances.
Occupational Health and Safety: Occupational hazards associated with the
construction of the project were those typical of medium scale civil
construction works, and include: transportation and use of cranes and other
heavy equipment, handling and storage of hazardous materials onsite, electrical
work and work on confined spaces, near water, and scaffolding, platforms, and
other heights, welding, excavations and trenching. For construction, CMSA hired
an external consultant to supervise CHEC’s health and safety compliance during
project’s construction. No major accidents or pending liabilities were
reported.
During operations, the main health and safety impacts are physical and chemical
hazards, working in confined spaces and exposure to organic and inorganic dust
as well as noise. The health and safety management team is composed of 16
professionals. Even though operations had commenced during IFC’s appraisal
visit, the operational occupational health and safety plans were still being
developed. CMSA has prepared an appropriate health and safety plans and
procedures that comply with in country requirements as well as with GIIP as
those reflected in the World Bank Group’s EHS Guidelines.
http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/gui_EHSGuideline
s2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf
,http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/gui_EHSGuidelin
es2007_PortsHarborsTerminals/$FILE/Final+-+Ports%2C+Harbors+and+Terminals.pdf




As indicated under PS1, per the concession agreement, CMSA has to certify under
ISO 9001 and 14001 and by its own decision has included OHSA 18001 and 28001
integrating quality, environmental, health and safety and security for the
supply chain as a management system (QEHSMS). The system must be certified by
1Q 2015. As part of this QEHSMS, the company is currently starting
certification audits.

Construction and operation activities are not expected to materially worsen the
existing environmental conditions, and APIMAN and CMSA have implemented
standard pollution prevention and control practices aligned with GIIP.
Dredging: The most significant pollution-related impact during construction is
the potential re-suspension of pollutants and disturbance to water quality
(e.g. turbidity, dissolved oxygen) associated with the dredging of the inner
harbor and navigation channel. APIMAN dredged a total of 7,743,600 m3 of the
inner harbor and navigation channel to a depth of 16.0 meters below sea level
to allow for the transit of fourth generation large vessels. CMSA performed
additional dredging of 275,179.50 m3 to level its berth and construct its
wharf. The COESPRIS (State Commission for the Protection of Health Risk) which
belongs to the COFEPRIS (Federal Commission for Sanitary Risks Protection) and
manages health programs, performs monthly monitoring campaigns for
phytoplankton, zooplankton and over ambient marine pollutant in strategic areas
around the Manzanillo port complex area of influence. Extensive chemical
analysis of dredge material were conducted and no contaminants were detected
that would categorize the dredged material as hazardous according to Mexican
norm (NOM 052 SEMARNAT 1993). The entire amount of dredged material was used
for fill on the terminal yard.
Pollution Prevention and Control: The potential for storm runoff to carry
pollutants into the marine environmental is expected to be very minimal since
it was reported that all the drains on the yard lead to the terminal’s
wastewater treatment system. Discharges from ships directly into the harbor are
prohibited. Facilities for the removal of contaminated bilge and sanitary waste
as well as solid waste disposal are provided through APIMAN.
A number of mitigation measures for the operation phase have been developed
that are intended to reduce the potential for impacts to water quality in the
harbor. Identified operational phase mitigation measures include: (a)
establishing within the rules of operation of the APIMAN the prohibition on
dumping burned oil and hydrocarbons in general, or liquid chemicals of any
type, into the ocean or drainage system in order to prevent contamination of
these bodies of water, (b) establishing within the rules of operation of the
APIMAN the prohibition on discharging bilge water into the ocean, as set forth
in the Regulations of the National Water Act, (c) preventing materials from
falling into the inner harbor during the loading, unloading, and handling of
bulk materials using piers, tarps, and/or nets, (d) prohibiting the maintenance
of ship hulls in the port, unless this activity is carried out at authorized
port facilities designed for such purpose.
Effluent and Waste Management: The new terminal has been designed and
constructed not to discharge any wastes to the harbor. The project has been
designed to minimize the generation of both hazardous and non-hazardous wastes.
CSMA will manage and dispose wastes following GIIP; for instance there is a
written procedure for the storage and handling of chemicals used for the
terminal operations, and a temporary hazardous waste storage area with
secondary containment. Liquid wastes generated by ships (i.e. bilge waste,
ballast water, sewage, and used oils) will be managed by contractors directly
hired by APIMAN, and it will be performed in compliance with MARPOL 73/38 Annex
V guidelines.
Management of Hazardous Materials (Hazmat): Handling and storage of hazmat is
expected to be minimal and only a minor fraction of the total cargo handled
will be considered hazardous. The container terminal’s layout includes an
appropriately designed section for dangerous cargo as well as an area to
isolate any hazmat containing cargo that may be damaged or leaking. CMSA has
developed clear procedures for the storage, handling, and final disposal of
hazmat in compliance with its globally applied practices.
Resource Efficiency and Green House Gas Emissions: Because of the nature of the
container terminal, resource utilization is limited primarily to the use of
gasoline and diesel for the surface transport of containers to and from the
intermodal yard and electricity to run the ship-to-shore cranes (STS) and the
rubber-tired gantries (RTG). The project will only use water for sanitary
purposes and washing deck areas. All equipment installed is state-of-the-art,
and appropriate for the intended use and efficiency.
The primary direct sources of GHG emissions are the RTGs, and the tractors used
to move the cargo containers to and from the intermodal yard. The cranes and
gantries have electric motors which get their electricity from the grid. The
tractors will use either gasoline or diesel fuel. CMSA has committed to
calculate direct emissions of GHG from its terminal operations.
In addition it is important to note that location of the new container terminal
at the existing port of Manzanillo increases overall efficiency by providing
for the joint use of a number of facilities including port area, emergency
response, and other functions.

The project is located within an existing Port Complex, where nearby
communities have coexisted with port activities for many years. There are a
small number of artisanal fishers who have also coexisted with port marine
traffic for over 40 years. Even though their presence within the port’s water
rights is prohibited, they can be occasionally seen to illegally fish in
restricted zones. However, no accidents with fishers are reported and they have
learned to navigate outside ship navigation routes and roadstead.
In the environmental and social impacts assessment for the port expansion,
APIMAN identified the expected increase in truck and rail traffic resulting
from the expansion program’s throughput of cargo containers as the most
significant risk to surrounding communities’ safety. As a result of this
assessment, modifications to the existing road and railroad access to the
terminal were made to effectively separate port traffic from the surrounding
community, mostly via road elevations and by-passes.
Because of the nature of the container terminal, and safety and security
policies of the overall Port Complex, access is restricted only to those
individuals with specific business relations to the port, and these are
typically mostly restricted to administrative office buildings. Drivers of
trucks delivering and picking up cargo must comply with safety requirements
while in the intermodal facility, and follow a pre-established and well
signaled traffic flow routes.
As stated above, CMSA has an EPR plan and a small emergency operations center
dedicated only to Project employees and terminal visitors. However, this
emergency operations center, does contribute with community vaccination
campaigns promoted by the public health department.
Security: Security of the overall port is the responsibility of APIMAN.
However, CMSA does have an internal port security team responsible for the
security of the container terminal, which is composed of one manager and one
supervisor per shift. As in all ICTSI terminals globally, CMSA is certified
under the International Ships and Port Facilities Security (ISPS) Code to avoid
and control any illicit activity or terrorist act involving international
ships. Such acts include piracy, armed attacks, terrorism, sabotage (alteration
or stealing of cargo), contraband and/or people’s trafficking. CMSA has been
certified as Level I ISPS Code, which includes installation of an access
control system, electronic personnel identifications and guard patrols,
internal cameras and TV 24/7 surveillance, and specific security rules between
terminal port and ships. CMSA has gone beyond the standard required by the ISPS
code implementing biometric access control, body and baggage scanning systems
as most modern ports around the world.

Overall impacts to biodiversity were minimized through locating the new
container terminal within an existing port facility, where the coastal natural
habitat had been greatly modified by urbanization of the City of Manzanillo,
widespread of industrial, touristic and other economic activities typical of
any urban setting, as well as all the supporting infrastructure, dredging and
civil works associated with a port complex operation and continuous expansion.
The Project is not located near any legally protected area. There is only one
natural protected area in the state of Colima, namely the estuary Laguna de
Cuyutlán, which contains approximately 270 ha of natural mangrove forest and is
a designated RAMSAR site. The nearest point of this protected area is located 3
kilometers from the Project site.
Biodiversity impacts associated with dredging activities typically result in
short term impacts to benthic fauna and fish species. Benthic invertebrates
recolonize dredged habitats relatively quickly and fish species return to
impacted areas once dredging activities are completed.
Mangrove Forest: Following the initial construction of the Manzanillo Port over
40 years ago and the consequent widening the opening of the natural access to
the ocean, the project site was colonized with mangrove forest as a result of
salt water infiltration into what originally was freshwater lagoon.
Mangroves are protected under Mexican Law – NOM-022-SEMARNAT-2003, and can only
be removed under very exceptional cases and upon the approval of the
environmental authorities of a detailed compensation program.
Therefore, even though the mangrove forest at the site was the result of
secondary colonization over a modified habitat, during the initial ESIA
performed by APIMAN, the environmental authorities required a detailed
assessment and compensation (offset) program – Estudio Tecnico Justificativio:
Cambio de Uso de Suelo en Terreno Forestal (2004). Extensive baseline studies
were performed as part of this assessment, and the license was granted with the
condition that APIMAN had to compensate any removal of mangrove forest in a 1:3
ratio. The agreement with SEMARNAT at the time of the licensing process was
that APIMAN would -in a 10-year period - re-plant a total of 75 ha of new
mangrove forest, along pre-selected sites which included the estuaries of
Laguna Valle de Las Garzas, Laguna San Pedrito and the protected estuary of
Laguna de Cuyutlán.
Once APIMAN granted the concession to ICTSI for the construction and operation
of CSMA, best efforts were used to avoid any unnecessary clearance of mangrove
forest. Therefore, even though the APIMAN license assumed that 25 ha would need
to be cleared and thus the 75 ha compensation program agreed with SEMARNAT, in
reality only 15.7 ha of mangrove where actually cleared for the Project.
Loss of mangrove habitat is being replaced on a like-for–like basis through the
creation of 75 ha of mangrove habitat within the region. Over the last five
years, APIMAN has developed and implemented a nursery with the three native
mangrove species, and re-planting and maintenance techniques that are proving
to yield up to 80% survival rates. APIMAN has already started to implement the
agreed mangrove compensation program. Up to the end of 2013 a total of 10.3 ha
of mangrove had been already restored in the Laguna Valle de Las Garzas and
Laguna San Pedrito.
CMSA will coordinate and monitor APIMAN’s efforts towards completing the
mangrove compensation program. As a requirement for IFC financing, CMSA is
committed to assure that at least the 47.1 ha required to mitigate on a 1:3
ratio the loss of 15.7 ha of mangrove habitat resulting from the Project are
successfully restored. Furthermore, IFC has agreed with CMSA on a financial
mechanism that will kick-in in the eventuality that APIMAN is unable to
complete the restoration of at least the remaining 36.8 ha required to achieve
compensation for the 15.7 ha cleared by the Project. CMSA will provide annual
progress reports to the IFC.
The baseline study concentrated in the mangrove forest, and failed to
characterize the estuarine aquatic ecosystem. Therefore, in order to establish
a better baseline for important fish and invertebrate species in the estuary,
as a requirement to IFC’s investment, CMSA will implement an aquatic fish and
invertebrate survey program to better characterize and monitor the aquatic
ecology of Laguna Valle de Las Garzas and the remaining mangrove areas in the
harbour.

The Port Complex is sited within Manzanillo City, and thus immerse in an urban setting. The closest neighborhood to CMSA is Las Brisas, which is located 300 meters to the west, between the terminal site and the open ocean. APIMAN is responsible for all stakeholder engagement and public disclosure for all activities associated with the port, and thus terminal operators such as CMSA have no formal mechanism or a visible function to interact with affected communities.
Stakeholder analysis, engagement and planning, and all the consultation process associated with the ESIA was conducted by APIMAN. In August 25, 2004 a formal ESIA consultation meeting took place with the participation of approximately 40 people, representing environmental NGOs, neighboring communities, the municipal and local governments, schools and universities. There were a total of 51 inquiries. The principal concern of the environmental NGOs related to technical viability and financial sustainability of the mangrove compensation program, who presented concrete proposals to formalize Laguna de Las Garzas as a legally protected area and the creation of a financial instrument for its administration and support. The main concern of local communities and local governments were related to congestion of supporting infrastructure, and potential increase in accidents, noise, and other nuisances related to construction and increase road traffic. During this meeting, APIMAN representatives presented the proposed mitigation measures to handle these concerns, and incorporated relevant suggestions. As Manzanillo has been a port city for many years, the surrounding communities are historically and culturally interlinked to port operations. There is broad support from affected communities and stakeholders for the construction of the port, and the formal consultation process confirmed that none of the participating individual or group opposed the construction of the project. Throughout construction there was no reported or known opposition to the project, except the complaint related to noise and visual impact from La Brisas communities which resolution, as noted above, was agreed to the satisfaction of the affected parties.
Grievance Mechanism: APIMAN has a formal Grievances Mechanism that is known and available to the surrounding neighborhoods. APIMAN is the intermediary through which all communication with port leaseholders is conducted. According to APIMAN, monthly meetings are held with the port leaseholders to discuss community issues / complaints. CMSA closely coordinates with APIMAN to effectively respond to community grievances associated to its operations. In case of any grievance APIMAN notifies CMSA by official letter and CMSA has to respond in the same way, then APIMAN answer to the community. All the communications with the community are managed through APIMAN.

Claudio Mustico
Director de Tecnología y Seguridad Portuaria
IT & HSSE Director
CONTECON MANZANILLO SA de CV
An ICTSI Group Company
E-Mail mailto:cmustico@contecon.mx
Tel / Pho: +52 (314) 3315595

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
CMSA will design and implement an Integrated Quality, Environmental, Health and Safety and Security for the supply chain (QEHSMS) management unit, and deploy a full environmental, and occupational health and safety team. This QEHSMS will include an external communication and grievance procedure, laying out how to manage third party enquires or complains	02/28/2015
CMSA will develop a written HR policy in alignment with the Mexican requirements and IFC PS2, including specific non-discriminatory policies and the development of an accessible and well-advertised internal grievance mechanism that includes opportunities for anonymous feedback, assures no retaliation, and provides accountability for the resolution of grievances	10/30/2014
CMSA will prepare appropriate health and safety plans and procedures to comply with in-country requirements and consistent with good international industry practices (GIIPs) as those reflected in the World Bank Group’s EHS Guidelines	10/30/2014
CMSA and the Lenders will implement a financial mechanism to assure there is enough resources to compensate for any unmitigated mangrove loss, in the eventuality that APIMAN is unable to complete the restoration of at least the remaining 36.8 ha required to achieve compensation for the 15.7 ha cleared by the Project.	01/30/2015
CMSA will implement an aquatic fish and invertebrate survey program to better characterize and monitor the aquatic ecology of Laguna Valle de Las Garzas and the remaining mangrove areas in the harbour in order to establish a better baseline for important fish and invertebrate species in the estuary	03/31/2015