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
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 according to IFC’s Environmental and Social Review Procedure because of the limited number of specific impacts that may occur are generally site specific, and those impacts can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key issues relate to: i) effective environmental and social (E&S) due diligence prior to project development to ensure alignment of the project with national requirements and IFC’s Performance Standards; ii) development and implementation of an environmental and social management system (ESMS) to ensure effective management of related issues pre-construction, during construction, and operations if applicable; iii) development and implementation of human resource policies and procedures, including that related to occupational health and safety, to ensure compliance of all companies/contractors involved in projects, and notably those involved in direct construction activities, with national requirements and IFC’s Performances Standards; iv) design and construction of the projects in accordance with recognized building standards including that related to life and fire safety; v) management of potential environmental impacts and risks during construction and operations and specifically that related to solid and liquid wastes, hazardous materials handling and community safety; and vi) resource efficiency either through the effective use of resources or the design of buildings to limit energy usage.

Given no specific projects have been identified to date, other than Performance Standard (PS) 1 and PS2 as identified above, no other PS’s are considered applicable at this stage. The PS applicability will be defined on a project by project basis and it can be anticipated that PS1-4 may apply to all projects, though this will be confirmed during the E&S due diligence procedure to be developed as part of the ESMS. This will similarly apply to PS5: Land Acquisition and Involuntary Resettlement, though the ESMS will include a framework approach to land acquisition to ensure compliance with this PS. The applicability of PS6: Biodiversity Conservation and Sustainable Management of Living Resources will also be identified during the E&S due diligence procedure, though if applicable, the approach to addressing related issues will be defined on a project by project basis. The latter will also apply to PS:8 Cultural Heritage and PS:8 Indigenous Peoples, though PS:8 is unlikely to apply to any projects given they will occur in urban areas and the existence of such peoples as defined is limited in Sub-Saharan Africa.

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 need for an environmental impact assessment (EIA) for projects initiated via the Platform will be determined by host country legislation, though the ESMS to be developed for activities associated with the Platform will also require a review of whether a formal independent EIA process is required based on potential project risks and impacts. The ESMS will also require an E&S due diligence procedure to be applied to all projects. The focus of the due diligence will be to identify the applicability of the individual IFC Performance Standards, determine potential environmental and social (E&S) issues and impacts related to the individual Performance Standards and define mitigation measures where necessary. The latter would then be captured in a specific corrective action to be applied to the project assessed. In addition, the E&S due diligence will be undertaken by a suitably qualified independent specialist familiar with IFC’s Performance Standards. The requirements as defined above are detailed in the project ESAP.



Specific aspects to be included in the ESMS and the general approach to projects to ensure such and the associated activities align with the Performance Standards and that E&S risks and impacts are adequately managed and mitigated, are described in the paragraphs below.



Prior to construction any land acquisition and resettlement will need to be aligned with PS5: Land Acquisition and Involuntary Resettlement. The ESMS will include a framework approach to land acquisition and this will then be applied on a project by project basis with the need for specific application thereof defined by the E&S due diligence. The latter will also define the applicability of PS 6: Biodiversity Conservation and Sustainable Management of Living Resources and PS8: Cultural Heritage to individual projects, and the approach to ensure related issues are adequately addressed if need be.



During the actual construction phase typical E&S issues, aside from that related to labor which is referenced in the following section, will include, amongst others, the discharge of contaminated (high silt loads / oil and grease) storm water and diesel and oil spills and solid and liquid waste management. In addition, there is the potential for nuisance impacts (e.g., noise and dust) on adjacent buildings and traffic congestion and safety issues depending on the proximity of the project to other activities. These issues can be managed via development and implementation of a project specific Environmental Management Plan; the requirement for this is defined in the project ESAP.



During construction there is also the need to ensure the application of acceptable building standards including that related to life and fire safety (LFS). Generally CITICC apply Chinese standards to projects and these are adapted to take into account local building standards and other international standards as need be. For the purpose of project development via the Platform,
the building standards and codes to be applied will be confirmed during the E&S due diligence process, including the applicability of these. In respect of the LFS standards, all projects will need to align with national requirements and include two alternative evacuation exits and an early detection and alarm system is required in the case of multi-story buildings. Further, prior to construction, a suitably qualified specialist will be required to confirm the building plans align with the requirements as defined. Once construction is complete, a suitably qualified specialist will also undertake an audit of the project to confirm completion in accordance with the LFS design as defined in the original building plans; if necessary, a corrective action plan will be compiled to ensure alignment with the requisite plans. The requirements as defined above are included in the project ESAP.



The approach to ensuring projects are completed in accordance with the original design will be determined on a project by project basis in that it may vary as there could be local/country partners in place, and equally local companies other than CITICC could be responsible for design etc. CITICC though has five committees responsible for overseeing the company’s activities one of which is the Risk Management Committee. Via this committee and the associated department, a risk management policy and approach is defined for each project and this includes the specific approach to quality management which includes ensuring a project is completed in accordance with the design criteria. The latter includes support via experienced CITICC technical personnel on the ground and involved in the day to day to day activities associated with the project. Quality management also includes application of specific procedures to ensure the suitable quality of building materials purchased. Thus where CITICC is the EPC contractor, their risk management policy and approach will apply.



A key component of the design process will also be identifying and implementing opportunities to reduce resource consumption and increase energy efficiency associated with projects. IFC’s Green Building Specialist has been in discussions with CITICC to confirm the approach to this issue and is in the process of identifying key green technologies and specifications that will be applied to all projects developed via the Platform. These will be defined in the Platform’s ESMS and the requirement is defined in the project ESAP.



During operations key E&S issues relate to the provision of potable water, the treatment and discharge of sewerage. The approach to these issues will be identified in the E&S due diligence, however there will be the requirement for the treatment of potable water and sewerage prior to discharge to ensure compliance with the requirements of the WBG EHS Guidelines. Further, given the unreliability of power supply in some Sub-Saharan countries, projects will likely requir
e backup generators and thus fuel storage will need to be managed with adequate containment.



The specific approach to managing E&S impacts during the construction phase have been defined above, while during operations this will be project specific in that the Platform may or may not be involved in this aspect. The ESMS will though define the approach to be adopted in compilation of management plans for the operational phase.



CITICC’s 5 committees and associated departments that manage the company’s activities include Budget Performance, Contractor and Performance, Safety Management, Risk Management and Control Management. Via these CITTIC control all aspects of the any particular construction project they are involved in. Currently and given that no specific projects have been identified as yet, the extent to which the focus areas of these committees would apply to projects undertaken by the Platform would still need to be defined. However, as previously noted the company has extensive experience and skills in construction projects and will apply these as need be to ensure projects are completed taking into the necessary quality related aspects. Insofar as implementation of the ESMS and oversight of E&S issues at a project level is concerned, the Platform will be required to nominate a representative responsible for such aspects. Further, the E&S due diligence will define the extent to which additional resources are required to manage E&S issues during individual projects based on the findings related to potential risks and impacts.



Upon development of the ESMS which will be completed prior to commitment of IFC to the investment, staff directly involved in the Platform whether from CITICC, IFC or other organizations will be trained on implementation of the management system including the E&S due diligence procedure.



Monitoring requirements will be defined in the project specific EIA and via the E&S due diligence procedure. During construction this would relate primarily to the Environmental Management Plan developed for this phase and equally include any feedback on the corrective action plan compiled as part of the due diligence if applicable. Monitoring during the operational phase would depend on whether the Platform is involved in this aspect or not. In the event this does apply, aspects to be monitored and reported on would include potable water quality and the discharge quality of treated sewerage. Further, there may need to be reporting requirements associated with the life and fire safety system and aspects related to the management of contractors providing services on site.



As part of the ESMS a generic stakeholder engagement plan will be compiled to be applied to all projects and this will define the approach during preconstruction, construction and in operations if applicable. The latter will also include a grievance mechanism to be applied. This stakeholder engagement plan will be applied during the
EIA if applicable and amended according to the project requirements. Similarly the plan will be applied during construction and operations and modified according the specific project requirements if necessary. These requirements are defined in the ESAP.

CITTIC employ approximately 1,000 people of which some 250 who provide technical services such as project management, design management, construction management, quantity survey and management of commercial aspects. Of the remaining staff, these are involved in human resources, finance, procurement management, marketing and business development and there are some 80 interpreters. As defined above, the extent to which CITTIC employees would be involved in projects will be determined on a project basis. Regardless though and as outlined below, they will be subject to the human resource requirements associated with the Platform.



The Platform will employ staff though this will be limited to business development personnel and technical staff to support specific projects. However, the Platform will not employ any staff associated with the actual construction activities. As defined in the project ESAP, the Platform will develop a specific human resources policy and procedures to be applied to staff they employ along with any OpCo’s such that this aligns with the requirements of this Performance Standard. Furthermore, inclusive in the procedures will be the approach to ensuring all contractors involved in construction activities also comply with this Performance Standard and national legislation as applicable. Equally, the procedure will also define the approach to ensuring those providing ongoing services e.g., cleaning, to projects during the operational phase also comply with the Performance Standard. Such procedures will also define how the Platform will undertake ongoing monitoring to ensure compliance as stipulated above.



The primary focus of occupational health and safety (OHS) will be during the construction phase as during operations such risks will be limited. As defined in the ESAP, all contract documentation will require contractors to align their OHS practices with the requirements as defined in the PS’s and specifically that defined by good industry international practice (GIIP) and the WBG EHS Guidelines. Equally, contractors will need to include their OHS plans in contract documentation submitted for purposes of being awarded the project and this will need to include the approach to ensuring related subcontractors align their OHS practices with the PS requirements and ongoing monitoring requirements to support such. Prior to contract award, the individual responsible for E&S related issues at the Platform will need to review the contractors OHS plan to confirm it aligns with the requirements defined above.



Once the contract has been awarded on any specific project, there will be an independent review within six months of the start of construction to confirm contractors / subcontractors are complying with the agreed OHS plan. In addition, the latter audit will also confirm contracting companies approach to the management of human resources is compliant with this PS and national legislation. The requirement is defined i
n the ESAP.



For purposes of operations, contractors will also be contractually bound to comply with the PS requirements and submit their OHS plans to the Platform for sign off prior to being appointed.

As no specific projects have been identified for development by the Platform to date, there is no information on community engagement currently. Community engagement pre development will be undertaken via the EIA’s and where these are not specifically required, the need for such will be determined via the E&S due diligence; equally the stakeholder engagement plan to be compiled for this specific component will also define the approach. The latter also applies to the construction and operational phases.

Mr. Xu Mingguang
18/F Tower A, TYG Center
C2 Dongsanhuan Beliu
Chaoyang District
Beijing
China
Tel: +86 10 59660308
Email: mailto:xumg@citic.com
Company website: http://www.cici.citic.com/

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop and implement an Environmental and Social Management System (ESMS) for the Platform aligned with the requirements with IFC’s Performance Standards. Specific requirements associated with the ESMS will include the following: Include a due diligence procedure to be applied to projects that; i) defines the applicability of the Performance Standards (PS) to projects, ii) determines environmental and social (E&S) risks and impacts as defined in the PS’s that apply to projects during preconstruction, construction and operations (if applicable); iii) identifies the applicable building codes and standards that will apply to the project and extent to which these are considered acceptable; iv) defines the need for an Environmental and Social Impact Assessment for the project where such is not required by national legislation; v) includes a project specific Environmental Management Plan to be applied to the construction phase of the project; v) a corrective action plan where applicable to ensure individual projects comply with the Performance Standards and World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines during the respective project phases; and vi) defines the need for independent monitoring of E&S impacts during construction and extent thereof.	11/30/2014
Appoint an independent suitably qualified Consultant specifically to undertake project due diligence in accordance with the Platform’s due diligence procedure as defined in the ESMS.	04/30/2015
Include within the ESMS a framework approach to land acquisition that will ensure compliance with PS5: Land Acquisition and Involuntary Resettlement	11/30/2014
Include within the ESMS a generic stakeholder engagement plan and grievance mechanism to be applied to projects during all respective project phases.	11/30/2014
Define in the ESMS the typical green building standards that will be applied to projects where feasible.	11/30/2014
Undertake training of all staff in the Platform on the requirements associated with implementation of the ESMS.	04/30/2015
Appoint a suitable representative in the Platform to be responsible for oversight and implementation of the ESMS	11/30/2014
Engage a suitably qualified specialist to confirm the life and fire safety plans for individual projects align with the applicable national requirements and include two alternative evacuation exits. All multi-storey buildings are also to include an early detection and alarm system.	04/30/2015
Following project construction and prior to occupation of buildings associated with projects, engage a suitably qualified specialist to audit project completion against the original life and fire safety plans as defined in No. 8 above. Based on the audit findings, implement a corrective action plan if necessary.	12/31/2015
Develop and implement a human resources policy and procedures aligned with the requirements of PS2: Labor and Working Conditions that will apply to all personnel employed by the Platform. This procedure will define the approach to ensuring that all contractors (in construction and operations) comply with the requirements of PS2 and national legislation as applicable. In addition, a procedure will be defined that details the approach by the Platform to ensure ongoing compliance by contractors with PS2.	12/31/2014
Include the requirement in contract documentation for contractors (construction and operations) to comply with the conditions related to occupational health and safety (OHS) as defined in PS2 i.e., that associated with Good Industry International Practice (GIIP) and the WBG EHS Guidelines.	12/31/2015
Include the requirement in contract documentation for contractors to include their OHS plans in submission of contracts prior to contract award. The OHS plans are to include the approach to ensuring subcontractors comply with the PS requirements, and how monitoring associated with this will be undertaken. The designated Platform representative responsible for the ESMS implementation will sign off on the OHS plans confirming compliance.	12/31/2015
Within six months of a project commencing construction, undertake an independent audit by a suitably qualified specialist to confirm compliance of contractors / subcontractors with the requirements of PS 2.	12/31/2015