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 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
During the appraisal, it was confirmed that Agrivision only relies on land acquired through willing seller / willing buyer situation therefore there are no adverse impacts related to Land Acquisition and Involuntary Resettlement (PS5); Agrivision will confirm through ESAP actions that their primary production only uses sustainable operated agricultural land and operates consistently with Global Good Agricultural Practice (Global GAP), which is the only applicable requirement under PS6 given that there is no critical, modified or natural habitat of concern on the farms; there are no Indigenous Peoples (PS7) known to be in the Project areas; and the operations do not make use of land that has Cultural Heritage (PS8) status and there are no Cultural Heritage (PS8) sites near the farmed land or the wheat and maize flour milling operations.

The proposed Project is to invest in environmentally sound, energy efficient primary crop production supporting the local food supply needs through the Company’s own wheat and maize flour mill, or for alternate crop productions for sale as animal feed products. The farms have been developed over many years in compliance with national regulatory requirements and international standards. Today, Zeder Investments Ltd. (the “Sponsor”) ensures the implementation of, and compliance with, current requirements and standards and is committed to good environmental and social management, with a proven record of openness and transparency. The Project will follow Global GAP principles and recognized food safety standards and will be operating well within local regulations and World Bank Group (WBG) environmental health and safety (EHS) guidelines. With no indication of impacts related to Performance Standards 5, 7 and 8 and only readily mitigated environmental issues under Performance Standards 1 through 4, and certification requirements under PS6 the Project is a Category B project in accordance with IFC’s Policy on Environmental and Social 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 environmental and social risks associated with the proposed Project, as described in the following sections, mainly relate to the assurance of appropriate implementation of already proven Standard Operating Procedures (SOPs), management systems and technologies. The mitigation measures agreed with the Sponsor are therefore focused on continuous implementation of Agrivision''s corporate Environmental & Social, Health & Safety, and Social (HSE) commitments and initiatives (e.g. continuous reduction of specific CO2 emissions by promoting zero tillage crop farming). An Environmental and Social Action Plan (ESAP) has been developed for covering and correcting identified Performance Standard gaps.

Agrivision has a well-developed, albeit only partially integrated between the three operations, management system for ensuring compliance with the standards the Company is committed to either due to local rules and regulations or due to voluntarily established Company goals. The individual systems used are all in line with and cover the requirements of IFCs Performance Standard 1. This includes policies covering human resource, environmental, health & safety management systems, community grievance mechanism, as well as food safety systems ensuring that all crops are grown and handled by Agrivision according to modern state-of-the-art practices. To ensure consistency in implementation and effectiveness the systems at the two farms will be consolidated according to an Environmental and Social Action Plan (ESAP) item agreed with IFC and described in the attached ESAP.



Agrivision has well developed environmental, human resources (HR), occupational health & safety (OHS), social responsibility/corporate relations, and farming principles/policies. The responsibility for the implementation rests with the individual operation’s managers (e.g. for the two farms and the milling operation) who are tasked to ensure that all farms and crop handling and milling facilities adhere to these EHS standards. Before taking ownership of the individual operations Agrivision also had access to Environmental Impact Assessments for each operation confirming its appropriate standards and detailing applicable regulatory requirements. During IFC''s appraisal individual managers were interviewed and their ability to provide consolidated and consistent corporate information on the adherence to the guiding principles were checked and found consistent and diligently implemented.



Agrivision''s local managers in each of the three operational centers, be it milling or the crop growing estates carry overall responsibility for their operation''s adherence to all of Agrivision''s corporate standards. In this respect each of the operations managers (one mill manager, and two farm managers) have local managers dedicated to the implementation of the different tasks, be it HR, health and safety, environmental and social, or integrated pest management. The local managers are selected and trained based on their specific task knowledge and responsibilities. Visiting the operations during the appraisals confirmed the local manager’s adherence to the principles set forth including consistent and timely reporting of actions taken, high levels of maintenance standard, and full adherence to the promoted E&S standards. The outcome of the reporting is used by the management to ensure any difficulties are dealt with appropriately, potential for improvements are acted upon, and the data provides the basis for Sustainability reporting, and annual monitoring reporting to investors, lenders and guarantors (MIGA). The evaluation of the performance information from Agrivision and on-site checks at the
farms visited is referred to in the sections below.



Although Agrivision has not yet certified any of its management systems according to ISO 14001 or OHSAS 18001 standards per se, their management principles and criteria are carried out under strict adherence to transparency and honesty in a rather flat organization. Currently Agrivision is being supervised frequently by outside specialists under the MIGA guarantee, which has had its own ESAP that has ensured both farms are operating in accordance with the Performance Standards. Agrivision has further agreed under the ESAP to audit / validate / certify the crop operations according to Global GAP (Good Agricultural Practice) or its equivalent. As agreed in the ESAP the milling operation will be certified according to ISO 22000 during 2015, and it will therefore likely be the first milling operation in Zambia with certified food safety standards.

Agrivision has 475 permanent and fixed contract employees (170 of these at the Mpongwe Mill), and an average of 225 casual employees at the farms with variations during the field preparation, crop management and harvest seasons.



Human Resources Policy, Working Conditions: Agrivision’s human resource standards and policies are influenced and guided by the principles of South African labor law and regulation, good international practice, as well as those requirements found in the Zambian labor laws. The outcome of this approach is in line with ILO core labor principles and the requirements found in IFC''s PS2. Each operation has their own HR function on site and they ensure standard employment conditions / contracts are used covering the rights, duties and principles between staff and the Company in accordance with PS2, as well as institutionalizing of nondiscrimination and employee grievance mechanisms. The farms provide accommodation for its employees, and the Company has been updating such accommodation over the recent years to reflect better water and sanitation standards. As an example of the cooperation between management and employees the management at the farms meet every two weeks, with the Employee Representative Committee to cover any issues, health and safety aspects or grievances that has arisen since the last meeting.



Gender equality. Traditionally, Zambian agricultural sector employment is dominated by male employees. While Agrivision favors gender equality the employment split reflect the general tendency in Zambia with only 18% of the farm employees being female.



Occupational health and safety. Agrivision takes occupational health and safety management seriously, with hazard assessment, substitution for less dangerous methods if feasible, training according to specific job risks, restriction on who can do specialized functions that carries risks needing extra training, provision of PPE equipment where needed, and has a system that ensures all accident are registered diligently and dealt with in respect to preventive actions. Nevertheless, the high number of casual workers in the agribusiness sector has influenced the number of “low technology” accidents like falls in connection with internal movements at the farm operations in a negative way. This has not resulted in serious accidents or fatalities, but does give relative high accident frequencies. Agrivision has therefore agreed as part of the ESAP to address this by targeting the risk of these actions and the outcome of the initiative will be reported yearly to IFC in the Annual Monitoring Reports.



Fertilizer and pesticide applications at the crop farms are carried out with modern equipment and according to modern principles for safe operations, all under the supervision of the senior management. Employees working with these functions have to complete technical training before they are allowed to perform these functions in accordance with the modern safety practice
. Equipment used for pesticide application was inspected at the crop farms visited during the appraisal and was found to be modern and well maintained.



Emergency Preparedness and Response. Agrivision follows the appropriate approvals and permits from relevant supervisory authorities with respect to emergency preparedness and response planning. For the milling operation a very high maintenance standard is also applied to secure the lowest possible likelihood of, for example, fires or explosions. Agrivision is also fully aware that their crop farming operations are located at distances from public help that requires them to be prepared to handle emergency situations on their own for a substantial amount of time. The farms therefore have their own clinics to provide first aid treatments.

Overview. Agrivision’s activities are divided into milling and crop farming operations, which are associated with different impacts upon resources and generation of pollution. Senior country management members assume responsibility for the environmental and social standards used by the group and have personnel with different skills in order to assess and manage these risks and impacts. Due to these differences the main risks and the preventive measure taken are described below activity by activity:



Milling operation. The main environmental risks associated with the milling operations are related to dust from the milling either causing a nuisance to close-by neighbors or creating the risk of explosions or fires if allowed to build up in an uncontrolled way. Mpongwe Milling was built to state-of-the-art standards for dust emission control through filtered ventilation and transport systems and it has been well maintained and is cleaned regularly to prevent any of the described dust related problems. Due to the mill’s modern equipment the energy consumption, delivered by national grid electricity, is kept within the expected norms. Water for cleaning and domestic usage is received via own wells while the sewage water, consisting of general plant cleaning water and grey sewage from employee facilities are treated via the municipal sewage handling system. Solid waste packaging materials and domestic waste is handled by certified waste collectors and oil/grease/chemical waste is handled by a specialist company.



Crop production. The operations at Agrivision farms are strictly limited to non-GMO crops, and are dominated by maize, wheat and soya bean crops. Agrivision has equipped its farms with appropriate international-standard heavy machinery for the large-scale production which is taking place. Crop specialists select the preferred crops and define crop rotation schemes suitable for the individual field''s soil structure and climatic conditions. With no animal fertilizer available Agrivision’s farms rely on commercial fertilizers and are limiting tilling of the soil. By the end of 2014 zero tilling was being practiced on approximately 2/3 of the land used, with a goal of converting the remaining land to zero tilling within the next years.



Agrivision is using Integrated Pest Management (IPM) systems managed and overseen by the highly experienced farm managers. Fertilizer and pesticide formulations do not contain Class 1a or 1b ingredients, and are further limited to application by specially trained operators using the latest technology application machines to avoid any broader spreading, or unintentional applications. Crop dusters are used by Agrivision as a potential alternative for pesticide application when it is well justified, for example if a specific summer is too wet and thus prevents the use of other application methods. To ensure the use is well justified and carried out correctly Agrivision will, as part of the ESAP present its
operational procedures that 1) demonstrate that its use is appropriate and that it is necessary, 2) demonstrate that the application procedures ensure against impacts to the health of those that may be living or working nearby (for example by avoiding drift, only applying it on days without winds, warning locals and those working nearby that it will be happening, etc.), and 3) in years when Crop Dusters have been used the correct usage will be demonstrated in the AMR reporting. Fertilizers and pesticides are kept under strict control at the farms and the preparation of the final mix for application is overseen by the stock manager at each farm.



Energy consumption at the crop farms is reduced by using modern machinery; deep plowing has also been eliminated on most of the fields.



The farms are reducing their solid waste as much as possible and are handling the remaining waste through dedicated landfill / combustion operations. Waste oil/chemical/pesticides are disposed of via specialist companies, while empty pesticide containers are currently being kept onsite in dedicated dry storage while the Company awaits a sustainable solution to its disposal.



During the farm inspections it was found that not all fuel / oil tank containments had the right design to prevent discharges should the tank or its piping experience a leak. Agrivision will, in accordance with the ESAP internally audit all containment around oil tanks to ensure they are properly sealed (no open drains), and will where possible equip these containment with rain shelter roofing to limit rain water collection in these containments.



The farms are based on irrigation schemes, which for both farming estates are fed from dedicated dams. The Somawhe Estate has a long established dam, which is fed by local springs and precipitation. This dam has excessive water capacity that has been proven over the years and that can sustain the potential expansions of crop areas on this farm. The Mkushi Estate dam is located on a local river catchment with a series of upstream dams. This river, and its ability to support all water users, which are large scale farms is regulated by the Zambian authorities. Currently the river feeding the Mkushi Estate dam is experiencing some imbalances caused by a series of new large upstream dams that are filling. Mkushi Estate is participating in discussions with authorities and other users to establish new water allocations for all users that will be fair and monitorable.



Energy Efficiency and GHG emissions reduction. Agrivision is set up for minimal energy consumption by:

the use of new modern and efficient agricultural machinery at the crop farms, and

significant introduction of zero tilling operations on currently 2/3 of the land under crop production.

The activities of Agrivision are typically low risk with respect to local communities, and does not use armed security personnel. Transport service for grain delivery and wheat and maize flour distribution is mainly handled by well reputed local transport operators on a contract basis. The milling operation is separated from local communities by being located in a light industrial area. The farms are in remote areas with low population density. For the crop farming, the usage of fertilizers and pesticides can cause short term risks, and these risks are minimized by strict adherence to applicable Agrivision instructions and the use of modern application equipment, while reducing the use of crop dusters. Agrivision also has strict training standards for staff involved in the handling of agro chemicals.

Agrivision’s farms are located in areas with degraded habitats due to past times mixed usage of the land. The Company has at the same time established internal expertise that ensures land selected for clearing and new farming is checked for potential biodiversity or cultural sensitivity before the actual clearing and subsequent farming takes place. The non-used areas in between the circular irrigated farm patches are kept in its original bush / open forest vegetated state and provide small biological shelters in the farming land.

Agrivision has committed management resources to dealing with the evaluation of the local community’s needs. The management resources follow principles in line with Corporate Social Responsibility (CSR) principles and is aiming to establish "social contracts" where Agrivision has activities. These social contracts, where local representatives are included in decisions on what to support, typically include support for local schools (as an example the Company has financed the renovation and expansion of a nearby school, which is now jointly used by the employee’s children and children from the surrounding area), or the provision of basic health care support. Agrivision is actively supporting agrarian educations and provide equipment and medicine for Company operated medical clinics that support both direct employees and local stakeholders. The appraisal of the Project included visits to both schooling facilities and medical clinics supported by Agrivision. ESAP item 1 will ensure that the Community Grievance systems used will be consistent between the two farms.

The local access of the ESRS and ESAP will be at the Mpongwe Mill, the Somawhe Estate and the Mkushi Estate at the following addresses:

Mpongwe Milling
Heavy Industrial Area
Plot 5385 Mutentemuko Road
Kitwe
ZambiaAtt: Daniel Kruger

Somawhe Estates
Somawhe Estates Ltd
Munkumpu Farm
Mpongwe
ZambiaAtt: Brian Jenkins

Mkushi Estates:
Chobe Agrivision Company Limited
Parklands Farm
Mkushi Farming Block
Mkushi
ZambiaAtt: Stuart Kearns

Broad Community Support is not applicable for this project

Agrivision Afric(34461) Supervision Disclosure Snapshot – Version 4
Description	Anticipated Completion Date	Status	Comments	Completion Date
Agrivision will consolidate its Environmental Management system documentation at the two crop estates(Somawhe and Mkkushi) to ensure full consistency between the reporting standards at its farm operations and ensure compliance with PS1 including a standardized Community Grievance System.	31-Dec-2015	Completed	Completed	8/31/2018
As part of Agrivision’s management system Agrivision will, ahead of any new farm land acquisitions confirming the land acquisition process carried out is a willing seller / willing buyer transaction and that no economic or physical resettlement has been caused to facilitate the transaction or if any resettlement had been carried out pre-selling of the land to Agrivision it would have been carried out in a form consistent with Performance Standard 5.	30-Mar-2016	Completed	Completed	8/31/2018
Agrivision will certify its Mpongwe Milling operations according to ISO / FSSE 22000.	31-Mar-2019	Completed	Completed	12/1/2020
To ensure Crop Dusters are only used when well justified (for example when a summer is too wet and this prevents the use of other application methods) and carried out correctly, Agrivision will present operational procedures that 1) demonstrate that its use is appropriate and that it is necessary, 2) demonstrate that the application procedures ensure against impacts to the health of those that may be living or working nearby (for example by avoiding drift, only applying it on days without winds, warning locals and those working nearby that it will be happening, etc.), and 3) in years when Crop Dusters have been used the correct usage will be demonstrated in the AMR reporting.	30-Sep-2015	Completed	Completed	8/31/2018
Agrivision will strengthen its health and safety programs, specifically to provide accident type assessments and safety training updates to farm workers with the aim to reduce the number of fall accidents they currently experience in connection with low technology jobs.	30-Mar-2016	Completed	Completed	8/31/2018
Agrivision will internally audit all containment areas around oil tanks to ensure they are properly sealed (no open drains), and will where possible equip these containment with rain shelter roofing to limit rain water collection in these containments.	30-Sep-2015	Completed	Completed	8/31/2018
Agrivision will engage in a process to audit / validate / certify the crop operations according to Global GAP (Good Agricultural Practice) or its equivalent.	31-Dec-2018	Completed	Completed	12/15/2018