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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
There are no Indigenous Peoples located within the project area, hence PS 7 is not considered applicable. No cultural heritage has been identified within the existing railway corridor, hence PS 8 is not considered applicable to this project, and although a chance find procedure will be developed under PS 1.

This proposed investment has been categorized B as it mainly involves refurbishment of existing assets and infrastructure within an existing (brownfield) footprint. The IFC use of proceeds will be directed at activities which are intended to make the company and its assets cleaner and safer for staff, communities and the receiving environment. Key environmental and social issues include pollution control (in particular effluent and sewage treatment), provision of potable water to workers, waste management, construction controls in protected areas, resettlement of illegal settlers and community safety. Of these, the most significant adverse impact is likely to be resettlement of persons living or conducting business (illegally) within the railway safety corridor.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System



Setrag is a subsidiary of the Eramet Group which has a Sustainable Development Policy, an Environmental Policy, and an Ethics Charter. The Sustainable Development Policy includes provisions on managing risks and impacts on health and environment specifically related to mining activities, stakeholder engagement, capacity building, resource efficiency, responsible supply chain management (in line with the European Regulations on registration, evaluation, authorization, and restriction of chemicals), and economic development of communities. The Environment Policy includes provisions related to mitigating impacts, continuous improvement, compliance with laws and regulations, information system in environmental performance, and scientific knowledge management. As outlined in ESAP action # PS1 1.a, Setrag will develop and implement its own environmental and social policy.



An external environmental audit mandated by Setrag was conducted in 2008 by the firm URS France. The audit included Setrag’s three maintenance sites (Owendo, Booué, Franceville). This audit revealed that none of the sites had the Ministry of Environment license to operate. A formal regularisation request was then transmitted to the Ministry of Environment for the Owendo facility. Similarly same requests were planned for the two other maintenance sites.This performance standard requires clients to comply with host country regulations. Setrag will obtain environmental license to operate at all sites as set forth in ESAP action # PS1 1.b.



Setrag has EHS procedures that partially cover the range of risks and impacts inherent to railway transport activities. One of the impediments to the efficient management of E&S risks and impacts is the lack of a unified organizational structure. Environment, quality, railway safety and police are under the responsibility of the Quality, Health, Safety, and Environment (QHSE) Department. Waste management is under the supervision of the General Services Department. Railway safety is under the Traffic Department, and enforcement of the Hazardous Materials Transportation Regulations is under the Trade Department.



As set forth in ESAP action PS1 1.a Setrag will establish and maintain an Environmental and Social Management System (ESMS incorporating the following elements: (i) policy; (ii) identification of risks and impacts; (iii) management programs/procedures; (iv) organizational capacity and competency; (v) emergency preparedness and response; and (vi) monitoring and review. The ESMS will be streamlined integrating and harmonizing management programs that are currently under other departments than QHSE (e.g. General Services, Traffic, Trade). Emphasis will be put on the following gaps: reduction of fuel consumption, fuel management (e.g. secondary containment), wastewater management, hazardous and non-hazardous waste management, and occupational health and safety from rail operations
. A Stakeholder Engagement Plan and a chance find procedure will also be developed and implemented as part of the ESMS.



For each of the construction sites of this specific project, Setrag will develop and implement an Environment, Health and Safety Action Plan incorporating health and safety training for all workers and contractors, coordination with the doctor and other staff to analyze safety incidents and illnesses and propose prevention measures, hazardous and non-hazardous waste management and resources monitoring systems, and an emergency preparedness and response plan.



Identification of Risks and Impacts



Many external and internal environmental audits have been undertaken for the railway (e.g. covering rehabilitation of workers accommodations, refurbishment of maintenance workshops, wastewater treatment), but no Environmental and Social Impact Assessment has ever been conducted because railway construction started prior to the adoption of the Environment Law dated August 26, 1993 (the first section of the railway having been built in 1978). For this refurbishment project, Setrag developed an Environmental and Social Audit (January 2015), an Environmental and Social Management Plan (''''PGES'''' dated March 2015), a Resettlement Framework (March 2015), and a Biodiversity Action Plan (March 2015), all of which are disclosed as attachments to this review summary.



The project footprint does not exceed the existing railway corridor. Sources of impacts associated with this project will include use of machinery and transportation, presence of workers (maximum of 10 teams of up to 40-50 workers at each construction site), storage and disposal of hazardous materials including used sleepers, construction and refurbishment of buildings and infrastructures. Main impacts are as follows: soil erosion, air and water pollution, noise, vegetation removal, waste production and contaminated sleepers, occupational health and safety, community health and safety, management of chance finds and resettlement of illegal settlers.



Gabon is very rich in terms of biodiversity. Tropical forests cover 85% of the country. According to the Convention on Biological Diversity Country Profile, it has 600 bird species, 150 mammals, and 8,000 plants with an endemism rate of 20%. The railway runs through natural habitat for about 80% of its length and passes through the Lope National Park (for 62 km), a World Heritage Site, the Bas Ogooué Ramsar Site (for 56 km), and the Rapides de Mboungou Badouma Ramsar Site (for 30 km). Lope National Park qualifies as a critical habitat based on criteria 1 (Critically Endangered and/or Endangered species) and 2 (Endemic and/or restricted-range species). The other two areas are also potential critical habitats for which assessment is ongoing.



In 2008, Setrag signed an agreement with WWF and the Ministry of Waters and Forests to collaborate in anti-poaching patrols in the railway corridor; to undertake awareness raising of Se
trag staff, train users, and local communities about wildlife species; and to carry out patrols of trains, workers’ camps, railway stations, and associated facilities. Bush meat (i.e. illegal venison) confiscated during those anti-poaching patrols is monitored and documented.



As the project entails refurbishment of existing infrastructure within an existing (impacted) corridor, no incremental adverse impacts on biodiversity are anticipated once basic management system procedures are implemented (e.g. anti-poaching policies), no net loss of biodiversity in natural habitat is expected and the project is not expected to lead to measurable adverse impacts on those biodiversity values for which the critical habitat was designated, and/or on the ecological processes supporting those biodiversity values. Nevertheless, as part of the project impact identification process required by IFC, Setrag drafted a Biodiversity Action Plan (January 2015, attached) in consultation with the Gabonese National Park Agency, the Ministry of Water and Forests responsible for anti-poaching patrolling, and NGO WWF. This plan includes management measures to mitigate potential for increased rail traffic and potential for retrofitting wildlife-friendly mitigation (crossings, speed controls). This issue is discussed further in PS 6, below, though management of potential impacts (largely control of poaching and contractor management within protected areas) will be dealt with under the (PS 1) ESMS and related procedures.



Organizational Capacity and Competency



Setrag has a QHSE Department with 14 staff, including a QHSE Manager, 4 EHS Officers, 4 Quality Officers, and 5 Train Safety Officers. Railway police (105 staff) are also managed by the QHSE Department. For this refurbishment project, as set forth in ESAP action # PS1 2.a, Setrag will hire a specific team responsible to oversee the implementation of the EHS management program outlined in the Environmental and Social Management Plan, the Resettlement Framework (and subsequent Resettlement Action Plan), and the Biodiversity Action Plan. At a minimum, Setrag will hire a Senior EHS Officer and one assistant, one Social Specialist, and 2-3 EHS Officers responsible to supervise the different project worksites. The Senior EHS Officer will be responsible to develop the overall ESMS and site-specific EHS Action Plans.



The QHSE department offers a range of training programs. For example, in 2014, 1,200 workers were trained in first aid level 1. Every year, about 100 workers are trained in fire-fighting and prevention. Thematic occupational health & safety training is provided to all workers every year (e.g hazardous materials handling, work in height), and use of personal protection equipment. Training is also provided within the department on the management of Eragreen, Eramet Group’s environmental data base that allows for monitoring and reporting on matters such as energy and water consumption, air emissions and waste
production. Specific annual training is provided to Safety Chiefs responsible for the safe movement of trains at the stations and to Regulators who are responsible for the safe operations of trains along the entire corridor. The train drivers and their assistants are also trained each year. They are also subject to continuous training and supervision.



Emergency Preparedness and Response



Setrag relies on an Emergency Preparedness and Response Plan (‘’Plan Fer’’) in case of emergency scenarios such as natural disasters, fire, explosions, oil and hazardous materials spills, train accidents, terrorism or vandalism. The plan includes the identification of areas where accidents and emergency situations may occur, response procedures, provision of equipment and resources, designation of responsibilities and communication, including that with potentially affected communities. It does not include provisions on periodic training to ensure effective response. As outlined in ESAP action # PS1 3.a, the plan will be updated to include specific training and practice (i.e., simulations and drills), schedules and equipment requirements for employees who are responsible for rescue operations, medical duties, threat and incident responses (e.g., hazardous material spill response), and firefighting and other responses specific to project sites, facilities and activities.



Monitoring and Review



Setrag reports on Key Performance Indicators to monitor energy and water consumption, air emissions (e.g. SOx, NOx, CO2, metals), hazardous and non-hazardous waste, etc. Information is compiled in a data base (Eragreen) and annual reports are drafted. Lost Time Incidence Frequency Rate (LTIFR) and accident free days are compiled in a specific data base (Eralink) and reported monthly. Customers and community complaints are also managed and documented. The company will also report annually to IFC as part of the Annual Monitoring Report (AMR).

Human Resources Policies and Procedures



Setrag’s organizational structure has 3 levels: managers (c. 15%), supervisors (c. 60%) and workers (c. 25%). In 2014, Setrag had a total of approximately 1,270 employees (among which 186 are women), with 184 management positions (31 women and 153 men). Most of the employees have open ended contracts. Setrag also hires many third party contractors providing services such as health, water management, electricity production and distribution in railway stations and worker accommodations, railway repair and maintenance.



Human Resources are managed according to an HR Internal Regulation (‘’Règlement intérieur’’ in line with the Gabonese Labor Law no 3/94, of 21 November 1994). This Internal Regulation has documented procedures for hiring, selection, disciplinary practices and termination, and terms of employment (wages, benefits, working hours, overtime, rest days, breaks, and leave). Working conditions and terms of employment are specified in the written contracts signed by employees, provided and communicated to employees during induction. As specified in ESAP action # PS2 1.a, Setrag will include in its HR Policy provisions with regards to non-discrimination and equal opportunity, child and forced labor, a worker grievance mechanism (including procedures for harassment), supervision of workers engaged by third parties, and supply chain. Setrag will ensure that contracted workers have access to a grievance mechanism. In cases where the third party is not able to provide a grievance mechanism the client will extend its own grievance mechanism to serve workers engaged by the third party.



Working conditions and terms of employment



Setrag complies with all national legislation limits related to working days per week, rest days and leave. The minimum salary (150,000 CFA) paid by Setrag is about 20-30% higher than the minimum wage in Gabon. In addition, each employee is eligible to the ‘’Caisse nationale de sécurité sociale’’ (i.e. social security cover) in case of illnesses, work accidents, and retirement. Setrag provides also a supplementary private health and life insurance. Normal working hours begin at 07:30 and last until 15:30 and do not exceed 48 hours a week and 12 hours overtime a week.



Workers’ Organization



Setrag is represented by 8 unions with a total of 40 representatives representing most direct workers. According to union representatives, recurring issues raised by staff are mainly potable water, lodging, recruitment, discrimination, and harassment in the work environment. Union representatives are selected every three years and Setrag enters collective bargaining with all unions. The current collective bargaining agreement was signed in December 2011 and is valid for an undetermined period of time and can be reviewed no sooner than December 2014.

Occupational Health and Safety

Setrag has an OHS management system which addresses some of the key aspects, including work hazards
, work with heavy machinery and accidents statistics which are recorded on a monthly basis and compiled in an annual report to management. On average over the past 3 years, the recorded Lost Time Injury Frequency Rate is about 8 accidents per million hours, as compared to an internationally acceptable benchmark rate for railway transportation of 6.5. A procedure for the use of PPE was drafted and approved recently by management. There are about 130 staff trained in first aid and the objective is to finalize this training covering all staff by the end of 2015. About 100 staff are trained in Life and Fire Safety each year. Setrag has a large medical center in Owendo with 3 medical doctors, 2 nurses, 1 pharmacy, and a laboratory. Many of the railway stations have a nurse on site (8 nurses in total). As set forth in ESAP action # PS2 2.a, Setrag will provide access to clean drinking water and sanitary facilities in all operational areas. Adequate places to eat and rest areas will also be provided as well as building of separate lockers for men and women at the Owendo site and at all railway stations.

As outlined in ESAP action # PS2 2.b Setrag will commission an independent review of its current Occupational Health & Safety (OHS) management system. The review will determine the extent to which the system complies with the requirements of this Performance Standard and good international industry practice. In the short term this will focus on the refurbishment project and will be expanded to the rest of operations at a later time. Based on the audit findings, Setrag will agree with IFC on a time based corrective action plan if necessary. As indicated above, Setrag will also develop a specific HSE Management Plan for operations as part of its ESMS with specific performance indicators to be monitored and reported to improve OHS performance.

Worker accommodation is provided at a few railway stations. The number of houses varies from 66 in Lastourville to more than 300 in Booué. Most houses date from the 1970s and are in need of refurbishment. Most common complaints relate to sanitary facilities, potable water availability/quality, poorly maintained infrastructure and waste management. This project will include the construction and/or refurbishment of up to 300 houses for workers. To be in line with requirements of PS2 as set forth in action # PS2 2.a of the ESAP, Setrag will develop and implement a set of standards and a plan for establishment and maintenance of worker accommodation and services. These standards will be compliant with the IFC and the European Bank for Reconstruction and Development (EBRD) Guidance Note on Worker Accommodation Process and Standards (2009).

Resource Efficiency



Setrag’s rolling material includes 25 locomotives, 831 wagons, and 56 passenger trains. It includes also about 90 road vehicles (on rental). Annual electricity consumption is 65,000 kWh, and water usage is around 330,000 L. Locomotives gas oil consumption is 5,434,000 L; and 1,227,000 L for vehicles; 55,000 L of gasoline is used for vehicles. GHG emissions amount to circa 16,000 CO2 t equivalent per annum. The following actions have been implemented to reduce energy consumption: acquisition of 6 new locomotives, development of a transport plan, and the use of solar panels for lighting in railway stations.



Water Consumption



Water is provided by the ''''Société d’énergie et d’eau du Gabon'''' (SEEG/Veolia) near urban centers. In railway stations, boreholes provide most of the water which was managed by Mika Services in 2014. Many of the sites have issues with water quality and quantity (in Lastourville, high manganese concentration; insufficient quantity in Booué and Ndjolé). Potable water analysis showed also bacteriological contamination in Lastourville and Abanga. Moreover, some stations have water treatment systems (filtration, chlorination), but do not seem to be run properly. To be in line with requirements of PS3 and WBG EHS General Guidelines as set forth in ESAP action # PS3 1.a water will be treated to WHO standards in all the sites and a potable water monitoring program will be implemented.



Wastes



Waste management is a major issue in most Setrag sites. In Owendo (Libreville), Gabon Propre Service collects solid waste once every two days and has a plan to build a recycling center. Used oil is collected by CimGabon and used at their cement factory. IEG has an incinerator in Port- Gentil where they dispose of contaminated soils. Medical wastes are sent to the incinerator at the main hospital in Libreville. Although collecting systems are in place in Owendo, solid wastes are not disposed of properly in any of the railway stations or around worker accommodation. Families living near railway stations, including Setrag’s workers, burn their waste in open air behind their backyards. As set forth in ESAP action # PS3 2.a, a waste management system will be developed and implemented in all of Setrag’s sites.



In Booué, a complete wastewater treatment plant was constructed many years back but is not functioning. As outlined in ESAP action # PS3 2.b, Setrag will undertake proper effluent management in all its facilities. This will include treatment of wastewater in accordance with WBG EHS General Guidelines values and effluent monitoring.



Hazardous Materials Management



There are no oil water separator and grease traps in any of the maintenance workshops for rolling material. Filling stations are not properly equipped with containment and unused fuel tanks should be decommissioned. As set forth in the ESAP action # PS3 3.a, a hazardous materials management plan will be developed and implemented, and all mainte
nance workshops and filling stations will be equipped with appropriate containment (e.g. oil water separators, grease traps, etc.) and spill prevention equipment.



Railway sleepers made out of wood are provided by a sawmill (Somivab) owned by Comilog. Somivab has its own forest concession south of Booué. Part of the wood at the sawmill is Forest Stewardship Council (FSC) certified (certificate valid until March 2015). Creosote is used as a wood preservative, and Setrag has mandated a study to assess creosote content in old sleepers in order to analyze disposal options. During this project, it is estimated that approximately 10,000 tons of contaminated sleepers will be replaced (by concrete sleepers) and disposed in the next 5 years. As set forth in ESAP action PS3 3.b, Setrag will develop and implement a specific management plan to dispose of used creosote contaminated sleepers in line with good international industry practice.



Vegetation control is done by daily workers along the railway. Setrag does not currently use herbicides at any of the sites.



Manganese ore is stored along the railway without apparent drainage to avoid contamination of surface water. Setrag will assess the risk of surface water contamination by manganese. If contamination is likely, as set forth in ESAP action # PS3 3.c, management strategies will be implemented to reduce exposure of sediment-generating material to water.

Community Health and Safety



In Gabon, train safety is regulated by Train Safety Regulations (''''Règlement général de sécurité''''). Freight and passenger train safety is mainly linked to management of train movement, train driving, railway and train maintenance, and overall safety management systems. ''''Hot Box'''' detection devices to detect wheel overheating are installed in three different locations along the railway. Level crossings where railway lines cross streets represent high risk accident locations for railways. A few crossings do not have proper signage. Electric wires and water pipes have been illegally buried under tracks. People are seen using the tracks to move from a location to the other. Several areas along the track are encroached by houses, business structures, etc. For the safe and efficient operation of trains, the project will require the relocation of encroaching structures within the safety zone (circa 15 m on either side of the tracks).



The most recent external safety audit was carried out in 2010 and some safety issues were analyzed in 2014 by a train consultant. As set forth in ESAP action # PS4 1.a, an audit of Setrag’s rail operational safety procedures and their implementation will be conducted to assess whether they are in line with requirements of PS 4, WBG EHS Guidelines for Railways, and good international industry practice. Emphasis will be placed on general rail operations safety, transport of dangerous goods, level crossing safety, and pedestrian safety. A corrective action plan will be developed and implemented.



Infrastructure and Equipment Design and Safety



At the Owendo site, there is a Fire Safety team of 6 people. For all their facilities, Setrag has about 20% of staff trained in Fire Safety with about 100 staff trained each year. The insurance company undertakes a Life and Fire Safety audit every two years (last one dated April 2013). Internal audits are conducted monthly including monitoring of the corrective action plan. As set forth in ESAP action # PS4 2.a, all structures (e.g. passenger trains) and buildings (e.g. railway stations, office buildings, etc.) accessible to workers and the public must obtain certification of structural and fire safety aspects by engineering and fire safety professionals registered with national or international professional organizations. Corrective action plans will also be developed and implemented.

Security Personnel

Following a decree in 1978, a trained unarmed police unit was instituted in Gabon with the same attributions and powers than judiciary police. These agents are regularly trained in fire safety, self-defense, ethics, anti-poaching patrolling, etc. Security guards are also hired to protect Setrag premises in Owendo (30 staff), Lastourville (3 staff), and Booué (5 staff). Moreover, armed regular police force can be directly involved at any of the sites.

This performance standard is considered applicable because of the overlap of the existing project with critical habitat (as described under PS 1 above), rather than because of any incremental adverse impacts related to the proposed project. As discussed already, the project entails refurbishment of existing infrastructure within an existing (impacted) corridor, thus no new adverse impacts on biodiversity are anticipated once basic management system procedures are implemented (e.g. anti-poaching policies), no net loss of biodiversity in natural habitat is expected and the project is not expected to lead to measurable adverse impacts on those biodiversity values for which the critical habitat was designated, and/or on the ecological processes supporting those biodiversity values.

Nevertheless, Setrag drafted a Biodiversity Action Plan as part of the project impact identification process (January 2015, attached) in consultation with the Gabonese National Park Agency, the Ministry of Water and Forests responsible for anti-poaching patrolling, and NGO WWF. This plan incorporates management measures to (continue to) minimize the impact of the railway on protected areas, in particular the Lope National Park, including provisions in the Park management plan for joint wildlife surveys that will allow monitoring of biodiversity values and effectiveness of management actions. Many of the agreed actions have been in place for some time now and will be given additional impetus through this project. Given the fact that no new biodiversity impacts are anticipated as a result of this project, potential net gains of biodiversity values will be delivered through the joint effort between Setrag, WWF and the Ministry of Water and Forests to collaborate in anti-poaching on the railway corridor.

External communications at Setrag fall under the responsibility of the Trade Department which is divided into 5 services (marketing, freight, travelers, sales, and public relations). Public Relations manage relationships with clients, including grievances. A call center is also functional. Regular announcements are also made at railway stations (e.g. posters), in newspapers, radio, and television, and sms are sent to regular users. A survey on customer satisfaction was conducted in 2012 (sampling of 1000 users randomly selected).

For this railway refurbishment project, consultations were organized in December 2014 in five locations, namely Owendo, Ntoum, Andem, Oyan and Ndjolé. This involved the following key stakeholder groups: communities living along the side of the railway, shop keepers, railway employees, NGOs such as WWF and Brainforest, Ministry of Waters and Forests, National Park Agency, Ministry of Environment, Ministry of Transport. Stakeholders provided input related to negative and positive impacts of the project as well mitigation measures. The main concerns raised included the following: community safety, noise and dust, exposure to hazardous materials, risks of accidents, resettlement, and social conflicts due to influx of workers. Positive impacts raised by stakeholders as results of this project include: increased community safety, facilitation of passengers transport, and decreased occurrence of train delays.

A Stakeholder Engagement Plan will be developed for this project. The plan will include the following elements: engagement principles, objectives and criteria; requisites and regulations; summary of any previous engagement activities including any documented evidence (i.e., agreements, minutes of meetings, etc); identification, characterization and priority of stakeholders, focusing on those directly affected and identifying any vulnerable individuals or groups; engagement program including indication of how interactions should be formalized (i.e., agreements, acknowledgment of receipt of information, etc); description of grievance redress mechanisms; list of time-bound activities (timetable/periodicity); and resources and responsibilities.

Patrick Claes
CEO of Setrag
P.O. Box 578
Libreville, Gabon
Tel: 241-01-70-80-06
Fax: 241-01-70-01-06

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	Establish and maintain an Environmental and Social Management System (ESMS). The ESMS will incorporate the following elements: (i) a Setrag specific EHS policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) stakeholder engagement plan; and (vi) monitoring and review. For each rehabilitation site, Setrag will develop and implement an EHS Action Plan, an OHS Training Plan for workers/contractors, a coordination mechanism with its medical staff (e.g. via a Health and Safety Committee) on injuries and illnesses, procedures for dealing with hazardous and non hazardous waste. A chance find procedure is to be developed and implemented.	12/31/2026	In Progress
2	Obtain environmental licenses to operate from the Gabonese Ministry of Environment for each site where it is legally required. Obtain authorization from National Park Authority (ANPN) to conduct rehabilitation works in the Lopé National Park	11/01/2016	Completed
3	Hire a Senior EHS Officer and one assistant, one Social Specialist, and 2-3 EHS Officers responsible to supervise the different project worksites. The Senior EHS Officer will be responsible to develop the overall ESMS and site-specific EHS Action Plans	11/01/2016	Completed
4	Develop an overal Emergency Preparedness and Response Plan and site-specific plans that will include zoning, roles and responsibilities, communication (staff, authorities, and local population), emergency procedures, available resources (fire stations, health center, list and location of available equipment, contacts lists), and training program. The plans will provide for staff training to ensure that all employees are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes. The plans will include schedule for fire drills.	09/01/2017	Completed
5	Prepare a Human Resources Policy to cover staff and management working relationships, working conditions & terms of employment, workers’ organizations, non-discrimination & equal opportunity, retrenchment, grievance redress (including procedures to address harassment), child labor, occupational health & safety, workers engaged by third parties, and supply chain.	07/30/2017	Completed
6	Provide access to drinking water and sanitary facilities in all operation areas. Adequate places to eat and rest areas will also be provided and building of separate lockers for men and women at the Owendo site. Setrag will develop and implement a set of standards for worker accommodation in line with the IFC and EBRD Guidance Note of Worker Accommodation Process and Standards. These standards will be applicable to current worker accommodations and to refitted wagons.	07/30/2017	Completed
7	Undertake an independent review of the OHS management system. The review will determine the extent to which the OHS management system complies with the requirements of this Performance Standard and internationally accepted best practice. This will focus on the refurbishment project and will be expanded to cover the overall operations at the late stage. Based on the audit findings, the client will agree with IFC on a time based corrective action plan if necessary. Setrag will also develop a specific HSE Management Plan for operations as part of the ESMS with specific performance indicators to be monitored and reported to improve OHS performance.	03/31/2017	Completed
8	Treat potable to World Health Organization standards in all the sites and implement a potable water monitoring program.	07/30/2017	Completed
9	Develop and implement a waste management system at all sites	02/01/2017	Completed
10	Undertake proper effluent management in all facilities. In Booue, refurbish the existing wastewater treatment system	07/30/2018	Completed
11	Develop and implement a hazardous material management plan for all sites (worskhops, filling stations and others), including an assessment of contaminated areas (identification of contamination sources, characterization of  soil and groundwater contamination) and a soil and groundwater remediation action plan (responsibilities, methods, timeline, budget). This should also include appropriate containment (e.g. oil water separators, grease traps, etc.) and spill prevention equipment	07/30/2017	Completed
12	Develop and implement a specific management plan to dispose of used creosote contaminated sleepers in line with good international industry practice.	02/01/2017	Completed
13	Setrag will assess the risk of surface water contamination by manganese. If contamination is likely, it will develop and implement management strategies to reduce exposure of sediment-generating material to water (e.g. manganese stored along the railway without adequate containment).	07/30/2017	Completed
14	Conduct an audit of Setrag’s rail operational safety procedures and their implementation to assess whether they are in line with requirements of PS 4, WBG EHS Guidelines for Railway, and good international industry practice. Emphasis will be placed on general rail operations safety, transport of dangerous goods, level crossing safety, and pedestrian safety. A corrective action plan will be developed and implemented.	12/31/2016	Completed
15	Obtain certification of structural and fire safety aspects of all structures (e.g. passenger trains) and buildings (e.g. railway stations, office buildings, etc.) accessible to workers and the public. This certification will be carried out by engineering and fire safety professionals registered with national or international professional organizations. Corrective action plans will also be developed and implemented.	07/30/2017	Completed
16	Develop and implement a Resettlement Action Plan based upon an updated census survey within the safety zone. In addition it will present an action plan on how any gaps against Gabonese entitlements will be dealt with.	07/01/2016	Completed
17	Update and implement the agreement between Setrag and the Ministry of Waters and Forests to collaborate against the illegal transport and commerce of bushmeat in the railway corridor.	12/31/2016	Completed