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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

While all Performance Standards (“PS”) are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with PS 1-4 and PS6. IFC’s due diligence did not identify project issues related to matters covered by PS5: Land Acquisition and Involuntary Resettlement; PS7: Indigenous People and PS8: Cultural Heritage for the following reasons: land plots leased/ acquired on a willing seller-willing buyer principle were already cultivated for decades; the transaction did not involve involuntary resettlement and/or economic displacement. Further development/ expansion of the complexes near the towns of Ladyzhyn and Katerynopil in Ukraine will be done within the footprint of existing facilities; no conversion of natural habitats has taken place; there is no presence of Indigenous Peoples or known cultural artifacts. In the event that issues anticipated by PS 5, 7-8 arise, the Company will engage with IFC to ensure these are adequately addressed. Screening and assessment of the potential impacts and risks will be done through the corporate and each plant’s existing and/or planned environmental and social management system (ESMS). The proposed investment is expected to have limited environmental and social impacts. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Therefore, this is a Category B project according to IFC’s Environmental and Social Sustainability Policy.

Key E&S risks and impacts associated with the Project include: i) the capacity of the corporate E&S management system to identify, assess and manage risks and impacts; ii) labor and working conditions including occupational health and safety (“OHS”); iii) air emissions; iv) waste and wastewater management; and v) social impacts on nearby communities. The Company has presented plans to address E&S risks and impacts to ensure that the Project will comply with the environmental and social requirements of host countries’ laws and regulations, IFC’s Performance Standards, and the World Bank Group EHS Guidelines. The information about how these impacts and risks are addressed by the Project is summarized in the paragraphs that follow.

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.

Environmental and Social Assessment, Identification of Risks and Impacts



MHP enforces Ukrainian legal requirements to carry out an environmental impact assessment (EIA) studies for all new developments and greenfield projects and evaluate potential negative environmental and social impacts followed by development of the corrective actions prescribed by authorities to avoid, mitigate or compensate identified adverse impacts. Specifically, the Company has finished EIA studies for the new facilities including Vinnytsia poultry complex located near the town of Ladyzhyn, Ukraine. Additionally, MHP has enhanced the E&S management plans for the operational phase of the existing Vinnytsia poultry complex to ensure consistency with IFC PSs and sector specific World Bank Group (WBG) Environment, Health and Safety (EHS) guidelines.



EIA studies for a soybean crushing plant being built within the existing facility’s land plot near the Town of Katerynopil are in progress. MHP will develop and provide to IFC environmental, social and occupational health and safety (“EHS”) management plans for the operational phase as per the ESAP. The plan will address requirements of Ukrainian authorities and the WBG/ IFC guidelines including emissions and effluent levels, waste management, environmental monitoring, and workplace monitoring.



In 2013, the Company developed and is now implementing a corporate procedure for early identification of potential E&S risks and impacts associated with leasing/ acquiring of new agricultural land for crop cultivation. Implementation of the procedure is delegated to the environmental specialists at the individual plants. Additionally, MHP adopted a corporate procedure for control of environmental and occupational health and safety (EHS) performance of contractors. Management of contractors’ EHS performance was improved through revision of the existing procurement/tender procedures for bidders and contracts with winning contractors by including specific environmental and occupational health and safety requirements; regular control of contractors EHS performance.



Policy and Management Programs



MHP developed and implemented an EHS policy in 2013. The policy is consistent with international standards on environmental management and IFC PSs. It provides a framework for the environmental and social assessment and management process. Further, MHP commitments related to environmental protection are disclosed on its website

http://www.mhp.com.ua/en/responsibility/environmental-protection

Animal welfare policy consistent with the European Union Directives 98/58/EU и 2007/43/EU is being finalized and adopted. MHP commitments on animal welfare focused on raising animals and minimizing negative effect at slaughter are published on its website:

http://www.mhp.com.ua/en/responsibility/animal-welfare



Management programs and plans of the individual production sites are based on policy, commitments, and findings of internal enviro
nmental audits and authorities’ inspections. Plans are developed or updated annually. Moreover, the Company adopted corporate plans and programs for environmental protection, reduction of greenhouse gas emissions, pesticide and fertilizer use, waste management. In 2013 MHP developed a program for gradual implementation of the EHS management systems consistent with ISO 14001 and OHSAS 18001 at the individual production sites being implemented. A timeframe for establishment of the EHS management systems will be provided to IFC according to the attached ESAP.



More than half of individual sites have obtained different combination of ISO 9001, ISO 22000, Global G.A.P., HACCP (Hazard Analysis and Critical Control Points) food safety certificates.



Organizational capacity, competency and training



EHS matters at each individual facility are coordinated by the respective EHS departments/services and plant-level managers as part of their direct responsibilities. The environmental management system and occupational health and safety (OHS) management system are developed and implemented separately by the chief ecologist and the OHS manager correspondingly. The Company has improved and formalized its corporate organizational structure - overall responsibility and authority for MHP EHS matters is delegated to the First Deputy CEO.



Specific EHS courses required by local regulations are systematically delivered. MHP has intended to enhance competency of key staff responsible for regular management of the EHS matters and will provide to IFC a schedule and plan for further training on ISO 14001 and OHSAS 18001 in the reliable training centres/ consulting companies satisfactory to IFC.



Professional training, staff selection procedures and support of students facilitate retention of competent personnel and continuous professional development.



Emergency Preparedness and Response



Emergency response plans (ERRs) appropriate to specific potential risks including life and fire safety are documented and maintained in accordance with local laws at each individual plant. ERRs are, typically, combination of procedures for using, inspecting, and maintaining emergency response equipment; notification of the public and emergency response agencies; training programs. Plans cover communication with local authorities and municipal rescue services in line with legal requirements.



The visited silos in Ladyzhyn including the sunflower crushing plant are equipped with dust suppression systems where appropriate; explosion safety devices; life and fire (L&FS) means including fire alarm systems, fire hoses, fire extinguishers and detached fire water tanks. Ammonia refrigeration system installed at the meat processing plant has undergone multistage inspections and approvals by relevant supervisory authorities. MHP EHS specialist located in Voronezh, Russia, inspected silos and mechanical workshops on a regular basis including status of gas cleaning equipment an
d aspiration systems for the vertical concrete silos. Lightning protection, electrical equipment and systems were improved according to inspection findings. MHP will conduct an explosion risk assessment, as per ESAP, in its vertical concrete silos in Russia by its own professional staff or a third party expert, both being acceptable by IFC to identify high/ moderate/ low risk areas of dust generation and provide to IFC a copy of the assessment and a corrective plan to ensure that mitigation measures including installation/ renovation of the aspiration systems, production equipment overhaul/ refitting, static electrical discharge, dust monitoring, all electrical equipment including electrical panels are dust proof, procedures for and implementations such as periodical cleaning are in place.



Monitoring and reporting



MHP conducted comprehensive internal environmental due diligence of its individual operations in 2010 and continue annual audits of selected facilities depending on their performance. Facilities were audited including availability of relevant permits and licenses, E&S performance, implementation of local authorities’ prescriptions and management system status. Adopted in 2013, a procedure for senior management review of EHS performance establishes review meetings of internal EHS reports on a quarterly basis. As spelled out in the ESAP, MHP will update its internal reporting system, develop formats for EHS reports approved by MHP senior management and provide the report templates that will bring qualitative and quantitative performance indicators including those listed below to IFC:

(1) Sustainability: energy use per unit (kWh/ton processed or Wh/ bird/ day); water consumption per unit (m3/ton processed or liters/ bird place/ year); carbon footprint (CO2 emitted /tons produced);

(2) Safety: Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days (Number of Days since last Lost Time Incident); Number of fatalities and first priority actions to undertake;

(3) Environment: air emissions of NOx, SO2, particulate matter for combustion facilities for different type of fuels; frequency of tests of air emissions and ambient air (dust, odour, noise) at the edge of the nearest residential areas; waste generation per unit (kg/ton processed or g/head); tests and limits of effluent levels; compliance with the local and the WBG/ IFC thresholds; number of independent EHS audits conducted/ year; key findings of independent EHS audits;

(4) Social: grievances from stakeholders received and topics to address; grievances from employees received and topics to address; number of the lawsuit related to labor and work conditions; retention and number of training days provided to new and existing employees.



The external reporting is carried out in accordance with local legal EHS requirements. Reporting to IFC on continuous improvement of E&S performance and the EHS management system will be pr
ovided within the context of the Annual Monitoring Reports (AMR).



Stakeholder Engagement:



The Company maintains various social projects through support and finance contributions to economic vulnerable groups, institutions that care for orphans, children, veterans and religious institutions to address immediate social and economic problems and improve the infrastructure within rural districts where MHP operates. MHP developed and implements a grievance mechanism to receive and respond communities’ concerns. Going further, in 2013, the Company enhanced its external communications with affected communities and developed a comprehensive stakeholder engagement plan (SEP) supporting an ongoing process for stakeholder engagement. The SEP consistent with PS1 provisions and good international practices is based on detailed stakeholder analysis including affected local communities and non-governmental organizations. The plan includes various forms of disclosure and dissemination of information; plans for consultation and participation, and regular reporting on EHS matters.

Human resources policies and procedures, terms of employment, non-discrimination and equal opportunity



MHP employs around 30,000 staff as of end 2013. Generally the human resources (HR) practices implemented by MHP are commensurate with this Performance Standard and local labor laws. The Company developed, updated recently the corporate human resources and enforces the implementation of the policy and regulations based on equal opportunities, non-discrimination principles, and worker rights to participate in professional associations and trade unions. Also, MHP offers to employees sustained and competitive payment; social benefits and discounts; employees came from other regions are given apartments to rent that may be transferred to their property after long-term work. In the town of Ladyzhyn MHP has been finishing construction of apartment buildings and a hostel for accommodation of employees from other regions of Ukraine. About 87% of workers and specialists employed by MHP live in the regions where MHP facilities operate.



Terms of employment including salary, working time, leave on maternity, illness and vacation, overtime payment, safe working conditions, promotion and bonuses are outlined in either the contract with employees or the internal regulations at the all MHP facilities. Collective agreements and regulations of individual operations define terms of employment through stipulation of employee and management rights and responsibilities. Upon appointment, personnel are provided initial induction training that facilitates employee’s familiarization and awareness of responsibilities, disciplinary requirements and rights, conditions of work and further OHS training.



Protecting the Work Force

Facilities enforce the implementation of labor laws consistent with host country labor laws. Individuals below the age of 18 years are not employed and no forced labor is used. Corporate personnel departments at the HQ and individual facilities are responsible to review data provided by potential candidates during the staff selection process.



Workers’ Organizations

Trade unions consolidate about ten percent of MHP employees. Collective bargaining agreements between the administration and workers provide for detailed and, in some cases, additional terms and benefits for employees and their families. Facilities that do not have trade unions have developed and maintain procedures, policies or internal regulations establishing responsibilities and commitments of management and staff. The commitment of the Company to allow all employees to join unions is defined the updated corporate HR policy.



Grievance Mechanism

A corporate grievance mechanism procedure was developed and implemented in 2010. This formal grievance process provides alternatives for employees to raise concerns other than to immediate supervisors and allows grievances to be presented without the risk of oppression in line with IFC’s Performance Standard 2. Additional
ly, MHP requested its contractors to ensure that workers have access to a grievance mechanism.



Occupational Health and Safety (OHS)



Responsibilities for day-to-day coordination of OHS matters are delegated to OHS specialists of the individual facilities. The individual facilities deliver OHS training required by local authorities. Lost time injuries are registered, investigated and reported to the corporate and facility’s management as well as relevant authorities.



There are monitoring programs of workplace conditions and scheduled monitoring of workplaces undertaken by supervisory authorities or authorized agencies. Specific mitigation measures are implemented, including supply of personal protective equipment (PPE) against physical (noise, dust) and chemical hazards (pesticides, disinfecting agents, antibiotic products), including biological security measures, where applicable. The Company provides, and requires the use of proper hygienic conditions, including shower cabins, working cloths and shoes, disinfection, and controls that these requirements are enforced. Also, the Company has mandatory life and fire safety and occupational health and safety training for its employees. Field staff that have direct contact with the crop production products was given specific training in specialized training centers and internally.



The Company undertakes employee medical examinations at the time of employment and, after that, repeats the health examinations according to a regular schedule based on the specific working conditions under which employees operate. MHP revised medical tests for workers handling crop protection products, adopted a policy for workers rotation to avoid chronic exposures to specific pesticides, and implemented quarterly registration of workers handling pesticides to ensure proper training, health examination and rotation, if needed, are in place.



All the lost time injury and fatality cases have been investigated with corrective actions defined to prevent reoccurrence. MHP will develop a program consisting of organizational and investment actions including immediate measures based on the outcomes of investigations and further diagnostic measures including thorough due diligence of OHS performance, hazard identification and risk assessment by an independent professionals acceptable to IFC at the selected facilities. As stipulated in the ESAP, the program for further improvement of occupational safety and health is a condition of disbursement.

Resource and Energy Efficiency



MHP undertakes continuous efforts to promote pollution prevention and energy efficiency systems and is fully committed to continue work towards efficiency of energy and water consumption as well as resources / material inputs. The Company continues work on conducting the basic assessment - benchmarking of water and energy efficiency at the selected production facilities. If this initial assessment identifies any potential for improvements a plan for implementation of resource efficiency measures will be developed. An initiative on wider use of alternative energy sources is in progress. Construction of the biogas facility at Oril-Leader poultry farm in Dnipropetrovsk region was finished. The co-generation plant of 5 MW capacity will process about 50,000 tons/year of chicken manure and about 146,000 tons/year of waste water and produce electrical and heat energy. At the Mironivsky feed mill, waste sunflower husk is burned for energy production sufficient to cover the demand in steam generation and heating of premises of the sunflower crushing plant; ash is used as mineral fertilizer on MHP own fields. Mironivsky chicken farms and the slaughterhouse also have the most technologically advanced and energy saving equipment supplied from leading European producers; vast majority of operations are fully automated. Moreover, individual facilities implement ongoing projects including closed water cycle at poultry processing operations; installation of nipple-shaped water supply systems at rearing sites; energy saving devices; heat recovery systems at meat processing and meal production operations; heat insulation of premises, production and auxiliary equipment and others.



Power for local operations is sourced from public grid. Water is supplied from own water wells or from mains of the nearest settlements. Physical, chemical and microbiological water quality is monitored regularly at each individual site by the MHP’s laboratories. It is supported by monitoring undertaken by local authorities.



Greenhouse gas emissions



MHP quantifies emissions of greenhouse gases (GHGs) in line with the local regulations and internationally recognized methodologies annually. Direct emissions from agribusiness operations, fuels consumed during stationary combustion and in mobile vehicles consumption; and indirect greenhouse gas emissions from electricity consumption accounted approximately 800,000 tons of carbon dioxide (CO2 eq.) in 2013.



Air Emissions



Silos and the sunflower crushing plant visited in the Vinnytsia region are equipped with dust suppression and aspiration systems, where appropriate. The rendering plant at the Mironivsky poultry processing plant is equipped with gas emissions abatement equipment. The similar abatement system is installed at the new facilities in Ladyzhyn. Monitoring of point source air emissions and control of its compliance with national limits are in place. Air emissions from boilers meet
local and are below the WBG limits.



Wastewater treatment



The principal sources of wastewater from MHP operations are poultry processing plants. Slaughterhouses have typical on-site wastewater treatment that includes mechanical treatment by flotation and biological treatment at aeration tanks; poultry farms with smaller slaughterhouses discharge wastewaters to the municipal mains after primary screening. Treated effluents are discharged to either municipal mains or to disposal/receiving ponds.



The most advanced technologies installed at the on-site wastewater treatment plants (WWTP) of Myronivska and Vinnytsia chicken facilities employ separation from grease and floatable solids, anaerobic and aerobic processes and mechanical treatment. Finally, liquid effluents are disinfected at the ultraviolet unit and discharged at the rivers. Vinnytsia WWTP receives wastewaters from poultry breading/rearing farms, the slaughterhouse and the meat processing plant.



Wastewaters generated by poultry breading/rearing farms with high concentrations of organics are delivered to mechanical separation; liquid effluents are discharged to receiving ponds; sludge is delivered to sedimentation ponds. After a period of settling (natural biological aeration), it is used as field fertilizer.



Monitoring covers analysis of liquid effluents from poultry farms, meet processing plants and slaughterhouses. It is supported by inspections undertaken by authorities. Wastewater treatment systems of individual sites are audited as part of the corporate audit program. Quality of liquid effluents meets strict national standards and the World Bank/ IFC effluents guidelines for poultry and meat production and processing.



Waste management



The Company has formalized and implements the corporate waste management programs/ plans for core businesses, including grain handling; poultry production and processing operations. Programs’ development was based on the outcomes of inventory of waste sources and types; it includes, inter alia, methods for collection and temporary on-site storage of biological wastes prior to appropriate disposal; proper monitoring of finished compost composition to ensure it is uncontaminated; management responsibilities and staff training programs.



The bulk of solid waste is generated by poultry farms. To minimize waste generation, individual sites maintain low water content in organic manure through scraping wastes. Waste is collected and composted and then distributed for use as fertilizer on MHP agricultural fields.



Mironivsky and Vinnytsia facilities employ advanced technologies for recycling of biological waste from the slaughterhouse and poultry farms. Waste processing/ rendering facilities are located remotely from others in a stand-alone buildings and combine digesters where different types of waste are treated with heat and/or solvents to promote deep decomposition. The rendering facility of Vinnytsia poultry complex is designed
to produce meals from waste streams generated by hatchery, rearing sites, the slaughterhouse and the poultry processing plant. Some chicken farms maintain biothermal composting pit (Bekkari pit) constructed of moisture- and thermo-resistant material with a hermetic cover and a ventilation system. Odourless and sterilized compost is used as fertilizer. Livestock litter is collected, composted and used either as fertilizer at own fields or sold to farmers.



Pesticide Use and Management:



MHP developed a pesticide management plan in 2012 which covered pesticide handling, application and storage, staff training, safety requirements, and disposal. In 2013 the Company adopted a policy statement to commit MHP to avoid use of WHO Class Ia and Ib chemical formulations in its operations. MHP formalizes procedures to ensure implementation of this policy. Specifically, in relation to pesticide use and management, MHP implements integrated pest/disease management (IPM/IDM) programs consistent in general with the PS3 and the WBG guidelines. The IPM/IDM programs include crop management practices, insect/disease monitoring, pest/disease ecology, biological control, and other control components, and, as a last resort, pesticide chemical formulations to avoid unacceptable economical levels of pest or disease damage. MHP has agreed to update its policy and procedures to meet PS3 Edition 2012 on avoiding use of products that fall in WHO Recommended Classification of Pesticides by Class II (moderately hazardous). As set forth in the ESAP, MHP will inventory class II pesticides and provide to IFC a report on outcomes of inventory, available controls on use of these chemicals including proper training, equipment, and facilities to handle store, apply and dispose, and, if needed, corrective actions to reduce application of Class II chemical formulation in its operations.

MHP operates a total vehicle fleet of 490 lorries; to improve transport safety and prevent transport collisions MHP developed in 2013 a transport safety policy and supported procedures.



Some individual sites, such as Starinska, Mironivsky chicken farms, Katerinopolsky grain silo in Ukraine and silos in Russia are located in the vicinity of settlements. Reportedly, buffer zones of facilities in Ukraine are in compliance with national laws and regulations. Russian regulations prohibit permanent and/or long-term residence of people within the buffer zones to avoid risks to their health due the potential for exposure to substandard ambient air quality. There are permanent or seasonal residents within the existing buffer zones of silos in Voronezh region, Russia. As spelled out in the ESAP, MHP will arrange ambient air quality monitoring of the nearest houses to identify actual impacts from dust and noise generated by the facilities in full operation. A copy of the monitoring report will be provided to IFC together with a correction plan, if needed, that will include organizational and capital investment measures for minimizing/ avoiding of negative impacts to nearby communities.



Emergency response plans appropriate to specific potential risks, including life and fire safety, are developed in accordance with national laws. Risks associated with spraying of pesticides and fertilizer application are addressed through selection of weather conditions and application techniques of fertilizers in the soil surface. As mentioned above, the Company applies certified pesticides and chemicals approved for application by local authorities; all warehouses for chemicals storage are licensed and approved for operation by supervision authorities.



Sanitation and disinfection procedures are in place and their use is systematically enforced at all MHP poultry rearing units. Biosafety procedures include limited controlled site access and suitable infrastructure (e.g. fences); entrance gate with vehicle disinfection area, cleaning and disinfection procedures for visitors, materials and tools (e.g. foot disinfection at the entrance to sites/houses), control of pathogen vectors (rodents, insects), and organic waste management. As part of its biosafety procedures, any sick or dead bird is removed and reported to the veterinarian. Breeders and broilers housing systems allow animals to engage in natural behaviors. Three facilities were certified by EU Commission in 2013; first deliveries to EU market started in 2013. Chicken housing at the Mironivska and Vinnytsia facilities is in line with Directive 2007/43 EU.



Well-maintained bedding, feed and water availability, disease control, adequate temperature, ventilation, and humidity are key parameters which are closely monitored. Broiler chickens are controlled against diseases. Only certified providers and approved antibiotics are applied. This approach will be expanded to the new facilities.



Additionally, MHP
controls potential risks to community health and safety from ingestion of drug (such as growth hormones) and pesticide residues. The Company monitors drug residues in pork meat and milk that meet maximum residue limits for veterinary drugs and pesticide recommended by the World Health Organization (WHO) and Food and Agriculture Organization of the United Nations (FAO).



Security Personnel. The Company employs either contracted from private companies or its own security personnel. In both cases security guards are unarmed, trained and certified as per the local regulatory requirements.

Ukrainian legislation has been recently revised to require a “crop rotation scheme” to be approved by local authorities. MHP is using biological methods for pest control recommended by local authorities and no alien species are introduced. Ukraine banned used of GMO thus, MHP is not using genetically modified seeds for crop production.

The corporate community engagement plan including mechanisms for communicating environmental and social aspects of current operations to local communities and procedures for receiving, documenting and responding to concerns from any external interested parties was developed and implemented. Grievance mechanisms include various ways for receiving concerns and grievances from stakeholders and communities including a website link and direct communications with responsible managers of the individual facilities.

E&S information on new developments is available for communities for consultations as part of the EIA undertaken for such projects.

For more information, inquiries and comment about the Project please contact:
Mrs. Anastasiya Sobotyuk
Head of IR and Communications
Tel: +38 050 339 29 99
Email: mailto:a.sobotyuk@mhp.com.ua
Website: http://www.mhp.com.ua
Address: 158, Ak.Zabolotnogo St, Kyiv, 03143, UKRAINE

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Develop and provide to IFC environmental, social and occupational health and safety management plans for the operational phase of Katerynopil soybean crushing plant. The plans shall address requirements of Ukrainian authorities and the WBG guidelines including emissions and effluent levels, waste management, environmental monitoring, and workplace monitoring	11/30/2014 12:00:00 AM	In Progress	Under discussion with IFC client
Develop schedule and plan for further training on ISO 14001 and OHSAS 18001 of key staff responsible for regular management of the EHS matters in the reliable training centers/ consulting companies satisfactory to IFC	11/30/2014 12:00:00 AM	In Progress	Under discussion with IFC client
Complete training on ISO 14001 and OHSAS 18001 of key staff responsible for regular management of the EHS matters in the reliable training centers/ consulting companies satisfactory to IFC	3/31/2015	In Progress	In Progress
Conduct an explosion risk assessment in vertical concrete silos in Russia by MHP’s own professional staff or a third party expert, both being acceptable by IFC, to identify high/ moderate/ low risk areas of dust generation and develop a corrective action plan to ensure that mitigation measures including installation/ renovation of the aspiration systems, production equipment overhaul/ refitting, static electrical discharge, dust monitoring, all electrical equipment including electrical panels are dust proof, procedures for periodical cleaning and measures to ensure their implementations	2/28/2015	In Progress	In Progress
Update MHP internal reporting system, develop formats for EHS reports approved by MHP senior management; report templates shall include, but not limited to, the indicators listed below: (1) Safety: Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days (Number of Days since last Lost Time Incident); Number of fatalities and first priority actions to undertake; (2) Sustainability: energy use per unit (kWh/ton processed or Wh/ bird/ day); water consumption per unit (m3/ton processed or liters/ bird place/ year); carbon footprint (CO2 emitted /tons produced); (3) Environment: air emissions of NOx, SO2, particulate matter for combustion facilities for different type of fuels; frequency of tests of air emissions and ambient air (dust, odour, noise) at the edge of the nearest residential areas; waste generation per unit (kg/ton processed or g/head); tests and limits of effluent levels; compliance with the local and the WBG/ IFC thresholds; number of independent EHS audits conducted/ year; key findings of independent EHS audits; (4) Social: grievances from stakeholders received and topics to address; grievances from employees received and topics to address; number of the lawsuit related to labor and work conditions; retention and number of training days provided to new and existing employees	2/28/2015	In Progress	In Progress
To improve MHP occupational health and safety (OHS) performance develop a program consisting of organizational and investment actions including immediate measures based on the outcomes of existing investigations and further diagnostic measures including thorough due diligence of OHS performance, hazard identification and risk assessment by an independent professionals acceptable to IFC at the selected facilities	08/30/2014 12:00:00 AM	Completed	Completed	09/04/2014 12:00:00 AM
Inventory class II pesticides and provide to IFC a report on outcomes of inventory, available controls on use of these chemicals including proper training, equipment, and facilities to handle store, apply and dispose, and, if needed, corrective actions to reduce/ phase out application of class II chemical formulation	4/30/2015	In Progress	In Progress
Arrange ambient air quality monitoring of the nearest houses to identify actual impacts from dust and noise generated by silos in Russia while in full operation and develop a corrective plan, if needed, that shall include organizational and capital investment measures for minimizing/ avoiding of negative impacts to nearby communities	11/30/2015	In Progress	In Progress