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 IFC's 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

This investment is classified as a Category B project in accordance with IFC’s Policy on Environment and Social Sustainability. Based on information reviewed by IFC, the proposed Project will have limited adverse E&S impacts that are few in number, site specific, largely reversible and readily addressed through mitigation measures, as outlined in the Environmental and Social Action Plan (ESAP) attached to this Environmental and Social Review Summary document (ESRS).

The main E&S risks and issues are related to the following: ensuring on-going compliance with Ukraine regulation governing the need to conduct environmental assessment of new developments (including the location of farms, the expansion of the meat processing operation and the design and construction of the new effluent treatment plant); obtaining and maintaining associated construction and operating permits, and the expansion and implementation of the integrated environmental, occupational health and safety (EHS) and food safety/quality management system to these new operations. The company also needs to more fully and robustly engage with the communities located in the area of the company’s operations to ensure they are aware of company operations and that any impacts stemming from these activities (including pesticide application, manure application, movement of heavy farming equipment and other company trucks, etc.) are known and understood and that the community has a means to raise any issues they may have regarding these impacts and that those complaints or comments are adequately addressed in a timely manner.

Impacts related to the following Performance Standards were not identified during IFC’s review: PS5: Land Acquisition and Involuntary Resettlement as the farm lands leased by the company (for use in both crop production and to site the farms themselves) are leased from either individuals or from villages in a willing lessor/willing lessee transaction. [Land transactions can be summarized as follows: Land availability is tied to each village with each hectare of land being valued by the state at 21000 Hryvna or UAH (approximately $1700 USD). Of this amount, 5% (1050 UAH) is paid as annual rent for the land with the village receiving 15% of this sum (157.5 UAH) and the person who holds the existing right to use the land receiving the remaining 85% (892.5 UAH). This practice is set in law. In addition, and as a standard part of a lease, the company prepares some land for local villages’ use. A lease agreement for farm land runs between 5 -10 years; that to be used for the pig farms (and therefore built upon) is for 49 years (the maximum length of time allowed under law). Payment for the use of the agricultural land is per annum; that for land for pig farms is required to be paid one time, up front (at the time of signing the lease)]; PS6: Biodiversity Conservation and Sustainable Management of Living Natural is not applicable as there are no impacts to critical or natural habitat and the land has long been used for agricultural purposes. PS7: Indigenous Peoples (IP’s) and PS8: Cultural Heritage do not apply as IPs are not present and the land was long been used for agricultural purposes and does not contain any cultural heritage.

In addition to the above, the WBG Environmental, Health and Safety (EHS) General and sector-specific Guidelines for Mammalian Livestock Production, Crop Production and Meat Processing apply to this investment. The IFC’s Good Practice Note on Animal Welfare has also informed this appraisal.

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.

Policy, Environmental and Social Risks and Impacts Assessment and Management System



The company has yet to establish an overarching policy that defines its environmental, (including occupational health and safety) and social objectives and principles. The company will therefore develop such policy that will provide a framework for the environmental and social assessment and management process that will include the commitment to comply with applicable Ukraine laws and regulations and be consistent with the principles of the Performance Standards and the WBG EHS Guidelines. The company does subscribe to, and is certified against the requirements of the ISO 22000 standard for food safety (the current certification is valid through March 2019) at its meat processing; the policy will therefore also make reference to this standard in the policy. The policy will indicate who within the company will ensure conformance to the policy and be responsible for its execution and will be communicated to all levels of the organization. This requirement is addressed in the attached Environmental and Social Action Plan (ESAP).



The company has established, and maintains a process for identifying and managing the environmental and social risks of its existing operations. An Environmental Impact Assessment (EIA) is required to be developed (AKA OVNS in Ukrainian) and submitted to authorities in order to obtain an operating permit for each operation. This requirement is not just applied to new projects; for example, the last assessment of the existing feed mill/processing complex was made in 2011 (and is required every 5 years). All new projects are required to be assessed before the project begins, i.e. farm 7 was assessed prior to its start of construction and this report was made available as illustration of compliance with this requirement. The company uses qualified consulting companies that are licensed by the government to conduct the assessment. An example assessment highlighted the need for management of traffic during construction, management of emissions, effluents and solid wastes, an energy and water use, etc. Assessments are used to inform company policies, practices, procedures and yearly management programs. Documents reviewed by IFC during the appraisal showed full compliance with such applicable requirements.



The company follows an ‘avoid, minimize or mitigate’ approach to dealing with project related risks and impacts. For example, each new farm is built to the same plan/layout (i.e. they are identical and this design integrates considerations of animal welfare, minimizes energy use, provides for segregation and management of solid and hazardous wastes, provides several layers of biosecurity measures, etc.) occupies about 9 ha and are based on the latest Danish technologies. Farms are built by the construction arm of the company, i.e. company employees subject to company oversight and management fabricate the walls and floors, transport th
e pre-fabricated pieces to the construction site and undertake the on-site construction, thereby managing OH&S hazards and risks. Farms (and other facilities such as the concrete plant where the floor and walls are made) are surrounded by concrete walls and are located to avoid interaction with communities. For example, farms are found in remote settings, away from communities (a minimum of 1.5km for farms of the size in operation at Nyva as per Ukraine law with the exception of Farm 4 which is closer but for which the company has received approval regarding its location from the government), on lands previously used for agricultural activity and away from surface water features. When risks cannot be avoided, measures are in place to ensure they are managed. For example, farms are inspected by a number of state authorities (e.g. the fire department) after construction is complete and before operations begin. During operations, veterinarian authorities, environmental inspectors, etc. regularly inspect the farms.



Land around each pig farm (approximately 800ha per farm) receives treated effluent from the pig farms 1 or 2 times per year (respecting riparian protection zones that are in place to protect surface waters and applied just before the growing season) thereby both providing for the safe and complete disposal of this waste stream (as all effluent is so applied) and increasing soil fertility. Yields from fields receiving organic fertilizer (in addition to mineral fertilizers) are up to 30% greater than those fields receiving only mineral fertilizers.



Operational permits and licenses for the company’s operations (as required by regulation) were reviewed by IFC, as were lease agreements providing land for pig farms and crop production.



Management Programs, Organizational Capacity and Competency



The management program in place at the company is constituted by a variety of procedures and practices that are operationalized by managers and staff throughout the organization. For example, the meat processing operation is certified to both ISO 9001 and ISO 22000 (and thereby incorporates a Hazard Analysis and Critical Control Point or HACCP program); the maintenance of these systems is the responsibility of the chief of the processing plant. The cultivated lands are under the responsibility of the Chief Agronomist and good agricultural practices are implemented (such as safe application of pesticides, manure application, etc.) by his 11 subordinate agronomists. They work alongside the company ecologist who is also responsible for environmental management at the concrete plant. Group wide Human resources are managed by a manager who is supported by a staff of three. OHS is managed Group-wide by the Chief of Labor Security who is supported by a manager at each operation.



The company interfaces with regulators (including those responsible for environmental oversight) through the aforementioned company ecologist who works with her count
erpart in this role. Duties include maintaining permits and licenses, overseeing the monitoring program and ensuring proper waste collection and disposal.



Training

The company provides training for those engaged in jobs that are related to environmental and occupational health and safety hazards and risks. Such jobs are assessed by both workers and managers in a collaborative process. Safe working procedures are then developed and documented. Implementation of these working instructions is designed to eliminate risks or to reduce residual risks to acceptable levels. Specific examples of this practice in operation are provided below in the section describing the company’s OHS practices.



Monitoring and Reporting

The above management programs incorporate performance indicators; for example, waste water is treated to meet effluent standards (see below for more details) and occupational health and safety is judged against lost time incident frequency reporting (LTIFR). (This is further discussed below.) Matters of OH&S are overseen by a Chief of Labor Security with managers in place at each operation. The Heads of Departments (HODs) conduct a monthly safety committee; managers also convene a weekly safety meeting. As is required in the above certified management system, senior management receives periodic performance reviews on the effectiveness of those systems. As is required by Performance Standard 1, this practice will be extended to ensure that the performance of the overall environmental management system – as described above – is reviewed on a similar basis. A summary of the agenda – and follow up action items – will be provided in the AMR.



Emergency preparedness

Emergency Preparedness is required by the State Fire Security Department (under the auspices of the Ministry of Extraordinary Situations.) The plans that are developed are done so in conjunction with the Department that then reviews the document prior to its being adopted by the company. Required permits also address possible sources of accidents that may lead to emergencies, e.g. those that pertain to the management of hazardous materials. As an illustration of this process, an example emergency plan (that for the concrete production facility) was discussed with company management; risks related to both employees and the greater public were described therein. Ongoing measures are required to prepare for emergencies; for example, the company conducts fire drills in accordance with regulations and maintains its own fire-fighting team that receives training from the public fire department.

Working Conditions and Management of Worker Relationship



IFC met with the company’s Human Resources manager to discuss and review labor and working conditions. The company has adopted and implemented human resources policies and procedures that are either consistent with, and in compliance to (or even exceed the requirements of), national labor law. The company regularly receives an audit of its labor practices and can demonstrate compliance to applicable requirements.



There are a total of 1080 employees of which 511 are women (who mostly work in the meat processing operation.) They are all permanent employees; there are no part time or temporary workers. When a worker doing a particular job does not have sufficient work (for example a tractor driver following harvest) they are re-assigned to another job within the organization. Also, to accommodate the seasonality of crop production work, the company allows flexible working hours (as per Ukraine labor law for agricultural workers) so longer hours when needed are balanced with shorter hours when the work is less intense. There are no contracted workers.



The minimum age for full time employment in Ukraine is 18; although the law allows apprentices/trainees to be hired at 16. The company has some 17 year olds (they can only work 7 hours a day – but they are paid for 8) and these individuals are prohibited from undertaking any hazardous work. Proof of identification – and age – is required as part of the recruitment process. The current minimum wage in Ukraine for all workers is 1218 UAH/month; the company pays more than double this rate (2500 UAH/month)



General terms of employment are contained in a collective contract (which is registered with the state) that every worker gets from the company upon being hired. This document includes details on pay and working conditions, etc. An individual’s specific job requirements are communicated during the interview process and are also contained in a written offer letter. The Ukrainian constitution contains provisions for non-discrimination in hiring and promotion. Jobs are advertised based on the skills and experience required (two examples were reviewed – one for head of labor protection and one for a person to work in the meat processing department). Equal opportunity (regarding promotion) is achieved by internally posting the job requirements for new positions as well as advertising them externally.



Regarding worker’s organizations, an internal commission of employees (formed by employees with principles being elected) is in existence. This body provides a variety of functions including that of a social organization (that provides financial support to worker’s families for example) and as a body that negotiates with the company for better wages and other benefits (a form of collective bargaining which is required under labor law.) Unlike a trade union, no dues are required to be paid to the organization. Company management stated that
if the commission wanted to become part of a larger trade union they could not prevent this from happening.



Given the company has been expanding over the last 6 years (by building more pig farms) there has been no retrenchment; this trend will continue as the company expands to 10 farms in total. It was stated that if retrenchment was to be required, then the company would follow the provisions of Ukraine labor law

.

The company has a form of employee grievance mechanism; it was reported that this is discussed during the job interview (as part of the rights and duties of employment). In addition, the State’s labor department can also receive complaints directly from employees (including those posted anonymously.) They then visit the company and review the issue. The company will review its own procedures and practice and the employee grievance mechanism will be enhanced – to also include the ability to internally record complaints anonymously – and the availability of this enhanced procedure will be communicated to the entire workforce in accordance with the requirements of this performance standard. This is addressed in the ESAP.



Occupational Health and Safety



The grain storage operation located at the feed mill and elevator is regularly inspected by the State Emergency Service (which includes the fire department) who review and report upon how matters of life and fire safety and other potential emergency situations are being managed by the company. Recent audit reports indicated that there were no issues with the operation of the grain storage facility.



Jobs that involve hazards and risks (e.g., welding, fabricating and then using cranes to move and load concrete floor and wall elements onto trucks and then offloading them at construction sites, working at heights, those working in grain elevators, those operating heavy farm equipment and applying pesticides, those working in confined spaces, those using vertical saws in the meat processing plant, etc.) are subject to written work instructions that describe the hazards and risks and the mitigation of those risks. Mitigation includes administrative controls (limiting the hours that individuals work those jobs and making line supervisors and managers responsible for the behaviors of those who report to them), engineering controls (including preventative regular cleaning of the workplace to prevent dust build up, and the maintenance of cranes and other equipment and the inspection of such equipment by the state on a regular basis) and use of personnel protective equipment (hard hats, boots, dust masks or respirators, safety glasses and/or full face masks, gloves and coveralls as appropriate). Those who conduct such work are trained (training logs showing those receiving training, the subject and the trainer who provided the instruction were reviewed by IFC) and only upon completion of such, and the subsequent receipt of a worker’s card permitting them to undertake such work, can the
y actually carry out those tasks. Provision of training is the responsibility of the respective Heads of Department.



As noted above, the company uses a variety of practices and procedures to provide a safe and healthy working environment. Such measures are consistent with the requirements of the WBG EH&S General and Sector-Specific (crop production, mammalian production and meat processing) Guidelines. With regards to documentation and reporting of occupational accidents, diseases and incidents, the company reported a lost time incident frequency report of 3 for the meat processing operation in 2011; no lost time incidents were reported in 2012 and 2013. This should be compared to a LTIFR of 6 for the meat processing industry based on US data. Whereas the current meat processing operation is small and these rates appear to indicate a very safe working environment, the company will review its overall reporting practices to ensure that all accidents, incidents and near miss that may result in a lost time incident throughout all operations are fully recorded (data on LTIFR in the farm, feed mill and the concrete production operations were not available for review). Reporting of data from the entire operation however (including farms, for example) in the Annual Monitoring Report or AMR will further allow for benchmarking and identification of areas where improvements may be required.



The company only uses a limited number of contractors. For example, the new grain storage silos were constructed by a contractor and specialist repairs to equipment (cranes, combine harvesters, etc.) are carried out by outside service providers. This outside help is limited to specific jobs; regardless, contracts with these service providers contain requirements related to labor and occupational health and safety regulatory requirements and such companies are required to provide evidence of current licenses and permits prior to the commencement of work. General awareness of hazards and risks (e.g., fire prevention and protection) and specific instruction based on risk and job type are also reviewed with the contractors before work is allowed to commence.

Resource Efficiency



Crops are rain fed not irrigated; the region experiences between 500-700mm of rainfall per annum. Therefore this element of the vertically integrated production system is not a significant consumer of water. Raw water needs for the pig farms are met from permitted groundwater sources. The State’s geological department conducts quarterly monitoring of this water source to ensure the quality of the water meets or exceed applicable national acceptability standards. Monthly consumption of water is at the meat processing plant is also reported.



The farms are allowed to extract a maximum of 80.46 thousand m3 of raw water per year; they actually use far less than this allowed amount (average use being 58 thousand m3/yr). Records reviewed by IFC showed the amount of raw water extracted; these are required to be sent to authorities on a quarterly basis. Given the average life of a pig is 180 days the company has benchmarked consumption at 1.45m3/pig which, whereas on the higher end, is still within the range of consumption reported in the literature (i.e. an average of 8 liters/day throughout the entire life cycle of the pig). The company will look for further opportunities to implement water conservation practices (through application of a water audit and cleaner production measures) in addition to existing practices (such as re-use of water in truck washing that has reduced consumption to 20% of previous totals) and report them in the AMR.



Pollution Prevention



The meat processing operation uses steam generated by a boiler that is fired using natural gas. This boiler also provides steam for use in the feed mill. The capacity of the boiler (installed in 2001) is 3 ton of steam/hour (which equates to 1.88MWth). When the need for steam is less, a small second boiler (installed in 2005) is used (this is rated at 1 ton of steam/hour). The size of these boilers precludes the need for monitoring under the General EH&S Guidelines; however, monitoring is undertaken to satisfy Ukraine regulations (under Ukraine Standard 201-97). The company is in compliance to the requirements contained therein. The company will report on continued compliance to Ukraine norms in the AMR.



As noted above, each farm (and the concrete plant and the area used to service agricultural machinery) is equipped with a small straw burning boiler (approximately 1.2MWth) to produce hot air and hot water – to keep both employees and pigs warm in winter. As per environmental regulations, the use of each boiler is subject to an assessment prior to its use. This assessment takes into consideration the proximity of any communities; as mentioned elsewhere in this document; farms are located away from communities (at least 1.5km from the nearest settlement). Each boiler is equipped with a 100m3 capacity water tank.



The 0.75MW boilers on the farms and that in use at the construction site consumed a total of 5167 tons in 2012. The company is self-sufficient in s
traw production. The State issues an operating permit for these straw fired boilers; the company is in compliance with all operating parameters and limits. The company plans to introduce straw fired boilers to generate steam for the meat processing plant and hot air to dry grain. They are also proposing use of a small wood pellet fired boiler (300kw) to provide heat for the headquarters office.



Scope 1 greenhouse gas (GHG) emissions from the raising of pigs and combustion of the above amounts of straw (for the current 6 farms in operation), the diesel consumed in standing and moving equipment and the natural gas consumed in the processing and the feed mill plant equated to 30,185 tons of CO2 equivalent. Scope 2 emissions (from electricity consumption) added a further 5,866 tons. The company will therefore quantify direct emissions from its facilities as well as indirect emissions associated with the off-site production of energy used by the project (e.g., electricity) in accordance with internationally recognized methodologies and good practice. The company will report their GHG emissions annually in the AMR. The company will consider alternatives and implement technically and financially feasible and cost-effective options (such as those discovered by undertaking an energy audit) to reduce project related GHG emissions.



Wastewater from the meat processing plant is treated in a small on-site plant that also treats sanitary waste from the nearby community. Whereas monitoring results reviewed indicated compliance with WBG EH&S Guidelines for meat processing, the company has commissioned a new larger treatment plant that will be built to treat effluent from a planned enlarged meat processing operation (to be located adjacent to the existing plant). The new treatment plant is being designed by an Austrian company and the operating (i.e. design) effluent limits will be in compliance with the limits as contained in the WBG EH&S Guideline for Meat Processing. The plant is expected to be completed by November 2015. Monitoring data (once the plant is operational) will be reported to IFC in the AMR.



The amount of solid waste generated by the company’s operations is estimated as part of the state assessment required prior to the beginning of operations. Data on the actual amounts generated are maintained and submitted to authorities to demonstrate compliance with these expected norms. Records (manifests) of final disposition of wastes (e.g. spent fluorescent tubes, plastic, paper, glass, protective clothing, lead acid batteries, oils and lubricants and used tires) are maintained by the company; wastes are removed and transported by licensed contractors and are either recycled or disposed of in licensed landfills. Dead pigs (and animal wastes from meat processing) are sent to a rendering plant.



Hazardous Materials (e.g. cleaning chemicals) are kept under lock and key in central locations in each farm. Refrigerant used in the meat processing ope
ration is R407C and R404A, a non-ozone depleting substance.



The company uses a wide variety of herbicides and pesticides in growing their crops. Only those crop protection products that are allowed to be used by law in Ukraine are utilized. At IFC’s request, the company cross-listed the chemicals that they use against the World Health Organization (WHO) Recommended Classification of Pesticides by Hazard (2009) and of the 28 products in use 4 were not listed in the WHO Classification, 22 were Class III and 1 was Class II. Application of crop protection products was witnessed during the site visit; workers were seen to be wearing personnel protective equipment commensurate to the risk of working with such chemicals. Given the overwhelming class of the chemicals being used (III – slightly hazardous), and the practice of application observed, the company is judged to be compliant to the requirements of this Performance Standard with regards to handling and use of crop protection products.



In compliance with the requirements of this and other Performance Standards the company will review, and comply with, the requirements of the aforementioned WBG General and industry specific EH&S Guidelines



Animal Welfare



A recent review of the company’s operations also included matters of animal welfare. The assessment used European Union criteria (legislation and regulation) pertaining to matters of animal housing and other conditions. Whereas overall welfare was judged to be of a high standard with the animals being well cared for, some practices were noted as being non-compliant to EU legislation; for example, the review noted that the company does not provide group housing for sows in existing operations, that temporary housing arrangements (due to construction) had created space constraints for some finishers and there was the need for more consistent provision of environment enrichment. In response, the company has committed to meeting EU Animal Welfare Directive’s requirements for its new farms, i.e. farms 9 and 10 (as 7 is under construction and 8 has already been designed). The company will report in the AMR on the progress towards achieving compliance with EU animal welfare; in addition, the company will refer to the current version of IFC’s Good Practice Note on Animal Welfare as guidance on rearing operations.

Community Health and Safety



Adverse impacts upon the health and safety of communities located nearby Nyva operations could result from practices associated with farming, such as inadvertent exposure to land application of effluent (used as fertilizer), exposure to agri-chemicals (e.g. pesticides), inappropriate operation of company trucks in populated areas or exposure to excess noise and/or inappropriate disposal of effluent from processing operations. In addition, possible outbreak of diseases in the pig population that could transfer to human populations could also occur.



AS noted above, agricultural land is leased by the company and used to grow crops (maize, soy, wheat, barley and oil seed rape) that are either used as inputs to the company’s feed mill (and hence food for the pigs) or are sold to traders. As of 2014 (with 6 pig farms in production), the company had 21,000ha under crop production; in 2013 all but 60,000 tons of total production (in this case maize) was used as inputs to the feed mill with this excess maize being sold. Each pig farm requires between 10-12,000 tons of feed per year. Company expansion plans call for a total of 10 pig farms to be in operation at project completion which will leave approximately 30,000 tons of excess production being available for sale. The company will ensure the good practices currently implemented on existing land are extended to any new lands acquired. For example, land application of slurry (which is injected during the summer application and as such reduces possible impacts associated with odors) and is generally limited to areas close to pig farms should be similarly managed on new lands. As noted elsewhere these farms are required to be located away from areas of population. Regardless, the company should make a point of informing local villages of the intention to apply the slurry; likewise, application of any agri-chemicals should also be included in communication with villagers. These actions should be integrated into a more pro-active formal engagement approach with local populations as is noted below as being required.



Trucks (for moving pigs and feed between operations and other agricultural raw materials to and from operations) are maintained by the company; the garage and chief mechanic are required to review and sign off on a vehicle after maintenance and before it can be used so as to ensure it is roadworthy. Truck drivers (of whom there are 20) are tested every day for alcohol and blood pressure before being allowed to drive; they also undergo a comprehensive annual health examination. The company reports that there have been no accidents involving their trucks. The company should be cognizant of all impacts that may occur due to truck traffic moving through local villages (such as dust, vibration and noise) and ensure that all trucks are driven according to local laws and that they are not overloaded. Being receptive to complaints stemming from truck traffic must be
considered as part of the enhanced stakeholder engagement plan, SEP, (see below). IFC will require reporting on future performance regarding truck operations in the Annual Monitoring Report (AMR) and as part of the reporting requirement within the SEP.



Effluent from the current limited meat processing operation is also addressed elsewhere in this document; monitoring results regarding effluent quality will also be recorded in the AMR to continue to provide assurance to IFC that this risk remains well managed.



Management of carcasses from farms (i.e. pigs that die prior to reaching the age to be slaughtered) was noted in a biosecurity report of Nyva operations as requiring some improvement. Whereas this was predominantly from a perspective of preventing pig to pig transfer of disease, the improvement of this practice will have associated benefits regarding overall community health, safety and security and the company shall act on the recommendations of that report. This is addressed in the ESAP.



Separation of the public from company operations is achieved due to farms being some distance from areas of population and their being surrounded by 2.7m high concrete walls as part of the biosecurity measures. The chance of inadvertent access to the farms (and exposure to any kind of transmissible disease) is further minimized as measures regarding limiting access to authorized personnel only (by having on-site, unarmed security guards, for example) are also in place.

The primary means of current and past community engagement with communities center on the EIA process for new developments (therefore driven by regulation which includes a public disclosure element) and that of activities related to corporate social responsibility. Therefore, and as is noted elsewhere in this document, the company will more fully engage with local communities and other interested stakeholders. The company will disclose this ESRS and the associated ESAP on its website (having first translated it into Ukrainian) and locally in appropriate venues (e.g. town halls, churches, etc.) and communicate its availability to local communities. Going forward, the company will update, finalize and adopt the current draft Stakeholder Engagement Plan (SEP) complete with a community grievance mechanism and a public reporting element so as to meet the requirements of the Performance Standards and Ukraine legislation and/or regulation with respect to stakeholder engagement. This plan was developed in conjunction with the EBRD audit of company operations in late 2013. This requirement is addressed in the ESAP. Reporting on the implementation of the plan, and a synopsis of activity managed through its implementation, will be accomplished using the AMR.

JV LLC Nyva Pereyaslavschyny
2 Pryvokzalna St.
v. Pereyaslavske
Pereyaslav-Khmelnitskiy district
Kyiv oblast
Ukraine

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Develop an environmental policy that will provide a framework for the environmental and social assessment and management process that will include the commitment to comply with applicable Ukraine laws and regulations and be consistent with the principles of the Performance Standards and communicate this policy to all who work for, oe on behalf of, the company.	12/31/2014 12:00:00 AM	Completed	Completed	08/25/2015 12:00:00 AM
The company will review its own HR procedures and practices and enhance the employee grievance mechanism – to also include the ability to internally record complaints anonymously – and communicate the update to the policies and practices to the entire workforce in accordance with the requirements of this performance standard.	12/31/2014 12:00:00 AM	Completed	Completed	08/25/2015 12:00:00 AM
The company shall implement the recommendations of the biosecurity report (developed as part of the EBRD due diligence appraisal)	12/31/2014 12:00:00 AM	Completed	Completed	08/25/2015 12:00:00 AM
The company will update, finalize and adopt the current draft Stakeholder Engagement Plan (SEP) complete with a community grievance mechanism and a public reporting element.	12/31/2014 12:00:00 AM	Completed	Completed	08/25/2015 12:00:00 AM