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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category A project according to IFC’s Environmental and Social Review Procedure because it has potential adverse environmental and social risks and/or impacts that are diverse and irreversible.

The key environmental and social risks and impacts mainly relate to i) land take for the plant site, worker housing, and quarry according to an agreement with a local village (the land is currently not in use but has a potential economic value for the village); ii) community health and safety, in that substantial heavy truck traffic will be generated during both construction and operation of the project, which could impact local communities; iii) potential for influx and uncontrolled development; and iv) the abstraction of water and the discharge of pit water, which could contaminate receiving water bodies and, as a result, affect both biodiversity associated with these water bodies and the ability of communities to use such water.

Aside from the management systems PPC will implement as part of standard practice, various project specific management plans will be developed and implemented to address the impacts and risks identified above. Specific actions have also been defined in the Environmental and Social Action Plan, which is being disclosed together with this document.

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.

PPC is establishing a new company in the DRC to develop and operate its greenfield limestone quarry and cement processing plant in the Kimpese area. To build up its systems for the DRC, PPC is relying on its expertise at the corporate level in South Africa, experience from its other operations as a regional cement player in Zimbabwe, Botswana, Mozambique, Ethiopia, Rwanda, and from consultants, and the company will develop its environmental and social management system (ESMS) in accordance with DRC and South African law, IFC Performance Standards, and its existing corporate policies, systems, and procedures.

Policy
At the corporate level, PPC has a clear commitment to sustainable environmental and social performance, which is articulated primarily through the PPC Group?s Environmental Policy approved in January 2013. This policy states that PPC is committed to understanding and managing any potential environmental impacts of its activities by integrating environmental management into its business functions and monitoring environmental performance systematically. Specific elements of this policy include the following:

Establishing clear accountability for environmental performance
Seeking continual improvement of environmental management through customized frameworks for engaging with stakeholders, identifying significant environmental impacts, and setting and reviewing progress against objectives and targets
Complying with environmental laws and regulations applicable to PPC?s activities
Identifying and implementing efforts to manage natural resources sustainably and optimally, including through resource optimization strategies and cleaner technologies
Preventing pollution and reducing waste
Working with stakeholders to communicate transparently, to develop effective stakeholder forums, and to develop capacity among them to identify, report, and act on opportunities to minimize negative environmental impacts and to promote sustainable use of PPC?s products
Managing PPC?s land assets to maintain biodiversity and to rehabilitate degraded areas

PPC currently does not have a comprehensive corporate policy on social performance; however, it has sought to adopt a proactive and inclusive approach to stakeholder engagement, including through formalized stakeholder engagement forums. This approach does not yet comprise a systematic, company-wide process for receiving and resolving grievances raised by stakeholders, for example, but it seeks to open channels for communication and dialogue with key groups through stakeholder forums at the corporate and operational levels.

At the corporate level, PPC has reinforced its commitment to equal opportunity and empowerment by becoming a signatory to the United Nations initiative ?Women?s Empowerment Principles ? Equality Means Business,? produced and disseminated by UN Women and the UN Global Compact. While not a formal member of the Cement Sustainability Initiative of the World Business Council for Sustainable Development, PPC does cooperate with it on data collection.

As defined in the project''s Environmental and Social Action Plan, PPC is required to develop a clear social performance policy, approved by its Board at the corporate level, to supplement its company-wide Environmental Policy as well as an overall environmental and social policy for its DRC operations, approved at the country board level. Both are due by 31 December 2014.

Identification of Risks and Impacts
At the corporate level PPC has sought to analyze material issues and risks related to its environmental and social performance, though this process has yet to encompass all relevant material issues and risks on a company-wide basis. The 2012 annual report indicates that three higher-order environmental and social issues were examined from a risk perspective: (1) safety, including lost-time injuries, (2) labor unrest, and (3) carbon footprint. Response strategies were developed in relation to all three. In the 2013 annual report, the first two issues were maintained as ?material,? while PPC?s carbon footprint was dropped from this list but nonetheless analyzed in detail as a separate issue.

At the project level, PPC?s local DRC partner was required under the DRC?s Mining Code of 2002 to develop and submit an Etude d?Impact Environnemental (or Environmental Impact Assessment, EIA) and a Plan de Gestion Environnemental du Projet (PGEP, or Environmental Management Plan) as part of the process for gaining the concession and securing relevant permits. The original EIA was carried out in 2010. As a result of limitations noted in the EIA, PPC has contracted SRK Consulting, a specialized environmental and social consultancy well-versed in IFC?s Performance Standards to supplement this information. A framework Environment and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP) were prepared in January 2014, and a comprehensive ESIA and ESMP will be completed by October 2014. In addition, detailed baseline specialist work is being carried out for air quality, surface, and groundwater resources and on socio-economic issues. These studies will inform the Comprehensive ESIA and ESMP, to be completed by October 2014.

Although the comprehensive ESIA might reveal additional risks or change the estimation of severity of impact, the framework ESIA conservatively identified the following risks in need of mitigation as part of the ESMP:

Air quality (to ensure low particulate and gas emissions during operations)
Greenhouse gas emissions during the operational phase
Biodiversity impacts including potential loss of flora and wetlands needs management
Management of surface and groundwater impacts to reduce the risk to water availability for other users
Loss of soil resources and change in land capability, including risk of soil contamination caused by vehicle operations
Noise and vibration impact in Malanga and Zamba villages during construction, operations, and blasting needs management
Visual impact of large constructions and landscape changes
Traffic and transport impacts, including accident risks and road damage, caused by increased traffic during both construction and operations.
Stimulation of local development and local investment in infrastructure and skills training during operations
Social impacts with an increased risk of social tensions, health and social impacts, and impacts on community health services associated with migrant worker influx
Land acquisition and economic displacement of Zamba and Malanga residents and potential impacts on ecosystem services

In light of these anticipated risks and impacts, the following key plans and procedures containing specific management and mitigation measures will be included in the ESMP:

Environmental and Social Management System (ESMS) Framework
Environmental Awareness Plan
Construction Management Plan
Construction Control Plan
Traffic Safety Plan
Emergency Preparedness and Response Plan
Greenhouse Gases (GHG) Management Plan
Cultural Heritage Management Plan, including Chance Find Procedure
Stakeholder Engagement Plan
Community Development Plan
Influx Management Plan
Contractor Management Plan
Employment and Capacity Plan
Draft Land Acquisition and Compensation Framework
Preliminary Closure Plan

An action item in the ESAP is for PPC to complete and publicly disclose the comprehensive ESIA and ESMP by 31 October 2014, and the new power line and specifically the proposed route will also be assessed in the supplementary assessment work to be undertaken. The latter will include identification of mitigation measures to be addressed by management, where required.

The closest other significant industrial project is also a proposed cement plant that is located more than 20 kilometers away and that will follow the same stringent emission requirements as the PPC project. A potential positive cumulative impact effect could potentially be achieved if the full implementation of an upgrade project for the Matadi to Kinshasa rail line would allow the cement plant to use this transport option for coal from the port and cement to Kinshasa i.e., negating the use of road. However, this possibility is not a real option at this time. There are additional cumulative impacts as a result of these two cement operations that are likely, including those related to increased traffic and negative effects of population influx, such as additional strains on available social infrastructure and public services. The effects will be mitigated principally through measures (described in greater detail below and in the ESAP) related to managing truck traffic at/near the plant and a Community Development Plan that should encompass assistance on urban planning for the nearby towns of Kimpese and, if appropriate, Songololo. The Community Health and Safety Plan should similarly take into account the increased demands on local health services and infrastructures on these nearby towns as well.

Management Programs
At the corporate level PPC has well-established corporate-level environmental, health, safety and social (EHSS) management programs with a detailed set of standard operating procedures applicable to existing manufacturing operations in South Africa and elsewhere. These will be applied in the DRC as well, taking into account whatever relevant practices that DRC law or the IFC Performance Standards might require that go above and beyond existing management approaches. It is PPC?s intention that management systems and operating procedures for the DRC project be equally stringent as for PPC operations in South Africa, or elsewhere. The environmental management programs in PPC?s existing manufacturing assets in its South African operations are certified under the ISO 14001 international certification program.

At the project level, PPC is developing a comprehensive environmental and social management system (ESMS) for its DRC project covering labor, environment, health and safety, land acquisition and involuntary resettlement, cultural heritage, stakeholder engagement (including grievance management and public reporting), and strategic community investment. It is being assisted by experienced consultants in these fields. See above under ?Risks and Impacts? for the full list of management plans that PPC is developing and intends to implement for this project.

An action item of the ESAP is for PPC to finalize and begin implementing a comprehensive ESMS for its DRC project, including those management plans and programs specified above, by 31 December 2014.

Organizational Capacity and Competency
Corporate oversight of environmental, health, safety and social (EHSS) issues is handled at the board level by a committee on risk and compliance and a social and ethics committee, whose chairperson reports to the full board. The committees? tasks are to evaluate and manage risks, to assist the board in monitoring PPC?s activities against relevant legislation, other legal requirements, or prevailing codes of best practice, and to ensure compliance with legislation and other commitments. Within the boards of country-level operating companies under the PPC Group, there are similar committees tasked with oversight of these issues within the country in question. Responsibility for the day-to-day management of EHSS issues is formally assigned at the corporate level to three different groups. The Group Risk Manager covers all non-safety and non-health issues and reports to the Executive: Secretariat and Governance, who in turn reports to the CEO. The Group Safety and Health Manager reports to the Executive: Technical, who in turn reports to the CEO. The Group Sustainability and Environmental Manager reports to the Head: Technical, who reports to the Executive: Technical. Day-to-day managerial responsibility for EHSS issues is further devolved to the project level. During the construction phase of the DRC project, PPC will hire a Risk Manager and an Environmental and Sustainability Manager; these positions are envisioned to continue during the operations phase. Both will report to the senior on-site manager. During construction and operations, the Risk and E&S Managers will have the support of technical officers responsible for health, safety, security, environment, and community development.

Training
At a corporate level, PPC has a well-developed program for training staff in occupational health and safety and an across-the-board procedure for contractor site induction, including training on relevant health and safety issues for contractors and subcontractors. PPC will adopt a similar approach to its DRC project, including requiring its EPC contractor to develop and maintain a mandatory induction training program for all construction workers. In addition, PPC?s project management of the EPC contractor includes its own oversight of how the contractor is training its construction workers and applying OHS requirements, especially for hazardous types of work. For more information on the specific areas of training in and oversight of such hazardous work for PPC and its contractors and subcontractors, see the sub-section below on Occupational Health and Safety under Performance Standard 2.

Emergency Preparedness and Response (EPR)
PPC?s operations will have emergency risks that will mainly be limited to impacts on their own site. To handle these risks, the organization will include the necessary emergency response team on site and health clinic facilities to provide emergency room services. For the initial phase this will be achieved by having the EPC contractor bring in its own medical doctor and clinic. Entering the operational phase, the emergency response facilities will include on-site clinic, ambulance, and staff on all shifts trained for emergency response.

Monitoring and Review
PPC has established a basic structure for monitoring and reporting on its environmental and social performance. At the corporate level, the company has begun using Global Reporting Initiative (GRI) indicators, version G3.1, as well as guidelines on corporate governance in South Africa set out in King III and the Listings Requirements of the Johannesburg Stock Exchange to report on its environmental and social performance. In 2012 and 2013, PPC reported that its annual report met a self-declared C+ classification under GRI (which requires reporting on at least ten GRI indicators across different categories). Under an action item of the ESAP (strengthening of a comprehensive environmental and social management system), PPC is required to expand and reinforce its monitoring and reporting system with special regard to its DRC operations.

External Communications and Grievance Mechanisms
As a publicly listed company with a century of history of operations in South Africa, PPC has a strong commitment to inclusive and proactive stakeholder engagement, including through formal stakeholder engagement forums at the corporate and operational level. This includes the exchange of relevant information and creation of channels for dialogue at the operational level. The company, however, does not currently have a comprehensive stakeholder engagement methodology that orients all of its international operations in a systematic fashion, for example in establishing standardized approaches to identifying stakeholders, consulting with affected communities about risks and benefits, establishing external grievance mechanisms, and reporting to communities on environmental and social performance. For example, PPC does not report having a systematic, company-wide process for receiving and resolving grievances raised by stakeholders, but it seeks to open up communication and dialogue with key groups through appropriate stakeholder forums at the corporate and operational levels. As part of an action item (strengthening of a comprehensive environmental and social management system), PPC will be required to implement an effective external grievance mechanism in DRC.

On-going Reporting to Affected Communities
PPC?s approach to stakeholder engagement in South Africa involves creating formal forums that are convened on a regular basis. These forums, in addition to the publication and dissemination of annual reports and other reports to broader audiences, constitute the principal modalities for conveying information to affected communities. PPC does not currently have a well-defined approach for reporting to affected communities in the DRC. The Stakeholder Engagement Plan ? required as part of the comprehensive environmental and social management system (ESMS)? will include provisions on reporting regularly to communities and other key stakeholders on how risks are identified, analyzed, and mitigated and the progress (or lack thereof) that the company is achieving with regard to mitigating negative impacts and enhancing positive project benefits.

Working Conditions and Management of Worker Relationship
PPC is hiring a third-party engineering, procurement, and construction (EPC) contractor to build the cement plant, and the company itself plans to hire a direct workforce of approximately 275 employees for the operational phase of the project. Additional third-party contractors are likely to be used during operations for transport and logistics, security, and possibly catering, housekeeping, and similar functions.

At the peak of the construction period, the project will require a temporary work force of between 1,000 and 1,200 skilled workers with the qualifications and experience to perform the various phases of project construction. Close to all of the skilled construction workforce will be sourced internationally while some unskilled functions will be carried out by local day laborers under the supervision of the EPC contractor. A temporary workers? camp will be built for housing the international workforce hired by the EPC. Unskilled day laborers will be drawn from the nearby villages in a way to maximize the opportunities for income to be earned by members of the local communities.

PPC will require that the EPC contractor abide by its corporate policies and practices, based on South African standards, for working conditions and occupational health and safety (OHS). PPC is including in an amendment to the EPC contract requirements that the contractor also abide by the requirements of IFC?s Performance Standard 2 as well as the IFC and European Bank for Reconstruction and Development Bank?s Guidance Note on ?Workers? Accommodation: Processes and Standards.? PPC will apply a similar approach, system, and procedures for oversight, monitoring, and documentation of contractor performance as it uses in South Africa. In addition, the ESAP requires that PPC conduct a third-party labor and OHS audit of the EPC contractor?s practices ca. 6 months after the start of civil works to ensure that the EPC contractor?s labor practices are in conformity with the IFC?s Performance Standard 2 and identify any gaps that PPC would need to address.

During the operational phase, PPC will apply its corporate guidelines, procedures, and monitoring systems at the country level in the DRC. Where PPC?s own corporate practices exceed DRC legal requirements, they will be maintained. These include a comprehensive approach to recruiting, training, developing, and managing its workforce at all levels, including workers? rights to form organizations for purposes of collective bargaining. It is PPC?s principle to respect worker rights, and it maintains constructive relations with unions at its sites. Through its Kambuku human resources management system, PPC promotes open and candid dialogue with its workforce at all levels. In addition, it has in place worker grievance mechanisms for its South African and other African operations, including an anonymous grievance reporting channel managed by an independent, external party. Furthermore, the IFC reviewed standard employment contracts for operator-level workers at PPC?s South African operations. In addition to clear working conditions and terms of employment, it included provisions on occupational health and safety, the company?s code of ethics, and access to grievance procedures. A separate corporate policy defines PPC?s approach to respecting the rights for workers to organize, form unions, and engage in collective bargaining with management.

The standard South African contracts will serve as the basis for PPC?s worker contracts in the DRC, adjusted appropriately for any relevant DRC legal requirements. Provisions of the DRC constitution and/or the 2002 labor code guarantee freedom of peaceful assembly, freedom of association, and the right to form and join trade unions without prior authorization or excessive requirements, as well as to carry out strikes once a union and employer have adhered to lengthy mandatory arbitration and appeal procedures. The law also stipulates different lengths for standard work weeks for different jobs. It requires rest periods and premium pay for overtime, but it does not prohibit compulsory overtime. PPC labor standards, policies, and procedures for the DRC will be based on the company?s corporate practices while ensuring compliance with DRC law. PPC has stated its intention to engage with unions that are registered with the Ministry of Labor and Social Welfare under the DRC labor code, and it intends to recruit its permanent workforce on basis of non-discrimination and equal opportunity, including for women.

Under an action item in the ESAP, PPC is required to conduct a third-party audit of labor practices, including those related to OHS, for its principal providers of contracted/subcontracted services within one year of the start of full operations to ensure conformity with the IFC?s Performance Standard 2 and to identify any gaps that PPC would need to address.

PPC is committed to the ongoing contribution of its operations to local economic development, education, and workforce development, and it plans to maximize the hiring of local labor for the operations phase over time. In keeping with its strong commitment to maximizing the participation of its national workforce in operations elsewhere in Africa, PPC?s intention is to have no more than 15% of its workforce to be international personnel by the third year after the start of full operations, and it will endeavor to maximize the training, recruitment, and employment of qualified workers and personnel from communities as close to the operation as possible. As it has done in South Africa and elsewhere in Africa, PPC plans to invest heavily in local workforce development through its in-house adult basic education and training (ABET) program, its Technical Skills Academy, Operations Academy, Mining Academy, and similar training programs. PPC will report on the achievement of international workforce reduction in its annual reports to IFC.

Protecting the Workforce
As a matter of company policy, PPC does not employ persons under the age of 18, and it has policies, systems, and procedures in place to guard against employing under-aged workers or forced labor in South Africa and its operations elsewhere. Similar policies, systems, and procedures will be developed and implemented for its DRC operation.

Occupational Health and Safety
PPC has extensive policies, systems, and procedures in place in South Africa and its operations elsewhere to ensure that its workers enjoy a safe and healthy work environment, taking into account inherent risks in the cement sector. These policies, systems, and procedures apply for its own workforce as well as those of its contractors and subcontractors, which are required as part of any contract with PPC and operational oversight by the company to safeguard, monitor, and report on breaches in occupational health and safety (OHS) measures to PPC, particularly for hazardous work. For both in-house and contracted work that is hazardous, PPC has measures in place to ensure that such activities are risk-rated, carried out by properly trained personnel using appropriate equipment, documented, and supervised appropriately.

PPC?s OHS practices are based on South African legislation on OHS and the Mine Health and Safety Act, and its South African operations are certified against ISO 9001 and 14001. In 2011-12 PPC recorded no fatalities at its operations, and its Lost Day Accident per Million Man Hour (LDA/MMH) frequency decreased from 1.7 in 2011 to 1.15 in 2012. PPC saw one fatality and an LDA/MMH of 1.4 in 2013.

Workers Engaged by Third Parties
PPC has an extensive system in place for its South African and other African operations with regard to the OHS performance of contractors and subcontractors. As noted above, PPC is requiring its principal third-party contractor in the DRC ? a foreign EPC contractor hired for the construction phase ? to apply both PPC?s corporate measures and Performance Standard 2 requirements with regard to that contractor?s labor and OHS practices. With respect to contractors and subcontractors in both the construction and operations phases, PPC will ensure that any third-party contractor has its own worker grievance mechanism in place for contracted and subcontracted workers, or that PPC will extend its own grievance mechanism to serve workers engaged by the third party. As noted above, PPC will both audit the EPC contractor?s performance on labor standards ca. 6 months after the start of civil works (action item in the ESAP), and PPC will commission a similar audit in the first year of full operations to ensure all other DRC contractors and subcontractors, particularly for transport, logistics, and guard services, are applying PPC?s corporate policy and procedures in light of IFC Performance Standard 2 during the operational phase.

Supply Chain
PPC?s primary suppliers are not considered to be at high risk of engaging child or forced labor. With regard to occupational safety and health measures for PPC?s contractors and subcontractors engaged in potentially hazardous activities, PPC has stringent policies, contractual requirements, systems, and procedures in place in South Africa and elsewhere to ensure that those third-party companies adhere to PPC?s OHS requirements with the same level of rigor as PPC does.

IFC?s assessment considered the Project?s compliance with environmental requirements, optimization of resource inputs, including energy efficiency and waste minimization practices, as well as the storage and handling of hazardous materials used in the construction and operations of facilities.

Resource Efficiency
The proposed clinker production and cement grinding facilities have been designed for low energy consumption and good emission controls with continuous monitoring of key pollutant emissions (particulate, nitrogen oxides, and sulfur dioxide). The limited amounts of wastewater generated will be treated and used for irrigating greenery around the plants, and no significant amount of solid or hazardous production waste, except for broken cement bags, canteen, office, domestic and laboratory waste, and maintenance wastes (used refractory bricks, lubricants, etc.) will be generated.

The clinker production plant will consume approximately 375 tons/day or 112,500 tons/yr of coal imported through the port of Matadi. The coal will be consumed exclusively in the calcining process ? no coal will be used for electricity generation as all electricity required for the plant?s operations will be sourced from the grid. The clinker plant is to be equipped with a five-stage preheater with a pre-calciner having a predicted thermal energy efficiency performance of 740 Kcal/kg of clinker and an electrical power consumption of 65kWh/ton of clinker, which is within industry standards established by the European Union. The Project?s cement grinding plant will also source its estimated 45kWh/ton of cement from the national grid to power the plant?s three grinding mills and bagging operations. The Company estimates that the combined electricity consumption per ton of bagged cement, including clinker production, grinding, blending and bagging, will be 100 kWh per ton of cement, which compares favorably to an industry standard of up to 105 kWh/ton cement.

The Project requires the installation of a new 13 km, 220 kV power line from the Kwilu substation to the plant site; this will be done by the public utility company and will not require passing over settlements or sensitive areas. IFC has reviewed this Project component as an associated facility and not identified any critical elements at this stage. The plant will also be equipped with emergency backup diesel generators.

The plant is based on a dry process with water only needed for cooling purposes, dust suppression on roads, and domestic water usages. The estimated water consumption is 1200 m3 per day. This consumption can be met by either deep-well extraction, or from local rivers. A hydrology and water study is underway for the determination of the best method of sourcing the water needs without causing aquifer drawdown or too low flow in the local river.
An interim sewage treatment facility will be installed for the construction camp, while for the operational phase a permanent sewage treatment plant will be constructed to receive wastewater produced by the plant and the staff facilities. The design of the permanent sewage treatment plant is still under consideration, but it will at a minimum treat the wastewater to be suitable for use as greenbelt irrigation or for release to an evaporation pond; in the event that release to a water course is deemed appropriate, it will be designed to meet the World Bank Group EHS Guideline for discharge of wastewater.

Pollution Control
Particulate emissions will be controlled at the quarrying sites and in the general material handling systems by designs requiring minimal material drops during handling and covered conveying systems with bag filters installed at transfer points. Water-based dust suppression will be used where evacuation and filtration systems are not practical, such as road transport within the quarry operations or between the quarry and the crusher located at the plant site.

The plant is located in a non-polluted part of DRC with minimal industrial activities. The ambient air has therefore been deemed good, and it is not likely to be affected by the plant?s operations within the limits of the World Bank Group EHS Guidelines. Nevertheless an air emissions baseline study in and around the plant will be needed and is included as part of PPC''s further preparation process. In addition this study will take into account potential cumulative impacts associated with the other new cement plant also being established in the broader region (though given that the latter is located some 20 km away, this is currently not considered an issue).

All plant units will have dust control measures installed at all emission points (e.g., bag filters at all emission points, except for the clinker cooler, where ESP filters will be used). These filters are all designed for maximum emissions of 30 mg particulate/Nm3.

Apart from particulate emissions, other major point source pollutants in the cement manufacturing process are sulfur dioxide and nitrogen oxides, which are related to the operation of the clinker kiln. Sulfur dioxide emissions will be low, as the alkaline conditions in the clinker kiln will result in the absorption of the majority of the sulfur entering the systems either through the raw materials or the fuel. The sulfur dioxide emissions will not exceed the WBG EHS Guidelines value of 400 mg/Nm3.

Formation of nitrogen oxides (NOx) is caused by fuel burning at high temperatures in the kiln. To minimize the formation of nitrogen oxides, the kiln will be operated following advanced combustion principles, including the use of low-NOx burners, which by controlling the flame shape are able to ensure a relative low core flame temperature. By applying these techniques the NOx emissions will be kept below the 600 mg/Nm3, as stipulated in the WBG EHS Guidelines. PPC will use all efforts to optimize the burner operations and achieve these results within six months of plant commissioning. An alternative way of lowering the NOx emissions is through the application of Selective Non-Catalytic Reduction (SNCR). This technology does, however, require a supply of concentrated ammonia, and the transport of concentrated ammonia on the roads of DRC is not considered a safe practice at this time. Should the plant therefore experience difficulties in achieving the 600 mg/Nm3, the first corrective actions will be to explore further burners and staged-combustion optimizations, to be followed by ambient air studies for acceptability of the achieved emissions, and only as a last resort the inclusion of SNCR.

IFC will require PPC to continuously monitor particulate emissions from the plant, namely sulfur oxides (SOx), and nitrogen oxides (NOx), while other pollutants including possible mercury emissions will be tested for at least once per year. In addition, an ambient air quality monitoring program will be developed and implemented with a specific focus on communities. The results of the monitoring will be included in the Annual Monitoring Report to IFC.

Noise and Vibration
Blasting, stone crushing, and vehicle movement will be the main sources of noise and vibration from the quarry and clinker manufacturing operations. Quarrying operations will be restricted to a two shift operation typically from 6AM to 10PM, and blasting will typically be restricted to one main blasting every fortnight and minor boulder blasting during the week between. Blastings will be set in sequences that include micro-delays between the blasting of the individual charges thereby reducing the vibrations in the ground.

Crushing, loading of clinker, and dispatch of trucks will be restricted to a two shift operation typically from 6AM to 10PM. Apart from the resident workforce, the nearest receptors to operations noise and vibration ? residents of the Zamba village ? are 2 km distant from the site. As such, no significant adverse impacts from noise or vibration are anticipated on human populations.

Management of Solid and Hazardous Waste
The solid and hazardous waste generated by clinker plant operations will either be recycled (e.g., used refractory bricks) or disposed. As there is no organized waste handling in the area, disposable waste from the operation and ordinary domestic waste (including damaged cement bags) will be handled by PPC in accordance with the outcome of the ongoing studies to be completed during 2014. The plant will not have a bleed, and will therefore not produce any waste streams that are in need of disposal. Overburden and top soil from the quarry opening and operation will be stored and reused for quarry reclamation as the quarry operation proceeds where applicable.

Quarry Management and Reclamation
PCC will prepare a quarry management and rehabilitation plan including the following distinct items; a) a tentative full quarry utilization plan including tentative final contours, with overburden and top soil application and vegetation (this plan is to be ready before production usage of the quarry starts); b) an overburden and top soil storage and reapplication plan for the full operational life of the quarry (this plan is also to be ready before the production usage of the quarry starts); c) a five-year rolling quarry management and rehabilitation plans including quarry contours, overburden reapplication and top soil needs, and replanting goals; and d) one-year rolling detailed quarry utilization, contouring, overburden and top soil application plans, including re-vegetation details and targets. These plans are included in the ESAP for the project.

Green House Gas Emissions
PPC plans to produce cement with an average clinker content estimated at 84% with the use of gypsum and limestone as additives. As such, the CO2 emission from PPC?s annual cement production will be around 690 kg/ton cement or a total of 759,000 tons CO2 from annual production of 1.1 million tons of cement. Coal imported via the port of Matadi will be used for firing the clinker kiln as no other fuel source is available to the Company.

Infrastructure and Equipment Design and Safety
Potentially negative community health impacts stem from dust and noise due to the movement of heavy equipment, materials and project personnel during construction. During operations, blasting and heavy trucks with raw and processed materials will affect the population of rural villages and settlements located within a few kilometers of the cement plant and along nearby roads, including National Highway 1, which will be an important conduit for importing raw materials and exporting finished product for the project. Community safety risks will also result from a marked increase in vehicular traffic during both the construction and operational phases and the concomitant potential for accidents involving both humans and domestic animals. To avoid risks to public health and safety and to minimize disruptions to local residents during the construction and operation phases, the Sponsor has commissioned specialized noise, dust, and traffic studies, and it intends to put into place specific programs and preventive/mitigation actions, including a Construction Management Plan and a Construction Control Plan.

With regard to traffic safety, the Sponsor has undertaken to design and implement a Traffic Safety Plan, in addition to upgrading and maintaining an 8-km stretch of unpaved Provincial Road No. 111 from National Highway No. 1 to the plant. The Traffic Safety Plan envisions enhanced road signals, vehicle speed control initiatives and safety standards by controlling against overloading, safety and defensive driver training, and sanctions for traffic violators. This Plan will also take into account traffic generation as a result of the other new cement plant such that cumulative issues area addressed. Monitoring of the implementation of these actions will occur as a routine component of the client?s ESMS.

With regard to potential negative social impacts of the increased presence of truckers waiting at/near the plant to offload or load, the Sponsor will include in its design of the plant an internal waiting area sufficiently large to accommodate 200-300 trucks per day. Included as ESAP action item, this waiting area will be secure and properly provisioned with sanitation, food services, and other small shops so as to minimize if not eliminate the need for waiting truckers to enter nearby villages for such services.

The presence of a new cement operation is also likely to increase population in the broader area of PPC''s plant, particularly in towns like Kimpese and possibly Songololo. In the short run, no influx of workers who might stay in the project area is envisioned as a result of the construction phase, since PPC is hiring an EPC contractor staffed with temporary foreigner workers. PPC also plans to construct a residential village for its permanent operations staff, estimated to number 275, who will be almost exclusively Congolese. PPC has undertaken to hire such staff as locally as possible, given the availability of qualified candidates. This will help to minimize influx associated with its permanent workforce. The major likely source of population influx is, therefore, the growth of third-party companies, particularly trucking and logistics services that might base themselves and their personnel in Kimpese and/or Songololo. Through its Community Health and Safety Plan and its Community Development Plan, PPC will therefore seek to strength the capacities of relevant local authorities to plan for and manage the demands of increased population on public services and infrastructure.

Hazardous Materials Management and Safety
The operation of the cement production plant will not generate hazardous wastes different from those already experienced in relation to vehicle operations (used oils, oil filters, etc.), and the plant will not use hazardous chemicals in its processes. The quarry operation will require the use of explosives. Explosive usage is strictly regulated by the authorities, and PPC will follow all rules in this respect. The storage for explosives will be established in a remote location to avoid any interference with operations and any risk of accidental impact from e.g. passing vehicles. No other hazardous materials are anticipated in the operation of the plant.

Ecosystem Services
Ecosystem services will mainly be impacted by the restriction of access to the land to be used by the project. The impact will however be minimal as the project land is currently degraded and converted from its natural form due to past removal of all sizeable wood (which has been harvested and used for charcoal production) and yearly burning of all grass. The surrounding areas are in the same conditions and do not support any substantial grazing of domestic animals. There is also no significant wildlife present in the area.

Community Exposure to Disease
The PPC project site is located within the Kimpese health zone, which is serviced by 30 health posts and five health centers. The nearest health center for the four villages close to the project site is located in one of them, Malanga, but it is considered to be poorly equipped and has a staff of only two nurses. Kimpese, a town about 20 km away, has the Evangelical Medical Institute hospital for treating patients with more serious conditions. However, healthcare infrastructure in the DRC is generally considered inadequate, due to lack of sufficient medical personnel, equipment, medicines, logistical capacity, etc. Diseases prevalent in the region are malaria, gastrointestinal and respiratory illnesses, and sexually transmitted infections including HIV. Based on the framework ESIA, the expectation is that the community health impacts associated with migrant worker influx and the additional demands on existing health services will be significant and primarily negative. For its own workforce and as part of its commitment to Zamba village under agreements negotiated by PPC?s Congolese partner, PPC has undertaken to construct a medical clinic for the project and provide access to community members, although the details regarding the type of facility, its management, and how community access will function have yet to be defined. The framework ESIA envisions that PPC will establish and implement a Community Health and Safety Plan.

The ESAP requires PPC to create an internal action plan by 31 December 2014, based on the Community Health and Safety Plan to be disclosed by 31 October 2014, and develop appropriate partnerships with health authorities, local health providers including NGOs, and other relevant stakeholders to strengthen local health infrastructure and services and to begin implementing such a plan by 31 January 2015. This Community Health and Safety Plan should take into account the broader impacts that population increase will place on the health zone''s infrastructure and resources and include measures for bolstering health services not only in the villages neighboring PPC''s operations, but also the towns of Kimpese and, if appropriate, Songololo, where companies such as third-party trucking services are likely to establish themselves. PPC will provide information on the implementation of these Plans in its Annual Monitoring Reports to IFC.

Security Personnel
DRC law prohibits the arming of private security personnel. PPC reports that it typically hires its own security guards, who are unarmed, for access control, patrolling perimeters, and surveillance within its facilities, and that the company generally minimizes the use of third-party security personnel. In the DRC, PPC has not yet determined its approach to establishing a guard force, including whether it will hire such personnel directly or outsource such services, and it has not yet defined how it will handle surveillance and security outside the perimeter of its facilities. The company has also yet to establish a policy in the DRC with regard to identification, analysis, and documentation of risks associated with third-party security providers (whether public or private), use of force, procedures for vetting security personnel (whether in-house or third-party) for any alleged human rights violations, or establishing norms for hiring, training, equipping, and supervising such personnel, including procedures for the investigation of any allegations of illegal or abusive acts and measures to prevent such abuses from recurring.

An ESAP action item ? due by 31 August 2014 ? is for PPC to carry out a security risk assessment and develop appropriate policies and procedures for managing the project?s use of and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in light of IFC Performance Standard 4.

Protection and Conservation of Biodiversity

The area consist of modified habitat in the form of land degraded and converted from its natural form due to past removal of all sizeable wood (which has been harvested and used for charcoal production) and yearly burning of all grass. The wider surrounding areas are in the same conditions and do not support any significant wildlife. There is, however, the presence of the protected tree Milicia excels (trade name: Iroko) in two forest patches in the concession area. This species was once widely present in tropical Africa, but it has been heavily exploited. It has an IUCN classification as “lower risk/near threatened”. Critical habitat, however, has not been found in the concession area. It has been agreed with PPC that the nursery to be established to provide seedlings for the rehabilitation of the quarry site will include and promote the tree Milicia excels in its vegetation planning, hereby providing an increased number of this tree in the final rehabilitated quarry.



The potential for impacts on biodiversity as a result of the powerline will be determined in the supplementary assessment work being undertaken.

Identification and analysis of sites of cultural significance is in a preliminary stage and needs to be completed by the environmental and social consultants contracted by PPC. As the resident population in the villages around the concession settled the area only a couple of generations previously and consider other regions to be their ancestral lands, there are to date no sacred sites reported by the local population, beyond cemeteries. However, based on experience elsewhere in the DRC, locations of cultural significance are likely to come to light over time, and the Sponsor will need to have a policy in place for identifying and properly handling such sites, including procedures for chance finds and for analysis and disposition of any items of potential archeological or cultural value encountered during construction or thereafter.



As part of the ESAP, PPC will implement a comprehensive environmental and social management system for its DRC project, including a Cultural Heritage Management Plan (with a Chance-Find Procedure). The Chance-Find Procedure will be applied as part of the start of construction, estimated to be April 2014.

At the corporate level, PPC has a strong commitment to inclusive and proactive stakeholder engagement. Within South Africa, the company is recognized as a responsible corporate citizen, including through proactive, transparent stakeholder engagement. This approach is being extended to PPC’s operations outside of South Africa, namely Zimbabwe, Botswana, Mozambique, Ethiopia, Rwanda, and now DRC. On environmental issues, PPC seeks to work with communities in which the company operates by disseminating environmental management knowledge, by organizing regular environmental stakeholder meetings at all sites, and by communicating transparently and effectively with communities. While PPC has a proactive approach to stakeholder engagement, it would still benefit from developing a consistent corporate policy to this issue, thereby ensuring a more uniform approach at its different locations. Such a comprehensive approach should include establishing standardized approaches to identifying stakeholders, consulting with affected communities about risks and benefits, establishing external grievance mechanisms, and reporting to communities on environmental and social performance.

In addition, PPC seeks to comply with all legal requirements regarding social performance and to act as a responsible corporate citizen everywhere it operates, principally through corporate philanthropy and community investments. It is guided within South Africa by its obligations for increasing company ownership by historically disadvantaged groups under the Black Economic Empowerment Act and through other contributions to community development. In South Africa – in addition to the group’s own corporate social investment (CSI) projects – PPC has developed social and labor plans aligned with Millennium Development Goals. The first five-year cycle of such plans has been completed, and a review was undertaken to strengthen such plans for the 2013-17 period. By engaging actively with communities, PPC seeks to identify and implement sustainable projects focused particularly on infrastructure development, poverty alleviation, and job creation. PPC funds these activities out of a predetermined percentage of profits. As part of its broad-based black economic empowerment efforts in South Africa, PPC has also actively encouraged enterprise and supplier development as part of its preferential procurement efforts. With regard to community development and corporate social investment, PPC has established three trusts for local education/skills training, community development, and partnerships with local construction associations. PPC’s socio-economic transformation efforts in South Africa are guided by a philosophy called REAL, which seeks to ensure that objectives are “relevant, empowering, actualized, and lasting.” This approach is being extended beyond South Africa, and 2013 saw the finalization of CSI strategies for PPC’s Botswana and Zimbabwe operations.

Within the DRC, the project has already begun to engage with local stakeholders through the Barnet Group, the concessionaire for the area to be quarried and the sponsor’s local partner in the project. These initials efforts have focused on dialogue with authorities in the villages to be impacted by the Project most directly, particularly Zamba, and they have yielded a number of signed agreements with this community on land acquisition for the site of the proposed plant and the site for workers’ accommodation during the construction phase. (See above under PS5 – Land Acquisition and Involuntary Resettlement.) Through the involvement of a specialized consultancy in analyzing and managing environmental and social impacts, the project is also putting into place a more structured approach to stakeholder engagement. This has included two rounds of community engagement meetings in October-November 2013, additional meetings with local authorities, government services, and NGOs, and the preparation of a Background Information Document in French and Kikongo. As of March 2014, the following stakeholders have been consulted through this structured approach:

National and local government authorities;
Providers of public services such as electricity, water, roads, health, and education in the project area;
Elders and residents of Malanga, Malanga Gare, Nkumba, and Zamba villages, including separate meetings with women and youth; and
Non-governmental organizations and businesses operating in the region.

Boxes to receive written grievances were installed in late 2013 at visible, accessible locations within the villages closest to the concession. As part of the ESIA process, there are plans for two additional rounds of public meetings (in March and October 2014). In addition, the elaboration of a full ESIA will also yield the following management plans:

Stakeholder Engagement Plan (including grievance management and resolution)
Community Development Plan

Community concerns about the project are primarily reduced air quality, limited water availability, impacts on food security, noise and vibrations, economic displacement, and cumulative impacts. The project is widely welcomed by stakeholders, with development expectations including employment opportunities for local residents and improved infrastructure and services such water, electricity, health, and education. There is a strong need for community expectations to be managed as the project goes forward, and for opportunities for employment and other benefits to be equally distributed among the four villages located closest to the project, namely Zamba, Malanga, Malanga Gare, and Nkumba.

These issues will need to be validated during the full ESIA process in 2014 and discussed further on an ongoing basis throughout the life of the project between the sponsor on the one hand and communities and other stakeholders on the other. As a matter of utmost priority, the sponsor will need to review existing agreements with Zamba, engage in further, more in-depth negotiations if necessary, and conclude a clear and comprehensive agreement with the village regarding land use, land acquisition, and management of potential displacement impacts.

Under the ESAP, PPC will update existing agreements with affected villages and bring them into alignment with PPC corporate approaches and good international industry practice by July 2014. PPC shall request an IFC review of any new or updated agreement with the affected villages prior to signature, and such an agreement will include detailed implementation plans and timetables. In addition, the requirement under its ESMS is that PPC finish developing and begin implementing a comprehensive Stakeholder Engagement Plan and Community Development Plan by October 2014. The Community Development Plan shall include measures to strengthen the capacities of nearby towns such as Kimpese and, if relevant, Songololo to plan for and manage the increased impacts of secondary population influx (e.g. from the establishment of third-party trucking and logistics companies that will service PPC operations).

Disclosure has taken place in late 2013 in the form of public meetings with affected stakeholders as part of the scoping for the expansion of the initial environmental impact assessment to meet IFC requirements. The current ESIA will be presented in public meetings during the month of March 2014 and hardcopies will be available in the affected villages. The additional studies to be carried out in the period up to October 2014 will also be disclosed via public meetings with the affected stakeholders and with hardcopies available locally.

Documents will be available at:
Office of the Chef de Cité
Kimpese
Republic Democratic Du Congo and
PPC Barnet DRC S.A.
Ex Immeuble Chanic
1527 Avenue Col. Mondjiba, Q/Basoko
Kinshasa / Ngaliema
Republic Democratic Du Congo

IFC has determined that there is overall broad community support (BCS) for the project. IFC’s determination of BCS took into account : i) the level of community engagement conducted to date commensurate with the impacts related to the development and operation of the project ; and ii) the review of project documentation and outcome of interviews conducted with key stakeholders within the area of influence. As part of its regular supervision of the project, IFC will verify that the Company conducts an ongoing process of Informed Consultation and Participation (ICP) as per PS1 through the construction and operational phase of the project.

Title	Anticipated completion Date	Status	Comments	Completion Date
PPC will develop a clear social performance policy, approved by its board at the corporate level to, supplement its company-wide Environmental Policy as well as an overall environmental and social policy for its DRC operations, approved at the country board level.	12/30/2014 09:00:00 PM	Completed	Completed	11/27/2014 09:00:00 PM
PPC will complete and publicly disclose the comprehensive Environmental and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP). In addition to the direct project activities, the ESIA and ESMP must address potential impacts / mitigation measures associated with the new power line.	10/30/2014 10:00:00 PM	Completed	Completed	12/04/2014 09:00:00 PM
PPC will finalize and implement a comprehensive Environmental and Social Management System (ESMS) for its DRC project by 31 December 2014, including an ESMP, additional management plans, and specific measures to address the following four items:	12/30/2014 09:00:00 PM	Completed	Completed	12/18/2014 09:00:00 PM
• Expanding and reinforcing its monitoring and reporting system with special regard to its DRC operations, including reporting regularly to communities and other key stakeholders on how risks are identified, analyzed, and mitigated and the progress (or lack thereof) that the company is achieving with regard to mitigating negative impacts and enhancing positive project benefits.	12/30/2014 09:00:00 PM	Completed	Completed	03/04/2015 10:00:00 PM
• Implement an effective external grievance mechanism.	04/29/2014 11:00:00 PM	Completed	Completed	04/24/2014 11:00:00 PM
• Apply a Cultural Heritage Management Plan (with a Chance-Find Procedure) by start of construction.	03/30/2014 11:00:00 PM	Completed	Completed	04/06/2014 11:00:00 PM
• Develop and implement a comprehensive Stakeholder Engagement Plan and Community Development Plan. The Community Development Plan shall include measures to strengthen the capacities of nearby towns such as Kimpese and, if relevant, Songololo to plan for and manage the increased impacts of secondary population influx (e.g., from the establishment of third-party trucking and logistics companies that will service PPC operations).	10/30/2014 10:00:00 PM	Completed	Completed	10/29/2014 10:00:00 PM
PPC will conduct a third-party labor and OHS audit of the EPC contractor’s practices ca. 6 months after the start of civil works under the EPC contract to ensure that the EPC contractor’s labor practices conform with IFC’s Performance Standard 2 and identify any gaps that PPC would need to address.	09/29/2015 11:00:00 PM	In Progress	Due date revised as agreed with IFC client
PPC is required to conduct a third-party audit of labor practices, including those related to occupational health and safety (OHS), for its principal providers of contracted/subcontracted services within one year of the start of full operations to ensure conformity with the IFC’s Performance Standard 2 and to identify any gaps that PPC would need to address.	12/31/2017	In Progress	In Progress
PPC will create an internal action plan by 31 December 2014, based on the Community Health and Safety Plan to be disclosed by 31 October 2014, and develop appropriate partnerships with health authorities, local health providers including NGOs, and other relevant stakeholders to strengthen local health infrastructure and services and to begin implementing such a plan by 31 January 2015. PPC will conduct an audit of progress in implementing this plan by 31 December 2015.	12/31/2015	In Progress	In Progress
PPC will include in its plant design an internal waiting area sufficiently large to accommodate 200-300 trucks per day. This waiting area will be secure and properly provisioned with sanitation, food services, and other small shops so as to minimize if not eliminate the need for waiting truckers to enter nearby villages for such services.	05/30/2014 11:00:00 PM	Completed	Completed	06/21/2014 11:00:00 PM
PPC will carry out a security risk assessment and develop appropriate policies and procedures for managing the project’s use of and relationship with security personnel, whether public or private (including either an in-house or third-party guard force), in accordance with IFC Performance Standard 4.	08/30/2014 11:00:00 PM	Completed	Completed	08/30/2014 11:00:00 PM
PPC will develop a comprehensive approach to land acquisition, compensation, and livelihood restoration for economic displacement as well as provisions for physical resettlement (if necessary in the future). Specifically, PPC will develop and approve a Resettlement and/or Livelihood Restoration Framework to guide the future acquisition of land (including compensation), to manage economic and any physical resettlement that might arise, to secure the replacement of productive land, to provide assistance for restoring and improving productive activities for those affected by economic displacement, and to provide social support networks of all vulnerable affected families.	05/30/2014 11:00:00 PM	Completed	Completed	06/16/2014 11:00:00 PM
PPC will by 31 December 2014 and within one year of any further displacement, whether economic and/or physical, complete a Land Acquisition, Compensation, and Livelihood Restoration Report, including: (a) detailed information on land/properties acquired and to be acquired; (b) socio-economic baseline information of affected owners and their families; (c) impact assessment on the livelihoods of vulnerable or land-dependent families, if relevant; (d) vulnerability analysis and eligibility for assisted resettlement and/or livelihood restoration for individual families, if relevant; (e) evidence of consultations and compensation alternatives offered by PPC; (f) compensation packages agreed upon with each affected village (if common land) or individual families in the event of direct impacts, if relevant; and (g) support given or to be given by PPC for community compensation, resettlement, employment/income restoration, and reestablishment of living conditions, if relevant.	12/30/2014 09:00:00 PM	Completed	Completed	12/18/2014 09:00:00 PM
PPC will conduct all future project-related land acquisition in accordance with the above-referenced Land Acquisition, Compensation, and Livelihood Restoration Framework. In the event that land acquisition for ancillary components (i.e. housing for permanent workforce, access roads, railway spur, etc.) results in economic and/or physical displacement, PPC will prepare a site-specific action plan that conforms with the Framework, a report on the implementation of such a plan, yearly livelihood monitoring reports (if relevant), and a completion audit.	03/30/2016 11:00:00 PM	In Progress	Due date revised as agreed with IFC client
PPC will update existing agreements with affected villages and bring them into alignment with PPC corporate approaches and good international industry practice, including detailed implementation plans and timetables. Any new or updated agreement with the affected villages should be in form and substance satisfactory to IFC.	07/29/2014 11:00:00 PM	Completed	Completed	08/31/2014 11:00:00 PM
PPC will prepare a quarry management and rehabilitation plan including the following distinct items: a: Tentative full quarry utilization plan including tentative final contours, with overburden and top soil application and vegetation. To be ready before production usage of the quarry starts: b: Overburden and top soil storage and reapplication planning. To be ready before the production usage of the quarry starts; c: Five year rolling quarry management and rehabilitation plans including quarry contours, overburden reapplication and top soil needs, and replanting goals: and d: One year detailed quarry utilization, contouring, overburden and top soil application plans, including re-vegetation details and targets. Establish a nursery providing the necessary seedlings for the rehabilitation of plant and quarry areas. Focus should be given to indigenous plants, with special focus on any potentially locally endangered species, which should be favored in the rehabilitation. Establish a quarry pit water control, that allows for all pit water to be controlled for and if needed treated for contaminants, especially ammonia caused by explosives usage, before any discharge to water courses or application to areas which could cause ground water contamination. Establish safety beams along ascent and decent roads in the quarry to provide safety for the haul trucks.	08/30/2015 11:00:00 PM	In Progress	Due date revised as agreed with IFC client
Establish continuous emission monitoring for NOx, SOx, and dust at the main stack and develop and implement an ambient air quality monitoring program with a specific focus on communities. Dec 31, 2016	12/31/2016	In Progress	In Progress
Establish procedures to ensure trucks delivering bulk raw materials to the plant and cement to the customers are not permitted to carry more load than what they are approved for.	12/31/2016	In Progress	In Progress