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

This is a Category B project under IFC’s Policy on Social and Environmental Sustainability. The environmental and social (E&S) impacts and risks associated with the proposed activities will be local in nature and inherent to the production and processing of cage aquaculture. Findings from the appraisal indicate that these risks and impacts can be avoided or mitigated by adhering to established aquaculture industry practices and standards and complying with applicable Mexican laws and regulations, IFC’s Performance Standards and WBG’s EHS guidelines. Available information indicates that the Company has thus far demonstrated material compliance with applicable Mexican legal and regulatory requirements on environmental matters. The project will have a significant positive impact in the local economy through the generation of at least 1,000 direct jobs over the next 2 years. Income generation, and introduction of new skills, will assist in diversifying and expanding the economy of Chiapas and improving rural livelihoods.
Land acquisition for the project will be limited to the purchase of one land hold of 4 hectares (ha), acquired on a ‘willing buyer – willing seller’ basis. The land is adjacent to Lake Malpaso, the site of fishery expansion, and will be used for the construction of a warehouse, administrative buildings and logistics facilities for fishery operations. Based on the information collected, PS5 - Land Acquisition and Involuntary Resettlement is not applicable. The Environmental Impact Assessment (EIA) for the proposed expansion next to Lake Malpaso did not identify any Indigenous Reserves or settlements in areas proximate to the lake. Although there are Indigenous People living in the Region, no impacts related to PS 7- Indigenous Peoples are anticipated. Similarly, no risks or impacts to cultural heritage were identified during appraisal exempting application of PS8 - Cultural Heritage.

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.

The Company has undergone rapid expansion of its fish rearing and outgrowing programs which have been now complemented with the completion of a state-of-the-art fish processing and cold chain facility. ADL has also recently completed the construction phase of a rendering and wastewater management facility to manage waste streams from hatchery and processing plant operations. The Company purchases all its vegetable feed from several local commercial suppliers and only uses contractors for transportation of product and employees. Key E&S risks associated with this investment are related with sustainably managing production practices in a finite watershed and developing and retaining a skilled workforce in a rural area. The appraisal team included an aquaculture specialist who reviewed all technical production parameters. The team determined that the proposed production increases are consistent with the overall carrying capacity of Lake Malpaso and that the water monitoring systems for out-growing were sufficient to adjust management practices to changes in flushing rates and temperature. The Company has assembled an experienced team of senior and mid-level managers which are committed to, and are very capable of, producing high quality fish products through sustainable practices under the proposed project.

Impact Assessment and Risk Management - The Company engaged an accredited consultancy to conduct environmental assessments of its hatchery and outgrowing operations in 2007-2009 and fish processing, rendering and wastewater treatment were reviewed in 2011. Each of the operations was reviewed in detail for both construction and operational phases and an Environmental Management Plan (EMP) was prepared for the management of each identified key risk, along with appropriate mitigation measures. The proposed expansion of the outgrowing operations to the second site (Malpaso) was assessed during 2012 and the amended EMP with mitigation measures was approved in May 2013. The EIAs and EMPs were sequentially submitted to and approved by Mexico’s Secretary for Environmental Protection and Natural Resources (SENMARTAS). Implementation of mitigation and management measures in the EMP will be monitored to ensure their effectiveness.

Management Policies and Programs – ADL has evident direction and management commitment for environmental and social sustainability. ADL’s parent company, Regal Springs, has been a leader in development of internationally-recognized practices and standards for aquaculture including the Aquaculture Stewardships Council’ (ASC) Tilapia Standard introduced in 2012. ASC-Tilapia includes seven Principles and 62 Criteria which are externally audited annually to ensure broad legal compliance, resource efficiency and biodiversity conservation, and use of globally-recognized social/labor practices. Regal Springs affiliated operations in Honduras and Indonesia operations were among the first to be certified to these standards and
ADL is currently undergoing its own certification assessment. Regal Springs maintains other internationally-recognized production systems, including Best Aquaculture Practices (BAP) used in the US and the Global Food Standards Initiative (GFSI) which is audited through the British Retail Council (BRC) standards. ADL has put in place virtually all of the preferred production practices and is quickly organizing these into working management systems. ADL’s food safety systems have already been approved by NSF Seafood (Surefish) and Costco’s supplier certification system. ADL will provide evidence of its certification to the ASC Tilapia Standard and will include the results of the ASC Surveillance Audits in its Annual Monitoring Reports. (ESAP 1.1.)

Organizational Capacity and Monitoring - ADL is currently in the process of revamping its institutional (business-wide) and environmental and social management procedures and systems to better coordinate and respond to material risks, impacts, and opportunities associated with the expansion of its operations. On the environmental and social front, an external consultant was selected to develop a strategy and corporate management system that readily identifies the key and material sustainability risks, stakeholders (in order of importance and relevance), and appropriate mitigation and management measures. Preliminary terms of reference were prepared and reviewed during appraisal. The strategy will adhere to best practice principles established by Centro Mexicano de Filantropia (CEMEFI), a locally recognized body in the field of corporate social responsibility in Mexico. The new strategy is expected to be ready by the end of 2013 and will focus on five main pillars: 1) corporate social responsibility; 2) quality of life; 3) ethics; 4) environment; and 5) community. Once developed, the external consultants will implement and embed the new system across the relevant parts of the business (e.g., HR, Production, etc.). Roll out of the new integrated management system will require working across all business groups and functions, undertaking training at all levels, and institutionalizing new policies and procedures on specific and cross-cutting environmental and social risk management issues. The new proposed corporate CSR strategy will integrate the main E&S considerations in this PS, thus ensuring there is a formal and systematic process for identifying, assessing, mitigating and managing environmental and social risks and impacts and for engaging and partnering with local communities. The new CSR strategy and management system will be monitored through key performance indicators (KPIs) and will be adjusted as needed through a continuous improvement process. (ESAP 1.2)

Stakeholder Analysis and Engagement Planning – Stakeholder engagement has thus far been appropriate to the complexities of the earlier stages of development but will need to be strengthened and formalized to meet the social risk and challen
ges in Malpaso. ADL currently manages stakeholder engagement and community relations through a dedicated team of two social specialists led by a Corporate Social Responsibility Manager. The team has been working together for a year and is responsible for establishing and maintaining good relations with local communities in and around the processing plant and the existing and future production sites in Lake Penitas and Malpaso respectively. The team has established good relations with the fishing cooperative in Lake Penitas and is in early stages of identifying relevant stakeholders in the area of Malpaso. ADL support to local communities includes the generation of local jobs (1,000 to date and an additional 1,000 jobs over the next 5 years), providing local school children with teachers, school supplies and lunches; through fishing cooperatives, provide fishermen with access to training, subsidized supplies and resources to improve their fishing practices, increase the productivity of their tilapia production, and fish stocks in the lake. This same level of support will be replicated and scaled up in the area of Malpaso. To meet this need, as set forth in the ESAP, ADL will prepare a combined Stakeholder Engagement and Community Relations Plan for the project. In alignment with IFC PS guidance, the Plan will identify stakeholders, determine their level of interest and influence in the project (by importance and relevance), establish appropriate methods for engaging with each group, and identify strategic and forward looking programs and activities to support and partner with affected communities. The objective of the Plan will be to strategically manage engagement and relations with project stakeholders and locally affected communities. (ESAP 1.3).

External Communications – ADL currently has an informal system to maintain its external communications. There was no system for communicating and responding to complaints, grievances, or customer satisfaction. The Company will develop a corporate procedure to implement and maintain external communications with the public in relation to environmental and social risks and impacts of the business. This will include a procedure for registering, assessing, and responding to external communication and adjusting the management program as appropriate as a means to ensure continuous improvement of the system. The procedure should be managed by the CSR team, in close coordination with management and other relevant groups of the business. (ESAP 1.4)

Grievance Mechanism for Affected Communities – The Stakeholder Engagement and Community Relations Plan will include a community grievance mechanism designed to receive and facilitate the resolution of project related concerns and grievances associated with the Company’s environmental and social performance. The GM will be readily accessible to project stakeholders and scaled to the risks and impacts of the project. Grievances will be resolved in a timely and cu
lturally-sensitive manner in alignment with IFC PS requirements. The GM will be reviewed annually for its effectiveness and modified accordingly. (ESAP 1.5)

Emergency Preparedness and Response - The Company has installed and tested emergency procedures at the hatchery and processing plant for seismic hazards. Chiapas State emergency management teams have verified requirements during the permitting stage and participated in a recent earthquake drill. Life and fire safety inspections are conducted semi-annually. The location of the plant is located at Amacohite on the Mezcalpa River flood plain which has experienced historic flooding in recent years. The closest hospital and substantial emergency response team is in Cardenas, roughly 50 kilometers from Amacohite. The aquaculture production areas on Lake Penitas and Lake Malpaso are in much more isolated and steeper areas some 50 to 100 km further upstream. Emergency management procedures for the lake operations have not been fully established and should be a priority given the vulnerability to tropical storms, landslides and seismic events. The risks associated with lake operations will be assessed and included in the 2014 Emergency Management Plan. (ESAP 1.6)

The main challenge for ADL will be to maintain a motivated and skilled workforce. While labor supply is not likely to be a risk, managing workforce issues and community expectations will be crucial to maintaining the business’ social license to operate. The businesses growth is dependent on a large workforce and thus will need to treat engagement and good relations with workers/communities as a priority. Appraisal confirmed that ADL understands these risks. The proposed Stakeholder Engagement and Community Relations plan required for the Project is expected to support and strengthen efforts in this area.

Human Resources Capacity - While a young business, ADL is managed by a small yet dedicated, committed, knowledgeable and experienced team of specialists focused on different aspects of the business. The main Group functions are Production, Financial, Processing, Quality, Human Resources (HR), and the Corporate Social Responsibility (CSR). The HR Department is comprised of a Human Development, Industrial Security and Operation level Managers (Hatchery, Penitas and Malpaso). The processing facilities have an in-house medical facility managed by a team comprising of a doctor and two nurses. The medical facility is responsible for providing workers with emergency medical care (e.g., accidents, etc.) and treating short, long, acute and chronic illnesses. ADL have their own ambulance and are equipped to undertake minor surgery within the premises. Medical staff must uphold and work in accordance to the Mexican code of medical ethics, whereby the doctor and patient relationship is treated as confidential. Additionally, HR and the medical staff deliver targeted seminars, speeches and screenings to workers on different medical issues of interest to both genders (e.g., breast cancer screening, talks on HIV/AIDS, drug and alcohol abuse, etc.).

Working Conditions and Management of Working Relationships - With state of the art tilapia processing and production facilities, ADL is a major employer in Chiapas and contributor to the economic growth and prosperity of the region. ADL currently employ 1,000 peoples with projections to create an additional 1,000 local jobs in the area (Amacoite, Penitas and Malpaso) by 2015. Workers enter into employment with ADL on a permanent basis. Employment for some jobs is subject to ability tests and all jobs require a full day of induction training. Workers have 8 hour schedules with regular and periodic breaks and time for meals. Performance targets and incentives are provided to workers depending on their role and job profile. Workers are provided with (among other things) good wages, up to three times higher than the legal minimum wage; free transport to work; free meals; leisure; job training; job related tools and personal protective equipment; and opportunities for career growth and development.

Human Resources Policies - Workers are supervised according to ADL’s comprehensive HR Manual which includes plans, proce
dures and provisions designed to ensure a fair, healthy, and safe workplace. The HR Manual is aligned to IFC’s PS on labor and working conditions (PS2). HR has a strict code of conduct and manages a grievance redress mechanism (GM) for all workers. The code of conduct and grievance mechanism is widely publicized to workers verbally, in posters and in HR notifications. The GM gives all workers the right to submit a concern, complaint or request (proposal) through a manager, directly through the HR Department or indirectly / anonymously in a drop box located next to HR and the canteen. The mechanism also allows workers to propose new initiatives or programs that could improve the general working conditions or wellbeing of workers. Proposals may include organizing sports clubs, increasing the number of potable water containers around the facility, etc. All grievances are formally recorded, answered and tracked/monitored directly by the HR Department, within a reasonable timeframe. ADL have a non-discrimination and equal opportunity policy and work with worker unions and organizations through their representatives. ADL does not employ workers under the age of 18.

Hiring Practices - ADL employs all workers and professional staff directly. The Company indicated that more than 90% of all employees were from the communities living in the direct area of influence of the hatchery, processing plant and production sites. Jobs are advertised and filled directly by ADL’s HR team who use different recruitment methods, including job fairs and coordination with the local heads’ of communities, to attract new talent. Socio-economically, the project area is characterized as rural, with low population density, comprised of peoples living in communal lands (ejidos) whose main economic activity is subsistence farming, cattle rearing and fishing. According to government sources the areas around Lake Malpaso, particularly on the southern coast, are in “high poverty” with very low employment (Consejo Nacional de Población, 2010).

Occupational Health and Safety - Occupational health and safety (OHS) risk and impact mitigation measures were identified in the EIA and EMP. ADL conducted a comprehensive OHS risk assessment of its operations in March 2013. At this time, it also began collecting and reporting on OHS matters. While OHS systems and procedures are still young and evolving, ADL has now developed a well-organized and operational OHS department. The team is headed by a medical doctor and an industrial hygienist who have conducted risk assessments of all primary work stations and identified primary mitigation measures and training requirements for each. Occupational safety requirements are outlined in employment agreements and detailed in a booklet (“Reglamento interno de suguridad e hygiene”) provided to each employment and trained in through during mandatory induction training and close on-site supervision. Emergency preparedness plans and training systems are
established and drills for fire and seismic events planned or ongoing. Egress to buildings appeared to be appropriate and fire detection and suppression systems were in place and monitored. Appropriate personal protection equipment (PPE) is routinely used across all operations. Signage identifying hazards was widespread, a lock-out tag-out system is in place for reducing risks from processing machinery, and Material Safety Data Sheet (MSDS) were readily available for all potentially dangerous chemicals used. Review of safety records indicated most accidents (60%) occur in primary processing operations (fileting and trimming) typical of the industry. Lost time injury frequency rates (LTIFR) and other OHS KPI’s are in early stages of being collected. Data collection and reporting is in the process of being improved but all of the safety requirements in the WB/IFC EHS General Guidelines were being addressed. Fluctuations in the type, location and severity of accidents also indicate the need to continue to more systematically analyze root causes and accelerate training programs where necessary. The Company will continue to work toward improving its internal OHS systems to permit more consistent and standardized analysis of OHS risks and events including near-misses. The Company will pursue establishment of an OHSAS 18001 program to improve its OHS effectiveness and reporting (ESAP Item 2.1).

Resource Efficiency, Water Consumption and Treatment - Successful aquaculture requires efficient conversion of vegetable feed, careful control of water resources, and management of residual products and waste. Review of data provided by the Company indicated that its hatchery and open-water production areas are achieving appropriate conversion ratios and proficiently managing feed and fresh water resources in fish production. ADL management confirmed that it does not use antibiotics and rearing practices. Water quality on the out-growing areas is monitored daily through extensive water sampling. Pelletized feed is dispensed using an automated “table based” system that is calibrated daily based on water temperature and chemistry to minimize overfeeding and reduce nutrient loading. Water consumption for hatchery operations, processing and sanitation services is well controlled and consistent with industry norms. Wastewater from the rearing operations is either recycled or mixed with effluents from the processing operations and treated in the multi-stage wastewater treatment plant. Effluent norms are established by SEMARNAT and monitored daily by ADL’s waste water facilities manager and independently by a SEMARNAT accredited laboratory on a quarterly basis. Records reviewed indicated that water treatment is effective, routinely monitored, and that effluent from hatchery and processing operations are within Mexican and WBG’s discharge limits for pH, BOD, COD, Oil & Grease, Suspended Solids, Coliform bacteria, and heavy metals. Discharge monitoring results will be included in the Annual Monitoring Report. (AMR). Energy consumption is monitored at various points and but the information is not yet centralized. Most energy used is provided by the grid for hatchery and processing operations (estimated at 500-700K KWH/month). An unspecified amount of natural gas used for the rendering boiler and stand-by power diesel consumption was not available. The Company estimated that Lake Operations currently consume an estimated 10 thousand liters per month. Observations and available information indicate energy efficiency is likely to be average and within the EHS Guidelines. Interviews indicated that stack emissions from rendering facility and ambient air emissions (ammonia, sulfides and mercaptans) were being monitored at the water treatment facility however, data was not provided at appraisal. The Company is reviewing energy and water consumption information and will provide unit consumption data and confirm air emissions compliance with the EHS Guidelines in the Annual Monitoring Report.

Waste and Hazardous Materials Management – The number of hazardous materials used in the Company operations are limited to strong basses and acids used in cleaning and waste water operations and ethylene glycol used as the refrigerant for the chillers and cold chain. A review of inventories, handling safety procedures, and working observations indicated that hazardous mat
erials are being appropriately managed and risks inherent to their use minimized. Some potentially toxic biological wastes from rendering operations are being transported off-site and land-filled by specialty contractors which pose some risks to the Company if the land-fills are not properly managed. The Company will verify and report all waste contractor compliance with Mexican land-filling regulations as part of the AMR process. (ESAP 3.1)

Community Health and Safety - An important impact that will occur during the operations phase of the project will result from induced development caused by ADL’s support to local fishermen communities. As observed in Penitas Lake, while fishermen and local communities have positively benefitted from ADL support (generation of family-based jobs, access to finance, higher incomes and creation of local markets), this development has created a localized waste management problem on Lake shores where artisanal fishermen land and clean their own tilapia. To prevent this from occurring in Malpaso, the proposed Stakeholder Engagement and Community Relations Plan will include a program with local fishermen groups to minimize waste generation, appropriately manage its disposal, where possible recycle wastes, and include awareness on habitat preservation and conservation management. Where relevant, ADL will coordinate these activities with municipal waste management authorities. (referenced in ESAP 6.1)

Infrastructure and Equipment Design and Safety - The Project is not expected to generate significant construction related health and safety impacts on local communities. Construction works will be limited to the land adjacent to Malpaso Lake, which is accessible to a main road and removed from local population. Construction related impacts from increased traffic, noise, generation and disposal of waste (land and water) and dust particles (air emissions) will be prevented, minimized and managed in accordance to the mitigation and management measures identified in the EMP for the project and outlined under PS 3.

Transportation Safety - ADL operates a significant fleet of owned and leased rolling stock and marine equipment to move people and products across the region’s network of largely rural roads and open waterways. The associated transportation risks to ADL’s staff and local communities will become larger as the Lake Malpaso expansion proceeds and supply chains are stretched further. In order to reduce risks to life and property, the Company will develop a Transportation Safety Plan that will assess the potential risks of its moving equipment on public roads and waterways and seek to avoid the occurrence of incidents and injuries to the public associated with production, processing and logistics operations. The Plan will address procurement and leasing operations, identify the resources necessary to implement and communicate the Plan, provide a schedule for roll-out, and identify a review process for determining its effectiveness. (ESAP Item 4.1)

Security Personnel - Expansion of the processing and production sites will require additional security arrangements to avert the risks to the physical assets of the Company and its workers. Arrangements will be made for patrols in and around the facilities, including production areas to secure and avoid theft of tilapia in the lake. ADL will prepare a security and safety plan in compliance with local laws, IFC
PS (whichever of the two is more stringent) and good international practices in relation to the hiring, rules of conduct, training, equipping and monitoring of security forces hired for the processing and production sites and operations. (ESAP 4.2)

Protection and Conservation of Biodiversity - Northeastern Chiapas has a distinct natural and land use history marked by successive waves of colonization and low levels of investment in agriculture and infrastructure until very recently. A series of four hydropower impoundments projects on the Mezcalapa River began in the late 1960’s and have now been completed generating a majority of Mexico’s renewable energy. The cage-based aquaculture is located in the central runs of the detention areas created by these hydropower projects. The area adjacent to the newly formed Lake Malpaso, the site of the proposed investment, is steep to moderately undulating terrain typically in low quality pastures with vestiges of failed agriculture improvement in citrus, cacao and other tree crops. Some areas of shifting cultivation for maize and beans (slash and burn or “milpa”) were observed and degraded gallery forests can be found in steeper areas which indicate the area was, until recent history, upland tropical rainforest.

Legally Protected and Internationally Recognized Areas - The native biodiversity in the area is best exemplified in El Ocote Biosphere Reserve which is approximately 10 kilometers away from Malpaso. Officially established in 1972, Ocote Reserve has been well studied and includes a core preservation area as well as multiple use “buffer zones” which includes indigenous and mestizo settlements. According to the Ocote Management Plan (SEMARNAT/CONAP, 2001), some 96 species in the Reserve are listed as Endangered, 42 Threatened and 20 Rare according to the IUCN. Pressure within and around the Reserve has increased as subsistence yields have failed to keep pace with population increases. The collapse of cacao production due to Witches Broom (Moniliophthora) in the 1980’s left few alternative cash crops. According to the 2010 Census, there is little, if any, formal employment around Lake Malpaso beyond the hydro electrical plant. ADL has explored possible partnerships with the Reserve, including using its reforestation requirements included in the EMP, to restore forests between the Lake Malpaso and the Reserve and provide improved biological corridors for migratory passerines. The Stakeholder Engagement and Communications Plan (ESAP 1.1) will include a socioeconomic assessment of livelihoods in area proximate to the lake to identify major land use constraints and appropriate options for biodiversity conservation which the Company may reasonably pursue.

Sustainable Management of Living Natural Resources - The Nile Tilapia (Oreochromis niloticus) was introduced to the river systems of southern Mexico from its African origin during the 1970’s. Tilapia is found in most fresh water rivers and lakes in Mexico and Central America. It is a voracious omnivore which competes very effectively with native species. Discussions with fisherman in the project area indicated that several native species remain available in both man-made lakes but that their
numbers have declined substantially. The biggest risk to sustainable management is very likely human pressure on the upland watersheds and clearing of remaining vegetation around the Lake itself. Both of these activities result in accelerated run-off, erosion, and increased sediment loading. When combined with artisanal fishery waste issues increased sedimentation could have a localized but significant impact on water quality impacting aquaculture yields. The Stakeholder Engagement and Community Relations Plan (ESAP 1.1) will carefully weigh the risks of such contamination and identify the most appropriate mechanisms to work with communities to reduce run-off and sediment loading. (ESAP 6.1)

ADL have established good relations with the local communities adjacent and near to the processing facility in Bajo Amacoites and Penitas Lake. ADL currently employ workers from more than 15 local communities in the area, making this group its most important stakeholder. ADL’s role as a major and predominant employer in the area will increase and grow as operations extend to Lake Malpaso. Good stakeholder engagement and relations with workers and communities will be critical to maintaining the success of the business and its social license to operate. Other important stakeholders include local authorities, fishing and agriculture cooperatives, second and third party contractors and local small and medium sized businesses, suppliers of goods and services. During appraisal, ADL demonstrated to understand the importance of maintaining good stakeholder engagement and community relations.
As it plans to expand, ADL will prepare a Stakeholder Engagement and Community Relations Plan (mentioned above, ESAP 1.1) to strategically manage engagement and these relationships in the long term. The plan will ensure that sufficient resources and effort is allocated towards ensuring the implementation of the plan. Engagement with communities and stakeholders will be participatory and inclusive, and where necessary, will include specific arrangements to protect the interests of ADL and the beneficiary. The Company will record, report, document, track and monitor the effectiveness of its engagement activities through a structured, systematic and timely process. Where grievances, concerns or specific requests arise, ADL will manage these accordingly through either the community based grievance mechanism attached to the Stakeholder Engagement and Community Relations Plan or the HR based GM for workers.

The Company will be requested to place an advertisement in a local newspaper in the region of Mezcalapa, Chiapas as well as its website (http://www.regalsprings.com) to inform the public of IFC’s environmental and social review (ESRS) findings and ESAP corrective action items.

Broad Community Support is not applicable for this project

Task Title/Description	Completion Date
Assessment and Management of Environmental and Social Risks and Impacts
ADL will provide IFC with evidence of its certification against the ASC Tilapia Standard and will include the results of the ASC Surveillance Audits in its Annual Monitoring Reports.	Jan-14
Establish and commence formal implementation of the corporate social responsibility strategy proposed by ADL to manage the business environmental and social considerations. The CSR Strategy and its components will align and integrate the considerations and aspirations of IFC’s PS 1.	Mar-14
Prepare a Stakeholder Engagement and Community Relations Plan. The Plan will identify stakeholders, determine their level of interest and influence in the project (by importance and relevance), and identify appropriate programs and methods for engaging key stakeholders to minimize the E&S risks. The Plan will include a timeline, critical milestones and key performance indicators for measuring effectiveness, and identify (financial and human) resources necessary to implement the Plan.	Jun-14
Develop a Grievance Mechanism to receive and facilitate the resolution of project related concerns and grievances associated with the Company’s environmental and social performance among affected communities.	Jul-14
The Company will develop a corporate procedure for external communications with stakeholders (through different mediums) where environmental and social risks and impacts require careful management.	Mar-14
Update Emergency Management Plan to include risks for flooding at processing facilities and severe weather and catastrophic events in Lake Malpaso operations.	Jul-14
Labor and Working Conditions
The Company will pursue establishment of an OHSAS 18001 program to improve its OHS effectiveness and reporting.	Jul-14
Resource Efficiency and Pollution Prevention
Develop and promulgate procedures to verify final disposition of hazardous and biological wastes.	Mar-14
Community Health, Safety, and Security
To reduce risks to life and property, the Company will develop a Transportation Safety Plan to assess the potential risks of its operations on public roads and waterways and develop and implement measures to effectively avoid the occurrence of incidents and injuries to the public associated with production, processing and logistics operations.	Sep-14
Prepare a Security and Safety Plan in compliance with local laws, IFC PS (whichever of the two is more stringent) and good international practices in relation to the hiring, rules of conduct, training, equipping and monitoring of security forces hired to protect and secure the hatchery, processing and production facilities and sites.	Mar-14
Biodiversity and Natural Resources Management
The proposed Stakeholder Engagement and Community Relations Plan will include a program with local fishermen groups to carry out (i) awareness training on how to minimize and manage waste generation and water pollution in the Lakes from increased artisanal fishing activities, (ii) risks associated with soil erosion, sedimentation and deforestation in and around the Lakes, and (iii) promotion of habitat and ecosystem conservation of the Lakes.	Jul-14