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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The Project has been assessed as an IFC Category B investment as it will result in a limited number of specific impacts that can be avoided or mitigated by adhering to industry recognized standards, guidelines and design criteria. Key findings of the appraisal that determined categorization included:

- The scope of the Project covers a limited “brownfield” footprint of the recently completed onshore Stubb Creek and Ekid receiving facilities along with supporting infrastructure.
- Seven Energy operations present potential impacts and risks that are typical for limited-scale oil and gas activities. These impacts and risks can be readily identified and avoided or reduced by following good international industry practice.
- Seven Energy is strongly committed to effective QHSSEC management and as part of IFC’s investment the Company is undergoing a review of its own existing comprehensive management systems. The review will augment these existing systems to ensure consistency with IFC’s Performance Standards and will be organized to meet ISO14000 and OHSAS 18001.
- There are no offshore activities as part of this investment.
- Future field-development, exploration and/ or acquisition activities will be assessed on a case by case basis before the activities begin via an appropriate level of environmental and social assessment aligned with both national regulatory standards and consistent with IFC’s Performance Standards and applicable EHS guidelines.

No significant environmental or social sensitivities have been found at Seven Energy’s operated locations. The Company’s existing procedures include processes for the identification of QHSSEC impacts and risks prior to entering new development areas and producing assets (including environmental audits, baseline studies and environmental and social impact assessments). Proposed activities can therefore be assessed on a case by case basis before activities begin and management measures commensurate with the identified impacts and risks can then be developed and implemented where necessary.

Key risks and issues related to this investment include the Company’s capacity to: i) undertake adequate social and environmental assessment and monitoring during exploration and development phases including the assessment of potential cumulative impacts; ii) ensure fair, safe and healthy working conditions during construction and operations for direct employees as well as for the contract workers; iii) ensure proper handling of hazardous materials, and management of airborne emissions, wastewater, solid and hazardous waste during construction and operations; iv) ensure appropriate management of the impacts of construction and operations on, community health, safety and security and consult and engage with potentially project-affected communities; v) ensure potential social issues relating to pipelines and facilities land acquisition processes are identified and mitigated; and vii) minimize adverse impacts of construction and operations on the natural flora and fauna within a project’s area of influence.

Environmental, social, health and safety issues that require mitigation are included in the Project’s Environmental and Social Action Plan (ESAP). Upon implementation of the mitigation measures, the project will comply with environmental and social requirements, namely the laws and regulations of Nigeria, recognized good international industry practice and IFC’s Performance Standards on Social and Environmental Sustainability.

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 development of the Uquo field and installation of the Ekid gas processing facility was completed in late 2013, with first gas production expected in December (11th) 2013. An environmental impact assessment (“EIA”), completed in 2008, was developed and approved consistent with the requirements of the Nigerian Federal Ministry of Environment (“FME”) and the Department of Petroleum Resources’ (“DPR”) Environmental Guidelines and Standards for the Petroleum Industry in Nigeria, EGASPIN (2002).

Whilst the Calabar power plant development is at an advanced stage of development the Company will review available documentation, which may include Environmental Impact Assessments, engineering design, pipeline routing studies and land acquisition processes. Seven Energy will identify environmental and social risks and appropriate mitigation measures. The Company will engage with the Calabar power plant sponsors to discuss possible mitigation measures of any significant impacts identified as part of the review.

In 2008 Universal undertook an EIA covering the Stubb Creek development which considered well development, EPF and CPF development, oil flow lines and export lines. The Stubb Creek development EIA was subsequently approved by FME and DPR, consistent with the Nigerian Environmental Impact Assessment Decree No. 86 of 1992. The EIA includes a brief Environmental Management Plan (“EMP”) for the Project outlining a Waste Management Plan, Drilling Management Plan, Community Development Plan, and Decommissioning and Abandonment Plan. In addition, the EIA defines drilling techniques along with a Memorandum of Understanding with the local communities detailing additional requirements for community investment. The EMP also addresses monitoring and audit requirements including designation of responsibilities. Prior to field development, the previous field operators commissioned an Environmental Evaluation Report of the Stubb Creek Field in 2004 prior its sale. Following Universal’s acquisition an EIA was undertaken in 2005 in support of a 3D seismic survey and two well work overs.

Following the Seven Energy farm-in to the Stubb Creek development, an environmental and social audit was undertaken assessing previous studies and the management system. Action items identified by the audit included i) improved pipeline monitoring and completion of right of way restoration and ii) asset level management systems implementation and revision. These items have been incorporated into the development’s risk register.

At the corporate level, Seven Energy has established a number of QHSSEC policies which are subject to periodic review. There are five core policies covering i) anti-corruption, ii) asset protection, iii) corporate social responsibility, iv) health safety and environment and v) quality. Supporting the five core policies an additional 14 Seven Energy management commitments and policies are defined as part of the corporate QHSSEC management s
ystem, including a) management commitment to QHSSEC, b) respect of laws and regulations, c) operational responsibility, d) risk evaluation and management, e) respect for the environment, f) safeguarding of health, g) contractors and suppliers, h) competence and training of personnel, i) emergency preparedness, j) incident analysis, k) audits and inspections, l) performance improvement, m) security and n) community.

The corporate Vice President (“VP”), QHSSEC, located in Lagos and supported by a QHSSEC team of ca. 55 qualified personnel, monitors Seven Energy’s operated and non-operated assets and reports directly to Seven Energy’s Chief Operating Officer also located in Lagos. Seven Energy develops an annual QHSSEC plan identifying objectives for the coming year, along with KPI’s and financial and personnel resources specific to those objectives. Seven Energy Group QHSSEC objectives are defined during the first quarter of each calendar year and subsequently approved by senior Seven Energy management. Both the Uquo and Stubb Creek assets have full time QHSSEC management structures (Frontier and Universal respectively) with supporting QHSSEC teams who report to the respective Field General Managers. Oversight and monitoring of both fields is provided by the Seven Energy ‘Projects HSE Manager’ and support teams which, are embedded within the joint venture company equivalent structures.

Seven Energy has established a reporting and monitoring system with field staff providing daily, weekly and monthly QHSSEC data which is documented and reported throughout the organization up to and including quarterly reports prepared by the VP, QHSSEC, and delivered to Seven Energy’s Executive Committee and full Board of Directors by the Chief Operating Officer. The VP, QHSSEC, is responsible for the development and implementation of the Company’s QHSSEC policies and procedures. In addition to the regular reporting, an emergency response plan is in place to report and if necessary respond to environmental, safety or security issues as they arise in the Seven Energy offices, operated and non-operated properties in which Seven Energy has an interest.

Separately, Seven Energy has established an Audit & Compliance Group. The focus of the department is primarily based upon an annual risk-based audit plan, approved annually by Seven Energy’s governance board. The 2013 audit program has included reviews of service providers and contractor performance along with supplemental gap identification and analysis in line with QHSSEC requirements. The role and scope of the Company’s Audit and Compliance Group is not limited to QHSSEC alone, with the 2013 audit plan including reviews of contracts and procurement, a review of the Oron pipeline project, compliance assurance, Company-wide budgeting and forecasting processes and compliance with the UK Bribery Act.

The Stubb Creek and Uquo Field assets both operate Environmental & Social Management Systems that pre-date
Seven Energy’s ownership. Seven Energy is currently revising the asset level systems to be consistent with the corporate level QHSSEC management system.

As part of IFC’s financing, the Company will also review existing corporate level policies, procedures and systems and augment where necessary to ensure consistency with IFC’s Performance Standards. As required, Seven Energy will engage a qualified third party consultant to review its QHSSEC system to ensure the Company’s individual projects are acquired, constructed and operated in a manner consistent with host country requirements, IFC’s Performance Standards and good international industry practice.

With regard to any future asset developments the Company undertakes, Seven Energy will ensure the revised QHSSEC management system will require that ESIA’s are undertaken at an appropriate stage in the project development cycle, such as during exploration campaign planning or parallel to a Front End Engineering Design phase of asset development. As part of the ESIA process, an Environmental and Social Management Plan (“ESMP”) for each new project activity will be developed setting out: i) measures to mitigate adverse direct and cumulative impacts, including, where feasible, impacts arising from associated facilities; ii) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; iii) organizational and financial resources for carrying out the measures; iv) an implementation schedule for these activities; and v) an appropriate incentive structure (including provisions for reward and penalties) to ensure plans are implemented. The ESMP will contain at a minimum, an emergency response plan, a spill control and response plan, a waste management plan, and a stakeholder engagement plan and community grievance mechanism. In the instance where Seven Energy proceeds with the acquisition of an existing or greenfield development opportunity, the target acquisition company would eventually operate under the Seven Energy QHSSEC following a period of reasonable transition.

Site specific biodiversity protection measures identified during any project ESIA will be incorporated into the ESMP and implemented by the project’s QHSSEC team. The Seven Energy QHSSEC Management System will require a project to assess, avoid and where avoidance is not possible mitigate material impact, if any, on threatened species of flora and fauna. The QHSSEC Management System will require all project ESIAs assess the impacts arising from supporting linear infrastructure consistent with PS6 including, but not necessarily limited to access service roads and onshore oil and gas pipelines; develop and implement construction demobilization and landscape restoration plan detailing a systematic restoration of the project area landscape following the completion of all civil works and the evacuation of construction sites, including muck disposal sites and borrow pits for civil work
s, material lay down areas and labor camps.

To date, existing Environmental Impact Assessments for the Marginal Fields, the OMLs and supporting infrastructure have considered cultural heritage. Beyond family shrines no sensitive tangible resources or sites of cultural significance were identified as part of these studies. Seven Energy has a Cultural Heritage Management procedure which is applied to all existing and new facilities, properties or assets owned in full or part. As part of the QHSSEC management system review, Seven Energy will develop a clear policy and review its cultural heritage management procedure to ensure consistency with Performance Standard 8 and to be applied to all future projects. As and when required, Seven Energy will ensure that adequate financial and personnel resources are available to undertake ESIA review and on-the-ground verification of potential presence and impacts to cultural heritage including the implementation of a chance find procedure.

In line with this, for all projects supported by IFC funds (‘Applicable Projects’) the corporate QHSSEC management system will require the Company corporate QHSSEC team to review existing ESIAs or equivalent documents. Where there may be gaps between the requirements of the Performance Standards and the Applicable Project, Seven Energy will prepare a supplemental environmental and social action plan aligning the project with Performance Standards and Guideline requirements. Where Seven Energy is not the operator of an Applicable Project, it will use reasonable endeavors to direct the application of the IFC’s Performance Standards to the ESIA.

For prospective farm-in activities or acquisitions, Seven Energy currently undertakes environmental and social audits which consider the management of existing and future assets to be developed, explored and/ or acquired by the Company. As part of IFC’s funding and Seven Energy’s ongoing QHSSEC management systems review, Seven Energy will augment existing standards to ensure the Company will: i) screen projects for E&S risk; ii) review assessments for completeness and consistency with IFC’s Performance Standards and EHS Guidelines; iii) identify the need for supplemental studies; iv) undertake the supplemental studies, appropriate update of existing EIAs and/ or undertake ESIAs in accordance with IFC Performance Standards; v) undertake regular project audits during construction to assess status of implementation of the project specific ESMP and implementation of corrective actions identified in the previous audit; vi) undertake annual audits to assess effectiveness of the corporate ESMS and status of implementation of corrective actions identified in the previous annual ESMS audit; and vii) build the capacity within the Company for corporate-wide QHSSEC management. Seven Energy’s corporate QHSSEC Manager and the QHSSEC staff assigned to each project company will be responsible for ensuring that the ESMP and Corrective Acti
on Plans are implemented by each respective project company throughout the construction and operation phases of a project.

Existing operated producing asset level management systems of Stubb Creek and Uquo field consider QHSSEC performance and oversight of contractors and sub-contractors. Seven Energy will review these current practices against the revised Seven Energy QHSSEC Management System requirements ensuring procedures are implemented for: i) contractors deployed by each project company meet relevant provisions of Seven Energy’s ESMS and ensure implementation of the ESMP as applicable to their respective activities; ii) QHSSEC training of Seven Energy employees and contract labor; iii) procedures for recording, investigating, reporting and undertaking corrective action in relation to QHSSEC incidents including those involving contractor and sub-contractor labor; iv) periodic monitoring of QHSSEC performance; v) management review of ESMS effectiveness and implementation of measures for system upgrade; and vi) continue the practice of regular reporting of QHSSEC performance to Seven Energy’s Board of Directors, regulators and investors.

While distinct communities are located proximate to project areas (including the pipeline ROW, production fields, production plants and other facilities), the relatively high levels of accessibility, established land tenure systems, established links with the mainstream economy and local government ensure that the various groups existing within the wider region in which Seven Energy’s activities are focused are part of mainstream society without specific attributes that would classify them as Indigenous Peoples as per IFC guidelines. For any subsequent project, Seven Energy will identify all potentially affected stakeholders including vulnerable groups and Indigenous Peoples. If it is determined that Indigenous People will be affected by the project, Seven Energy will apply the provisions of Performance Standard 7.

As part of IFC’s financing Seven Energy will develop a Code of Conduct to guide Seven Energy’s employees, contractors and other parties on interactions with potentially affected communities and other stakeholders. The code of conduct will include disciplinary actions and all employees will be required to acknowledge receipt and understanding of its provisions.

Seven Energy’s individual operations currently plan and implement training programs consistent with the corporate QHSSEC system and national regulatory requirements. These include the identification of workplace hazards; the use of personal protective equipment and collective protection equipment; the roles and responsibilities of employers and employees, induction programs; defensive driving programs; first aid and lifting management. Seven Energy also requires that employees and subcontractors have formal education, experience and where required are certified to the appropriate levels for the assigned functions. Seven Energy prov
ide induction training covering aspects such as the technical competencies of the assigned work activity. The Company have an established internal communications program whose objective is to disseminate corporate policies and practices starting with a standardized induction program covering QHSSEC aspects relevant to the individual job description. As part of IFC’s financing, and in combination to ongoing QHSSEC management system reviews, the company will review existing training and communications procedures to ensure training programs are consistent with IFC’s PS requirements.

Seven Energy directly employs on a permanent basis approximately 84 people of which 75 are Nigerian nationals 9 are expatriates. As of December 2013 Seven Energy was employing an additional 97 Nigerian nationals through its manpower service providers and as direct/ indirect contractors. A total of 34 women (both permanent and contract) currently work for Seven Energy.

Seven Energy has in place a “Manual of Human Resources Management Policies” that describes employment categories, general conditions, benefits, professional conduct and the Company’s expectations within the work environment. The manual is consistent with local regulations and internationally recognized standards including non-discrimination and equal opportunity, minimum employee age requirement (18 years of age), compensation, working hours and overtime allowances. Seven Energy respects freedom of association and as part of IFC’s financing will include a specific statement within its Human Resources policies committing to respecting such internationally recognized labor rights.

In addition to salary, Seven Energy employees receive a number of additional benefits that include: paid annual leave and recognized public holidays; a pension scheme; various life and medical insurance benefits for employees and employee dependents; along with maternity and medical leave. Salary increases are linked to staff performance as assessed by the Company’s annual staff performance appraisal process.

Prior to an employee’s assumption of duties Seven Energy issues the candidate an offer of employment along with a contract detailing working conditions such as work location, benefits and remuneration. The Manual of Human Resource Management Policies as well as the Company’s Code of Business conduct and Ethics, confidentiality agreement, Anti-corruption and Conflict of Interest policies are provided to employees upon commencing their employment with Seven Energy. The Code of Conduct and a Disciplinary Policy includes general statements in relation to expected behavior of all employees mainly within the workspace. Employees are also required to acknowledge receipt and understanding of the Company’s Anti-Corruption and Conflict of Interest policies within the first week of employment.

Seven Energy has established an Employee Grievance Policy and procedure. In the event that employees are unable to resolve a perceived issue with their direct supervisor, they are encouraged to bring the issue to the Human Resource manager informally to seek to resolve grievances at the lowest possible level of management. When a more formal approach is needed, employees can submit a statement in writing to their manager or to the HR manager to be handled in a confidential manner, without retribution for logging the grievance and as promptly as possible. The grievance process includes provisions for appeals with a senior management team if the employee is not satisfied with the initial decision. Whilst not
explicitly stated in the policy the Employee Grievance Mechanisms does not impede access to other judicial or administrative remedies available under the law or through arbitration procedures. IFC understands that there are no cases pending against the company in the labor legal system. As part of IFC’s financing, Seven Energy will augment the existing corporate grievance mechanism to provide timelines for complaint submission and resolution along with a procedure for anonymous complaints.

Seven Energy has a well-established local recruiting and hiring procedure as well as pre-established working conditions for local workers, which are agreed with local communities. Such conditions and procedures are set out in community level Memoranda of Understanding (MOUs).

To ensure adequate conditions in work camps, Seven Energy has developed a draft camp management plan providing guidelines and establishing minimum standards for design, construction and management of camps. As part of the SOP review commissioned by Seven Energy, the camp management plan is being reviewed and due for finalization during the first quarter of 2014. Seven Energy will incorporate the recommendations to this management plan and implement as appropriate.

Seven Energy ensures that contractors are provided with adequate working conditions, ensuring that child labor or forced labor is not employed through the inclusion of addenda in contractor agreements stating such requirements. Seven Energy’s Audit and Compliance group has mechanisms to conduct internal audits and audits to non-operated joint venture partners and contractors including the implementation of the code of conduct for business and compliance with contracts and procurement policies.

Occupational Health and Safety (“OHS”) is a key component at Seven Energy’s operated producing and exploration assets. Activities are subject to hazard identification and risk assessment to ensure that OHS controls to manage risk are in place prior to starting the activity and necessary competency requirements for key roles are specified. Individual job methods are reviewed through standard job safety analysis so that the safety management procedures and practices in place are correctly planned and implemented. The strict enforcement of OHS procedures is reflected in the positive safety statistics reported for Seven Energy’s operations which are well within industry norms. As outlined previously, incidents, including near misses, are reported to management on a daily, weekly, monthly and quarterly basis and each is investigated. Procedures are adapted where necessary to prevent re-occurrence. Seven Energy has not experienced any fatalities in its operating history with LTI and incident rates well within industry norms.

Firefighting and emergency response plans are established for parts of the operated assets and are under review for the remaining part. Small localized drills are frequently conducted to practice and test em
ergency arrangements. Frequent communication with neighboring oil companies is tested and arranged through participation in the geographical committee for the area.

The environmental regulator, the FME, has regulatory control relating to pollution prevention in Nigeria. Operators are subject to routine audits on their environmental performance by the FME’s impact mitigation and monitoring function which includes environmental monitoring as defined in the approved field environmental management plan. Once commissioned, the FME will also regularly (usually on an annual basis) send inspectors to Seven Energy producing facilities to audit and inspect the facilities, collect samples of effluent for analysis and check waste tracking records.

Power to the central process facilities at Stubb Creek and Ekid will be supplied by feed gas generators with diesel back-up. Limited additional airborne emissions occur from gas-fired process heaters. Venting volumes are considered low for both operated fields. Seven Energy will quantify direct emissions from the facilities owned or controlled within the physical project boundary, as well as indirect emissions associated with the off-site production of energy used by the Company. Quantification of GHG emissions will be conducted by Seven Energy annually in accordance with internationally recognized methodologies and good practice.

As outlined previously, all produced water generated at Seven Energy’s operated producing assets will be re-injected down-hole; no produced water will be discharged to the environment. Both facilities include produced water treatment via phased separators, which will be collected, stored and disposed of in lined ponds prior to re-injection. Drill cuttings are initially held in lined cuttings pits located at the drill pad. Following the completion of the drilling operation, mud contaminated and non-mud contaminated cuttings are treated (via thermal desorption) and disposed of via licensed waste management contractors. The drill pad is subsequently restored to its original condition. Other wastes are segregated and transferred to approved facilities for recycling, re-use or treatment and disposal by licensed waste management contractors via the use of waste consignment notes. Both Stubb Creek and Ekid dispose of hazardous waste that is not returned to the manufacturer / vendor (e.g.: used lubricating oil) or collected by FME (e.g.: used batteries) to an approved hazardous waste facility.

As part of the corporate level QHSSEC management system, Seven Energy will review, and where necessary, augment existing Waste Management procedures which will require its operated assets to develop mechanisms to track waste consignments from the originating location to the final licensed waste treatment and disposal location. Drilling Waste Management Plans will be reviewed and updated to include other planned activities, as needed.

Similarly, the waste management procedure will make provision for audits of associated waste management facilities to be regularly conducted by Seven Energy QHSSEC department personnel or by qualified specialist consultants
, where required. Waste management procedures will incorporate chemical handling procedures to handle all hazardous chemicals that are produced, used, or stored during all activities, ensuring consistency with IFC’s guidelines. Transportation of hazardous material will comply with Nigerian regulatory requirements and applicable international requirements. Specific training will be provided to all relevant personnel. These waste management procedures will apply to all Seven Energy contracted resources and will be audited by Seven Energy QHSSEC department personnel.

Communities in the Company’s region of operations have a long history of exposure to the oil and gas industry and have a developed awareness of the associated risks. Historically, the region has experienced a number of tensions relating to incidents associated with attacks to surface oil pipeline infrastructure. In order to address this, Seven operates, and implements in new areas of operation, a robust stakeholder engagement program to maintain good relationships with communities. The program also seeks to create awareness within communities of the risks relating to Seven Energy’s operations. To the extent possible, Seven Energy seeks to develop buried pipeline infrastructure as a standard procedure. Similarly, the Company has developed a participatory (community based) Right of Way maintenance and monitoring system for the Uquo to Oron pipeline which, will be implemented post construction phase.

As with similar projects, risk to community health of Seven Energy’s operations include traffic accidents, construction and operations accidents such as blowouts, and communicable diseases and other health and safety issues related to immigrant workers during construction phase.

As part of the Company’s QHSSEC management system, Seven Energy has developed and implements Community Health Safety and Security procedures, including Emergency Preparedness and Response. As required by Seven Energy’s QHSSEC Management System emergency preparedness and response plans are developed on an asset by asset, or activity by activity, basis to contain strategies to respond to specific situations such as well-kicks and blowouts, including requirements for drilling operations to provide for medical evacuation. Also, an extensive programme of community consultation involving community meetings, radio/TV announcements, leaflets and an instructional DVD will be expedited prior to the introduction of pressurized hydrocarbons into the line – as was performed for the Uquo to Ibom Power Plant 18” pipeline project.

Seven Energy has developed an Asset Protection Policy and accompanying management system designed to protect company assets including property, personnel and proprietary information. Through the policy Seven Energy is committed to identify security threats and minimize identified risks while conducting its asset protection operations in accordance with national legal requirements and international standards. Seven Energy has developed set of security plans and operational procedures including asset protection standards and asset protection manual, incident investigation and reporting standards, personal security awareness handbook, security induction procedures, security plans for each if its facilities, and rules of engagement. Through its Asset Protection Standards, Seven Energy is committed to conduct security operations in compliance with the Voluntary Principles on Security and Human Rights. Seven Energy has developed a Human Rights Risk Assessme
nt to be applied at all its operations, projects, owned and managed sites, new acquisitions, offices and facilities.

All personnel working or providing services for any Seven Energy operation, including public security forces must conform to company security guidelines. Seven Energy provides training on its security policy and procedures to its personnel and to public forces when assigned to its operations.

Seven Energy’s Senior asset protection and transportation manager position is covered by two experienced expatriates on back-to-back rotation. All personnel including security personnel hired by Seven Energy are forbidden to use or carry weapons. However, Seven Energy recognizes that the security situation in the region remains volatile. As such, the need to provide armed security forces is standard practice for the sector in the regional context. In accordance with Nigerian policy, public security forces such as the police and army provide services to facilitate safe and secure operations of the oil and gas industry.

Both the scale and duration of construction is limited. Workforce accommodation and the management of solid waste and effluent would pose minimal health risks to the communities residing in the vicinity of the activities. Seven Energy have developed transport management plans to reduce potential impacts of transportation activities to local communities and trains its employees on defensive driving.

As part of the corporate level QHSSEC management system review, Seven Energy will also review its existing Community Health, Safety and Security and associated procedures and augment where required to ensure consistency with IFC’s Performance Standards.

There has been a history, spanning several decades, of social tension between the Niger Delta oil and gas sector and local communities, along with reported human rights concerns in the area. Various initiatives have improved the situation in recent years, and individual companies such as Seven Energy have built good community relationships. Seven Energy specifically has engaged with local communities through a number of initiatives including constant communication with community leaders and other local based groups, permanent presence in affected communities, the implementation of a grievance mechanism, Corporate Social Responsibility programs to support local development, a local employment program, and a land acquisition program based on good faith negotiations and livelihood restoration. As part of its Asset Protection system, Seven Energy is committed to the Voluntary Principles on Security and Human Rights and has developed a procedure to conduct Human Rights Assessments throughout its operations.
Although the area where Seven Energy operates is mainly rural, the population density is high and land use for agricultural and other traditional activities is relatively intense. Impacts associated with Seven Energy’s routine activities are expected to be marginal, however pipeline and other facility construction can be significant although temporary. Seven Energy has a CSR/Community Relations team of eleven individuals including a CSR manager based in Uyo who reports directly to the VP, QHSSEC. Additionally, FOL has a Public Liaison Officer (PLO) and a CLO. The CSR team keep community members informed of the Company’s activities, respond to or report community concerns appropriate and coordinate the implementation of development initiative in accordance MOUs signed with communities and with Seven Energy’s CSR policy. Through its daily activities CSR Representitives engage with a number of community groups including Community Chiefs, youth and women groups and Memorandum Implementation Committees, which is formed by village chiefs and ensures the adequate implementation of MOUs.
Seven Energy has developed a Stakeholder Engagement Plan (SEP) that includes strategies for stakeholder identification and analysis and conduct stakeholder engagement activities. The SEP provides guidelines for stakeholder engagement during the development of ESIAs, negotiation and subscription of MOUs, and the construction, operations and closure stages. Seven Energy has in place a community grievance mechanism and keeps a grievance log to register and follow up on grievance redress.
As part of IFC’s financing, Seven Energy will augment the existing corporate Stakeholder Engagement Plan and grievance mechanism in accordance with IFC Performance Standards. Seven Energy will develop project or activity specific SEPs including provisions to develop detailed annual operating plans for stakeholder engagement activities.

Project documents will be available at the following address in Lagos, Nigeria.
Dr. Glenn Bestall, VP, QHSSEC, Seven Energy, 7 Anifowoshe Street, Victoria Island, Lagos, Nigeria – mailto:glenn.bestall@septaenergy.com

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date
1.Review and update its corporate level QHSSEC Environmental and Social Management System, procedures and policies per IFC’s Performance Standards and guidelines, to include the following elements as described in the ESRS a) Emergency preparedness and response plans b) Acquisition/ farm-in screening mechanism for new assets/ projects with definition of mitigation processes c) Corporate and site level Management Plans; Corporate Minimum Standards; Standard Operating Procedures; Corporate Code of Conduct for employees, contractors and other parties d) Corporate standards defining ESIA requirements e) Environmental and social monitoring and/ or audit requirements f) Contractor and sub-contractor supply chain management g) Corporate Grievance Mechanism standard h) Chance Finds Procedure i) Waste Management Plans k) Training protocols	6/30/2014
2.Qualified independent third party environmental and social consultant to review existing portfolio (including “Uquo” and “Stubb Creek”) Environmental and Social Impact Assessments, including associated export pipelines, develop action plan and address gaps where necessary to ensure consistency with the Company QHSSEC Environmental and Social Management System.	6/30/2014