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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

All the manufacturing facilities are located in industrial areas. The production processes involve mainly mixing and consume a limited amount of energy, and little water. Most of the wastes generated are recycled and air emissions are mainly dusts from mixing/packaging and are readily scrubbed. Most of the expansions are located within the existing properties and in case of small pieces of land needed for expansion, Mapei only purchases land inside established industry zones. The operations have the potential for very limited impacts to the communities outside of industry zones.

The key E&S risks and issues relate to; i) occupational health and safety; ii) solid wastes recycling and management; and; iii) road transportation and community safety.

Mitigation measures for the potential E&S impacts have been identified and are incorporated into the Environmental and Social Action Plan (ESAP). The potential adverse E&S impacts of this project are therefore few in number and limited to project sites, and may be readily mitigated. This is therefore an E&S Category B project.

Most of the expansions are within existing properties and if any small portions of land are purchased for new facilities, they will only be purchased from within existing industry zones on a willing-buyer/willing-seller basis. Thus PS5: Land Acquisition and Involuntary Resettlement is not applicable and neither is PS6: Conservation and Sustainable management of Living Resources. There are no Indigenous Peoples in the project areas and further given the location of the facilities, PS8: Cultural Heritage is not considered applicable to the project.

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.

1. Assessment and Management of Environmental and Social Risks and Impacts

Corporate Environmental and Social Policy: Mapei has an EHS policy as specified in its Code of Ethics. According to the policy, Mapei considers the health and safety in the workplace as one of the employee’s fundamental rights and as a key element for Mapei’s sustainability. All decisions made by Mapei must respect health and safety in the workplace. The company also undertakes to continuously improve the environmental performance of its production processes and to meet all the key legislative and regulatory provisions regulating this matter. Besides its EHS policy, Mapei also has its own EHS and technology standards, which are compliant with Italian and European Union regulatory requirements.



Mapei starts the development and extension of an effectively certified environmental management system (EMS) based on the fundamental principles of minimizing environmental impact and optimizing the use of resources. All Mapei facilities, except those newly acquired, have ISO 9001 certification. 15 facilities in developed countries are ISO 14001 certified and 8 facilities in developed countries are OHSAS 18001 certified. Currently Mapei is focusing on obtaining ISO 14001 and OHSAS 18001 certification for all key facilities in developing countries. Ultimately though and as required by the E&S policy, Mapei plans to obtain certification for ISO 14001 and OHSAS 18001 for all facilities. The certification process and dates will be planned by the proposed new environmental department.



Identification of Risks and Impacts: Mapei aims to increase its production through both capacity expansion of existing facilities and merger/acquisition/ (M&A) for new facilities. Mapei has a strict E&S procedure for M&A whereby they only purchases existing facilities within established industry zones. For greenfield facilities, Mapei only purchases land from existing industry land owners on a willing buyer/willing seller basis.



For M&A, Mapei contracts external experts to conduct Phase I and Phase II site investigations. Where major soil/groundwater/equipment contamination is identified, Mapei does not proceed with the M&A. In case of minor contamination, Mapei requires the seller to remediate all contamination to Mapei standards prior to the M&A. For new and expansion projects, Mapei conducts environmental and social impact assessments (ESIA) according to local regulatory requirements. For all new projects, these are built on a best effort basis according to Mapei technical standards which are compliant with Italian and EU standards. For this investment, Mapei is also committed to complyiong on a best effort basis with IFC Performance Standards (PS1-4) and applicable World Bank Group (WBG) EHS Guidelines for all projects in -emerging market countries.



Corporate Environmental and Social Management and Organization: At the current stage, Mapei’s EHS management is under the Global Operatio
ns Department (GOD), located at its largest manufacturing facility in Mediglia, Italy. The GOD Director reports directly to the Mapei president. Central Engineering and Operational Safety teams in the GOD are responsible for environmental and occupational health/safety (OHS) management across Mapei. There are dedicated EHS engineers in GOD’s Operational Safety team for major EHS issues. However, all the other engineers also take responsibility for routine EHS issues. Mapei shall endeavor to establish a Health Safety and Environment Unit (HSEU) capable of overseeing EHS matters across the corporation.



At large facilities dedicated EHS manager/engineers are in charge of daily EHS performance on-site and report directly to the facility general manager with dotted reporting lines to GOD (to HSEU in the future). At smaller facilities onsite engineers are in charge of routine EHS performance and report directly to the facility manager with a dotted reporting line to GOD (to HSED in the future).



EHS training is required for all new employees and all new employees are required to pass different levels of examinations, based on the specific positions, before allowed to work onsite. All the employees working in the manufacturing processes take different levels of annual EHS refresher courses based on their positions.



The E&S requirements are included in all purchase contracts for major suppliers which require the major suppliers E&S performance to meet all local regulatory requirements and applicable Mapei EHS and technical standards. GOD conducts routine audits of E&S performance on all major suppliers.



Emergency Preparedness and Response: According to Mapei technical standards, all the manufacturing buildings and warehouses are equipped with fire detectors and sprinkler systems. Certified reliable firewater pumps are adopted and there should be enough water storage for approximately 2 hours of firefighting. At large facilities, there are part-time internal firefighters who undertake monthly trainings. All Mapei facilities are located inside existing industry zones and local professional fire brigades are also available. Emergency response plans are prepared at each facility. Each facility convenes one or two fire/emergency response drills per year depending on the operational risks. There have been no major accidents and emergency response incidents in the past few years of operation.



Monitoring and Review: The GOD keeps in daily contact with all production facilities. Online conferences are held whenever necessary. Each facility reports EHS quarterly to GOD. Mapei is working on a corporate wide intranet site for EHS performance which will allow GOD (or HSEU in the future) access to the EHS performances at each facility in real time. In case of non-compliances identified in the quarterly reports, the corrective action is proposed and documented for the future review of the implementation.



Besides self-reporting, GOD engineers (or
HSEU in the future) also conduct routine EHS and technical inspections according to both local regulatory requirements and Mapei EHS and technical standards. For critical facilities, up to six inspections are conducted with focus on recent key findings per year and for simple facilities, at least two inspections are conducted per year. The non-compliances and corrective actions are recorded in the inspection reports submitted to GOD management. The implementation of corrective actions are reviewed during future inspections. In line with the ESAP for this investment, Mapei will on a best effort basis permit an IFC visit and assessment of the EHS performances at Vinalvil Egypt S.A.E. according to local regulatory requirements, Mapei EHS/technical standards, and good international industry practices.

Corporate Human Resources Policy and Management: Mapei has a corporate human resources (HR) policy that requires all its subsidiaries to set up HR procedures following local labor laws. Mapei corporate HR policy also requires all subsidiaries to comply with the general principles of freedom of association, privacy and equal employment opportunities. The HR procedures include the terms of employment and working conditions. These include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, vacation, other leave, and retirement. Mapei has HR policy training that is part of the new employee induction, and all employees have access to this policy. Mapei HR policy, where applicable, also applies to the contract labor at all Mapei facilities. For purposes of construction, the company will on a best effort basis ensure that the associated contractors comply with the labor and working condition requirements .



Working Conditions and Workers’ Organization: The employment terms at each facility strictly follow the local labor laws, while the corporate HR policy also specifies key principles for working conditions, such as compensation levels, employment terms, overtime management, etc. Mapei supports freedom of association and works with unions for related labor issues. In case of absence of unions in some facilities, Mapei also allows collective bargaining from employees.



Non-Discrimination and Equal Opportunity: The HR policy specifies non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All hiring and promotion are merit-based. When candidates have equal qualifications, preferences of hiring are given to local residents and females. Currently, 18% of Mapei management team, including facilities in emerging market countries, are female.



Retrenchment: Currently Mapei has more than 7,000 employees worldwide, in which approximately 25% are in emerging market countries. Retrenchment is not expected for this investment. An undetermined number of employees will be hired for the expansion in the emerging market countries, plus construction labors through contractors.



Grievance Mechanism: Grievance mechanisms are introduced during the new employee induction. The employees can report their grievances to either HR managers or union labor leaders. All the grievances and the mitigations are recorded. Anonymous grievances are also allowed in Mapei. The HR managers/union leaders shall report to the senior management if they are unable to solve a grievance. Mapei ensures all employees have direct access to responsible senior manager without limitation for grievances.



Protecting the Work Force: Mapei has a corporate policy to forbid hiring of workers below the age of 18 years and forbid forced labor. HR checks birth and school certificates during the hiring process. Mapei has a strict labor
audit procedure for its major suppliers, as a part of supplier audit program, to ensure no child or forced labor is used at major suppliers and the occupational health/safety performances of the major suppliers meet all local regulatory requirements and applicable Mapei standards.



Occupational Health and Safety (OHS): Mapei has routine OHS training, including new employee training and annual refreshers. There have been no fatal or serious accidents in the past three years. Personal protective equipment (PPE) is sufficient at each facility and enforced strictly. Recordable accidents and workplace air/noise are monitored at each facility and reported to GOD (or HSED in the future) every quarter.

Corporate EHS Performance Management and Compliances: There is little wastewater generated at most of Mapei’s manufacturing facilities. The only wastewater stream, the cleaning water, is recycled back to the production process. In case of small quantities of wastewater generated at some facilities, it is sent to licensed waste management facilities for treatment and disposal. The sanitary wastewater is discharged to the municipal sewer system or disposed at the on-site septic tanks. The main air emissions are dust from the power products manufacturing processes. Each facility is equipped with dust scrubbing installations to insure compliance with both local and Mapei EHS/technical standards.



Besides its EHS policy, Mapei also has its own EHS and technology standards, which are compliant with related Italian and EU standards. All the Mapei facilities meet local EHS regulatory requirements and most of the Mapei facilities are compliant with the internal standards. For this project and in accordance with the ESAP, Mapei shall endeavor to comply with local standards and achieve Mapei standards in line with WBG EHS Guidelines for the manufacturing facilities in Turkey, China, and Malaysia.



Solid and Hazardous Wastes: The sanitary wastes at all facilities are collected by municipal contractors for disposal. Some 95 – 99% of the industry waste (collected dust or waste liquids) are recycled back to the production. In case of small quantities of solid wastes or waste solvents in some facilities, they are sent to licensed waste management facilities for treatment, recycle or disposal.



Greenhouse Gases (GHG): Limited energy was used for the mixing manufacturing processes at Mapei. After the expansion in Egypt, Mexico, Panama, India, Turkey, China, and Malaysia, Mapei will generate approximately 2,500 tonnes of CO2-equivalent GHG annually, mainly from electricity purchase and vehicle fuels.

Community Health, Safety and Security: There are communities near some of Mapei’s warehouses/distribution centers. The normal operations at Mapei have limited impacts to the communities nearby. Majority of Mapei’s raw materials and products are transported by trucks. Mapei only allows trucks with qualified insurance and licenses to enter its property for loading/unloading. The road conditions at the project countries are satisfactory.



Security Personnel: Mapei hires external agencies for facility site security that conducts routine ID checks at the gates and security monitoring. The security guards have no weapons and report to the local police stations for serious security issues.

During M&A or new expansion project, Mapei will consult neighboring industries in the industry zone and the nearby communities. According to the local rules, Mapei also discloses where applicable the related ESIA’s to nearby communities and the contact information for each facility for the community to report any grievances. All the grievances and responses/actions are recorded. In accordance with the ESAP, Mapei shall on a best effort basis standardize across all operations its practice of ESIA’s disclosures to the community and contact procedure to report any grievance. Mapei also supports local sports events and use the sports events as a way to reach out the communities.

This document will be disclosed as applicable in the relevant local language on the project site related to this investment. For inquiries or concerns about the environmental and social impacts of this project, please contact:

Mrs. Veronica Squinzi
Global Development Director
Mapei S.p.A.
Viale E. Jenner 4
20159 Milano, Italy
Phone: +39 02 37673347
Fax: +39 02 37673214

Broad Community Support is not applicable for this project

Mapei(34144) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
1.  Will sustain on a best effort basis an effective corporate EHS management structure.	31-Dec-2014	Completed	Completed	8/6/2015
2.  Arrange IFC visit to the Vinalvil Egypt S.A.E. plant.	31-Dec-2014	Completed	Completed	7/31/2014
3.  Will maintain on a best effort basis community engagement across all the operations	31-Dec-2014	Completed	Completed	6/29/2017
4.  Maintain on a best effort basis labor and working conditions for construction contractors based on local and where applicable on Mapei standards.	31-Dec-2014	Completed	Completed	8/6/2015
5.  Maintain on a best effort basis local and Mapei standards where applicable for its plants in Turkey, China and Malaysia.	31-Dec-2014	Completed	Completed	8/6/2015