While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 7 – Indigenous Peoples
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category A project primarily due to the likelihood of potentially significant and diverse environmental and social impacts and risks associated with Pacific Midstream’s current assets and investment plans.

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

Environmental and Social Management System and Policy
Pacific Midstream (PM) is a newly founded corporate vehicle established by Pacific Rubiales Energy Corp. (PRE). The Management team is in the process of being recruited and the E&S management system will be developed on the basis of the PRE ESMS and IFC Performance Standards.
PRE has an integrated ESMS with ISO 9001, ISO 14000 and OSHA 18000 certification. Their policies and procedures include requirements for contractors on Health, Safety, Environmental and Quality which are part of the contractors? contractual obligations. The company?s contractors and suppliers are subject to a third party compliance verification that encompasses monitoring of legal, financial, labor and environmental, health, community and safety aspects and also includes periodic reporting by E&S consultants (interventores) embedded in the operational teams of the contractors. PRE has a Social Management system led by the Corporate Social Responsibility Group (CSR) which focuses on stakeholder engagement, grievance management, impact management, social project development and compensation as well as community investments. The Social Responsibility Policy addresses the obligations to stakeholders, mainly focused onlabor conditions, local recruitment, local procurement and social investments. The Social Policy is guided by the Principles of the Global Compact and is reported in their Sustainability Report using GRI standards, which has allowed recognistion by the Dow Jones Sustainability Index. This Social Policy is part of the?Commitments that are established in the Company?s Sustainability Policy, which groups all material and relevant aspects that the Company promotes in its Operations. Contractors are required to comply with a Labor, Environmental, Social, security and technical annexes for any and all services, which have a positive direct impact on all stakeholders?. There is a close coordination between the CSR team and the environmental and real estate teams (responsible for land acquisition and easement) , as well as with core operational teams such as Projects, Exploration, Drilling and Production. As part of the Corporate Policy, the Social Investments are being channeled through Shared Value Programs, which allow local communities to develop commercially feasible companies to be linked to the Company?s value chain and the regional commercial activities promoting Local Procurement.
PEL has an ESMS fully aligned with the environmental and social standards of PRE covering all project related activities including contractors? management.
CT: EXMAR Shipmanagement has a suite of corporate policies and procedures governing environmental, health, safety, and quality issues, including a certified safety management system for Shipmanagement operations, in accordance with the International Safety Management (ISM) Code, the international standard for safe management and operation of ships. EXMAR Shipmanagement is ISO 14001 certified for environment, OHSAS 18001 for occupational health and safety, ISO 9001 for quality and is in the process of incorporating ISO 29001 (specific to the oil and gas industry) into its quality system. For the onshore pipeline the PRE ESMS will apply.

ODL has an integrated ESMS. Through ISO 31000 (Risk Management) communication with key stakeholders identifies, monitors and mitigates the most important risks to the project. An audit plan is developed on a yearly basis including regular independent audits. The project has an ethical telephone line which covers both staff and contractors. The pipeline is monitored by walkovers as well as an optical fiber cable which is sensitive to any intrusions. The people conducting the walkovers also record any grievances from affected communities. As part of the project, 1% of the project costs are invested in environmental projects as well as compensation for land disturbed by building the pipeline. ODL has not had any security incidents since it became operational in 2008. ODL has agreements (Convenios) with armed public forces to provide peripheral protection for the pipeline. These agreements are limited to providing logistical support and are developed in line with the requirements of the Voluntary Principles. ODL has developed a Human Rights Policy to ensure that their business activities and the work implemented for them by contractors are aligned with the principles of human rights.
OB has a comprehensive social policy and management system for their operations and a dedicated team for their implementation. The Social policy commits to identifying social risks and addressing them through the mitigation hierarchy. A key component is the grievance mechanism which is disseminated among affected communities and fully integrated into the overall management system to address root causes for grievances. OB has a policy for local recruitment which they effectively implemented through the contractors during the construction phase, employment opportunities included opportunities for women. Consultation with affected communities initiated during the ESIA process continued throughout the construction and operational phase. Community representatives (Presidentes de Juntas de Accion Comunal, personeros) are involved in monthly meetings with contractors, company representatives and to discuss the implementation of the social management plans and address any community concerns. All staff and contractors receive training on the social policy and management plans on a regular basis including as part of induction. In addition OB has made agreements (Convenios) with the armed forces for peripheral protection. All agreements are made in line with the requirements of the Voluntary Standards. Private security personnel in the field are not armed. During the construction period OB worked closely with Fundacion Pais Libre, a Colombian NGO focused onpreventing kidnappings and extortion, and who assisted in resolving all 19 kidnappings that took place during the construction phase.

For current and future assets where PM holds majority interest PM has committed to implement the requirement of IFC Performance Standards and the relevant World Bank Group Guidelines through their corporate-level environmental, social and health and safety management system (ESMS ) which will contain, at a minimum, the following elements:
-Policy: PM will develop an overarching Policy statement of the E&S objectives and principles. consistent with IFC Performance Standards, including principles of FPIC when Indigenous Peoples (IPs) are affected.

-Risks and Impacts Identification Process and Management: The corporate ESMS will define PM?s social and environmental risk and impact identification process. This process will include all the necessary steps and methods that are required to screen, identify, analyze, measure, or assess, in quantitative terms, to the extent possible, the potential risks and impacts (including environmental, social, health, and safety, labor and security) associated with the activities to be developed and assure that the mitigation hierarchy is applied to manage all identified impacts and risks. When applicable, this process will involve an Environmental and Social Impact Assessments (ESIAs) process in line with IFC?s Performance Standards. EPC contracts for each project will incorporate the relevant project-specific mitigation measures and actions identified during the assessment process to ensure compliance with Colombian requirements, as well as IFC PS.

Project-specific mitigation measures will include management of impacts and risks addressed in PS2 through PS8.

In addition as part of the corporate management system, PM will develop an environmental and social risk screening procedure, which considers the capacity of the operators of prospective assets to manage risks and impacts in meeting PM corporate E&S policy requirements. This procedure will provide inputs to the decision whether to pursue the opportunity in consultation with IFC. The corporate management system will also include procedures for continuous monitoring of the existing portfolio. All assets/projects will have their independent ESMS which will be overseen and monitored by PM to ensure compliance with PM policies and procedures.

For assets where PM holds minority interest PM will assess new acquisitions through the risk screening procedures and monitor portfolio projects as described above. Ensuring implementation of the corporate policies at asset level will be on a best effort basis.


Identification of Risks and Impacts and Management Programs
A key component of identifying risks and impacts of prospective projects and developing adequate mitigation measures includes the development of ESIAs. Prior to the formation of PM in 2014 ESIAs were submitted to the environmental authorities and the required licenses granted for PEL, ODL and OB.CT is in the process of finalizing the ESIAs (one for onshore and one for off shore activities) for submission to the local authorities approval is expected by June 2014 while construction is planned to be initiated by September 2014. PM will be involved in the monitoring of the construction phase of PEL.
IFC reviewed the ESIAs for PEL (2010), CT (2014), ODL (2001-2014) and OB (2010) all of which were developed in accordance with Colombian requirements by competent independent consultants. The ESIAs have solid baseline data, comprehensive assessments of risks and impacts and the framework for establishing effective management plans and are overall of high quality. For the two assets with minority interest (ODL and OB) it is concluded through the review of available documentation that they have been developed and are managed in line with Good International Industry Practice (GIIP).
PEL: The ESIA was approved in February 2012 by the competent national authority (Autoridad Nacional de Licencias Ambientales ? ANLA). The ESIA identified key impacts during the construction phase related to the construction of access roads, workers? accommodation and storage areas with potential impacts of erosion, landslides, sediments runoffs to water bodies and dust. Impact on fauna and flora are mainly caused by adjustments to vegetation throughout the RoW (Right-of-Way) corridor to avoid interference with power conductors. The RoW corridor runs through savanna and low grasslands but also through more sensitive areas such as gallery forest and ?morichales?. The ESIA concludes that impacts are generally moderate and can be adequately managed through the implementation of management plans. Loss of vegetation is compensated depending on level of sensitivity from a ratio of 1:3 to 1:6 and a program was developed to rescue the epiphytes (such as orchids ) impacted throughout the RoW. 19,300 epiphytes were rescued from the trees that were cut along the right of way. A program to relocate the epiphytes was established and will be monitored for 4 years. PEL is still in the process of identifying off set locations for impacted forest (compensated at a ratio of 1:5). Alternative analyses for the RoW were conducted and the preferred route was approved by the environmental authority and refined to minimize potential environmental and social impacts. The 230-kV transmission line with 552 towers was constructed within a 32-meter wide RoW that extends for nearly 260 km. The preferred route runs parallel to the existing ODL oil pipeline to take advantage of an existing linear corridor in part of its trajectory. The base of the towers consists of 12x12 meter concrete pads. The transmission line corridor was realigned to avoid impact on protected areas such as national parks and the land of vulnerable communities (displaced communities granted land under the national land-restitution scheme). The RoW easements were negotiated with 260 landowners and did not result in any physical or economic displacement but the process resulted in 20 cases that had to be resolved by the authorities (impositions). Impacts during the construction phase were minimized by using existing roads, placing towers away from the margins and riparian vegetation to protect surface water bodies, and minimizing vegetation suppression, where possible. PEL has an agreement with the public armed forces to provide peripheral protection of the towers. The agreements are drafted in line with the requirements of the Voluntary Principles. A security assessment was conducted prior to the construction phase and updated for the operational phase. To date no security incidents have taken place. It has been certified by the Minister of Interior that the development and operation of infrastructure for PEL has not affected any Indigenous Peoples.
CT: A comprehensive ESIA containing a baseline, impact assessment, economic rationale, management, mitigation, monitoring and contingency plans was prepared for both the onshore and offshore projects by the ANTEA Group. Each project identifies the inherent impacts and risks associated with project activities, and provides a comprehensive and well documented account of the engagement strategy used to map, inform and consult with affected stakeholders, in a timely, open, participatory and culturally sensitive manner, including the process of Prior Consultation (Consulta Previa) carried out with five (5) IP communities located in the area of influence of the onshore pipeline.

Offshore
The general area of influence of the offshore project is the Gulf of Morrosquillo. The direct area of influence was narrowed down to the areas directly impacted by construction, operations, and closure and abandonment activities. For safety purposes, in the area of the offshore platform there will be an implementation of a maritime traffic management plan. The ESIA concluded that the project will result in impacts (deemed moderate) on artisanal fishermen operating in the area although they will still have access to other fishing grounds in the area. The towns of Santiago de Tolu and Palo Blanco are the nearest and most directly affected communities by the project.

The ESIA includes a thorough assessment of the main environmental, social, health, safety, and security risks and impacts of the project per activity and phase of project development. Stakeholders were mapped at the early stages of the assessment and regularly informed and consulted on the project, its impacts, proposed mitigation and management measures. Consultations were documented and concerns were used to inform the mitigation and management process.

During the construction phase development impacts are largely associated with disturbances caused by increased road traffic, movement of large and heavy vehicles and machinery, high dust and noise levels, potential interactions and risk of conflict between the workers with community members, high expectations for jobs and social benefits, visual impacts from boats, cranes and other heavy machinery offshore. Impacts are considered to be temporary in nature, reversible and mitigated with the implementation ofGIIP during civil works.

The area of the gulf is characterized as an important port and shipping town with some artisanal fishing and seasonal tourism activity. Due to the deterioration of the marine environment and the depletion of corals and fish stocks in the gulf, commercial fishing is not feasible. Fishing is done on a subsistence basis by individual fishermen with access to small boats. During the construction phase there will be some restriction on fishing activities, and the usual marine traffic in the area, however, once operational people will have free access to navigate inside gulf waters according to the General Maritime Directorate?s (DIMAR) definition .

Coastal communities in the gulf area are accustomed to co-exist with offshore activities, which play an important role in the economy of the area through the long-term presence of the COMPAS and Ecopetrol who maintains export shipping activities further east. The project is not expected to generate adverse impacts on the overall quality of life of local people, nor the marine environment.

The project will have a policy for hiring local peoples for technical and non-skilled jobs which will reduce workers coming from outside the local area. The offshore personnel are expected to be accommodated on board vessels and also use local hotels. The number of international workers into the area will be kept to the minimum and will mainly consist of skilled labor. This will not adversely impact the social dynamic in the area as the numbers of foreigners to enter the area will be small due to the limited size of the project and the area is already exposed to influx of non-locals and foreigners for the port/shipping activities and for tourism.
The visual impacts will be higher during the construction phase due to the volume of construction related boats and machinery. Once operational, the remnant impacts of the project will be the visual impact caused by the vessels docked and navigating offshore, as well as the permanent fixture of the associated platform facilities which can be seen at a distance on a clear day and in dim lights during the night. The offshore facilities will be continuously monitored by security personnel, which will receive training on how to handle interactions with fishermen and other civilians..

Onshore

The onshore pipeline will extend a total of 80 km with a diameter of 18 in, and a Right-of-way (RoW) of 20 meter across 8 municipalities San Pedro, San Luis de Since, San Juan de Betulia, Corozal, Morroa, Sincelejo, San Antonio de Palmito and Santiago de Tolu.
, all within the Department of Sucre. Portions of the Right-of-Way (ROW) will run parallel to existing pipelines operated by Ecopetrol and Promigas . The width of the trench will be 1.5 m with a depth of 1.5 m.
During the construction phase it is expected that impacts related to dust, increased heavy traffic, potential disturbances on local communities, potential impacts on local infrastructure and residential property, clearing of land/easements, potential contamination of waterways and soils, temporary and permanent loss of crops and trees and other small structures, the generation of solid and hazardous waste, and effluents, will be , mitigated and managed with the use of GIIP, the project has management plans in place to mitigate the above impacts and has committed to implement the PS and the World Bank Group Environmental, Health and Safety Guidelines (WBG EHS).
It is the responsibility of the Ministry of Environment and Sustainable Development to make a determination with respect to the approval of the ESIA?s and ESMP?s and grant the licenses. CARSUCRE, the Regional Autonomous Corporation of Sucre, is the environmental authority responsible for ensuring the protection and conservation of natural resources in the Department of Sucre, where the projects are located in their entirety. DIMAR will review and approve the navigation routes and maritime traffic and signaling, while the National Infrastructure Agency (ANI), through Resolution 1526 of December 2013, will establish the conditions for the FLSU, Puerto Gas Licuado del Caribe (PGLC) concession.

ODL: The areas traversed by the selected RoW have sparse vegetation, are predominantly flat with relatively cohesive soils which prevents severe erosive processes. Soils have a thin organic layer and are relatively shallow, and as a consequence they have been assessed to have a low ecological productivity. The area crossed by ODL was qualified by the ESIA as of low environmental sensitivity. The ODL?s route alternative analysis has taken into consideration the existence of roads to minimize the need to open new accesses to the pipeline and have considered sensitive areas to minimize impacts. Specific provisions for offsets are included in ODL?s environmental license. Offsets vary from 1 up to 7 times the size of the area of intervention, depending on the sensitivity of the site. For this reason the RoW has been kept as narrow as possible ranging from 30 meters to 10 meters in sensitive areas. The project received as part of the ESIA process a certification from the Ministry of the Interior (MI)that there were not Indigenous Peoples present in the project area of influence. However, in 2009 the group of Indigenous Peoples, Humapo opened a case against the MI, Minstry of Envrionment and Metapetroleum (who was the license holder) among others as the Humapo community consider that they should be granted the right to participate in a consultation process considering the proximity of the pipeline to their community. In 2011 the constitutional court ordered MI, Ministry of Environment, The mayors? office of Puerto Lopez, Incoder (Instituto Colombiano de Desarrollo Rural) and ODL to initiate the consultation process which was done in 2012.

The consultation process resulted in partial agreements aiming at strengthening the cultural identity of the Humapo community. The agreements were documented and submitted to the constitutional court in June 2012 together with an outline of the areas where an agreement was not reached. The response from the constitutional court is still pending.

OB: The pipeline runs parallel to an existing road (the national route Carretera Marginal de La Selva) and uses part of the existing ROW. The project lead to the improvement of 180 km of existing roads but did not require opening any new access roads. Although the pipeline route was selected to avoid highly sensitive ecological areas, and to mitigate impacts on epiphytes (including for instance orchids) a rescue program was developed and transplanted epiphytes will be monitored over a 3 year period. The pipeline crosses several rivers with the most important one being Rio Tigre en Arauca. All rivers were crossed underground and construction was done in the dry season to minimize potential impacts from flooding and all river crossings have subsequently been reinstated. Two communities were directly affected by the pipeline route and construction: San Antonio and Carrasto Bajo both located in Casanare. Impacts were temporary and limited to the construction corridor for the pipeline with no economic or physical displacement. OB has an effective contractors? management system which has resulted in very low levels of accidents and grievances during construction of the first phase of the OB pipeline. As part of the contractual agreement during the construction phase contractors followed the OB standards on OHS, labor standards, community engagement and E&S. Compliance was monitored on an ongoing basis by independent consultants (interventores) who were assigned to the contractors E&S teams and reported to OB management on a weekly basis. The same approach will be followed for the second and third phase of the pipeline construction when implemented.
It has been certified by the Minister of Interior that the development and operation of infrastructure for OB has not affected any Indigenous Peoples. For the development of OBneighboring indigenous communities not located in the project area of influence were included in the general consultation process.
PM will develop a consistent corporate Environmental and Social Impact Assessment (ESIA) procedure, according to GIIP, to ensure a comprehensive identification of environmental and social risks and impacts conforming to the requirements of the host country?s laws and regulations, as well as those of IFC?s Performance Standards for any new projects.

Organizational Capacity

PMs Management team is in the process of being developed and benefits from full support from the PRE environmental and social teams. PM will have a committed Environmental and Social Manager reporting to the CEO of PM with an adequate team of professional and financial resources? to implement the E&S Management Plan. The E&S Manager will be responsible for screening new proposed assets, monitoring the performance of portfolio projects and ensuring that the corporate E&S policy and procedures are fully implemented at the assets with majority PM ownership. In addition, as an integral component of the corporate ESHS-MS, PM will retain an external environmental and social advisory consulting firm (ESAC) with extensive and proven international experience applying IFC Performance Standards to help guide the construction phase of CL, the development of the corporate management system and future developments.
The Management teams of PEL, CT, ODL and OB all have competent well-staffed teams to implement the E&S policies and procedures. PEL will ensure that the current and future assets with majority interest will have competent staff and adequate resources commensurate to the E&S risk of the project.

Emergency Preparedness and Response

PEL: PEL prepared a contingency plan for the 230-kV Chivor-Rubiales Transmission Line. This plan includes a risk analysis that identified potential events that could lead to an emergency incident along the transmission line and the substations. Potential events include natural (e.g., lightning, seismic, flooding, etc.) as well as events that could result from human actions or errors (e.g., terrorism, lack of maintenance, forest fires initiated by local practices, etc.). The contingency plan has identified the level of training and qualification required for brigade members, communication equipment, means of transportation, fire-fighting, first-aid and other pieces of equipment needed for proper response in the event of an emergency. In addition, the contingency plan also includes a list of civil defense, army, and local authorities from the various municipalities and towns located along the 260 km transmission line that need to be contacted during an emergency. Furthermore, in order to comply with conditions of the environmental licenses issued by ANLA, PEL will include provisions for potential contamination of surface water bodies (i.e., morichales) located near the Quifa Substation by potential accidental releases of oils. PEL is also required to conduct drills in coordination with municipal authorities and neighboring communities. It is also recommended that PEL include more site-specific details in the existing contingency plan, such as locations of the brigades and key emergency response equipment along the extension of the project.

CT: For the offshore components the project has conducted risk analysis for the submarine pipeline, FSLU and FSU, riser platform and ancillary facilities and based on the assessment determined the mitigation measures as well as a contingency plan. Risk criteria used in the assessment included (i) anthropogenic, sociopolitical or cultural risks with potential impacts to human life; (ii) natural or environmental risks including earth quakes, hurricanes, electrical storms, etc.; and (iii) technical and/or operational risk. The contingency plan has been prepared and include minimization of risks or strategic planning, which will ensure that all emergencies are categorized and responded to in an adequate manner (emergencies are classified as tier 1, 2, and 3), as second component of the plan is an operational plan and the third component include a communication plan to employees as well as other stakeholders including communities in the vicinity of the project. The contingency plans allows for adaptation of the programs and activities resulting from the implementation and/or experience gained during their use.

For the onshore pipeline, the project carried out a number of risk assessment studies, including Consequence Analyses and Layer of Protection Analysis to identify and mitigate risks associated with accidental event scenarios along the pipeline infrastructure. The primary cause of a major accidental event is statistically related to external interference with an active line (e.g. digging). Land practices reported along the pipeline easement are pasturing with limited agriculture, and the pipeline route corridor is sparsely populated, which reduce the likelihood of occurrence of external interference. Worst case scenarios were identified and quantified, including areas of greatest impact. The overall risk of a major leak triggering a major event (flash fire, jet fire and vapor cloud explosion) was considered low. Through implementation of GIIP mitigation measures included in the pipeline design, all residual risks were rated as acceptable or as low as reasonably practicable (ALARP). Mitigation measures include, among others, adequate thickness of the pipeline walls, depth of pipeline burial (>=1.5 m), increased burial depth at infrastructure crossing, adequate buffer in under crossing existing active pipelines, block valves and emergency shutdown system, and pipeline integrity monitoring through fiber optic sensing cables and operational procedures for intelligent pigging and line patrolling. Taking into account the proposed preferred route, the presence and location of existing active oil and petroleum product pipelines, the location of households and other public infrastructure in the project area of influence, the Company will review and update, as needed, the studies performed since 2012 and carry out a Quantitative Risk Assessment, with due consideration of pipeline detailed design at crossings with existing active lines and in sections where the proposed pipeline is parallel to other lines, to ensure that risks, including potential domino effects in case of an accident, are mitigated. A Contingency Plan, including emergency preparedness, operational and communication, has already been developed, as presented in the ESIA, and will be reviewed, made operational and kept up-to-date during the Project life.

The ODL pipeline has emergency valves (shut-off valves) located every 35 kilometers and pressure indicators every 25 kilometers. A SCADA system monitors key factors (such as volume, pressure, temperature, and valve status) and different alarm systems give early warning to the SCADA controllers. The pipeline is protected from external corrosion by a cathodic protection system. ODL has an alliance with two other companies operating in the area, HOCOL and CEPCOLSA for emergency response and spill contingency plans. The shared spill contingency bases are located in Puerto Gaitan and Tauramena having a capacity of up to 15,000 barrels. Emergency drills are conducted on a yearly basis with the municipalities and the firefighters brigades.
OB has emergency preparedness and response plans and oil spill contingency plans for the operational phase of the project. For communities within the area of influence of the pipeline OB has a cooperation with the Colombian Red Cross to implement community emergency response plans. Emergency drills are being conducted at the workplace (monthly), with local authorities and communities (twice a year) and at national level (yearly). For larger emergencies and spills OB has an agreement for support with Varichem an independent contractor with equipment that would support Tier I, II and III. Varichem has a strong presence in Colombia servicing 40% of the oil industry including Ecopetrol and PRE.

As part of IFC?s investment, PM will review and update corporate-level procedures for emergency response and oil spill contingency plans including adequate training of employees and contractors to ensure consistent and effective implementation of corporate standards.

Monitoring and Review
PEL: As condition of the environmental licenses issued by ANLA, PEL prepared Environmental Compliance Reports (Informe de Cumplimiento Ambiental ? ICA) that were submitted to the ANLA every six months during the construction phase. During operations, the ICAs will be submitted on an annual basis. The ICA present results of all monitoring programs included in the Environmental Management Plan.

CT: The ESMP includes a monitoring, inspection and audit program with key performance indicators (KPIs) to track construction and operational performance of the project against environmental, social, health, safety, security and quality criteria. Communities, including the IP and fishermen groups, will be given opportunity to work on monitoring activities in relation to impacts on flora, fauna, and other areas. Following approval of the environmental permit, the project will monitor marine conditions on a quarterly basis or as required by the license or regulations. In addition, as an integral component of the corporate ESMS,

PM corporate staff will monitor E&S performance of future developments against ESIA based action plans, as well as established monitoring protocols and metrics (e.g. air emissions, air quality). The results of routine monitoring and measurement activities carried out at the project level, as well as any environmental or safety incidents will be recorded. In addition, PM will implement a formal E&S audit program to further ensure environment and safety performance for all its business activities. Non-conformances with established standards and metrics and the related corrective action recommendations will be recorded and tracked. Monitoring thresholds will be consistent with those referenced in the applicable IFC EHS Guidelines and Colombian environmental quality standards. Monthly, quarterly, and annual operations and environmental performance data will be consolidated into reports and made available to PM senior management. The results of E&S monitoring will be evaluated and documented at both individual sub-projects and corporate level. Reports will furnish the information and data needed to determine compliance with the corporate E&S Policy and ESMS. The format of these reports will include a summary of findings and recommendations.
In addition, as an integral component of the corporate ESMS, PM will hire an independent ESAC (Environmental and Social Advisory Consulting Firm) with extensive and proven international experience applying IFC Performance Standards, that will closely supervise PM?s sub-project compliance with IFC PS, supervision focus will be on the construction phase of CT but the scope of the external monitor will depend on the risk profile of the assets. This supervision will include periodic site visits as well as documentation review, and the development of corrective action plans if any breaches are encountered during supervision activities.

The operations of PEL and CT have fully adopted the PRE Human Resources management system. PRE has a comprehensive HR management system including policies and procedures covering direct staff and contractors. The grievance mechanisms for the different operations are designed to cover employees and contractors. Employees of contractors are informed about the grievance mechanism through the induction program and through regular health and safety meetings. The HR management system focuses on contractor management outlining requirements related to working and employment conditions as well as freedom of association and prevention of child labor. All labor requirements for contractors and subcontractors are included in the legal agreements and compliance is monitored by an independent third party (COTECNA) as well as by National Energy Industry Union (UTEN). PRE has explicit policy commitments and procedures to ensure freedom of association both for direct staff and contractors.



Occupational Health and Safety (OHS)



PEL has developed and adopted an Integrated Health, Safety, Environmental and Quality (HSEQ) Policy, which has been formally approved by the Company’s Board of Directors. The HSES Policy states that Company seeks to be a leader in the sectors it operates by applying the best industry practices. The priority of the Company is the protection of the people and the environment and the mitigation of risks and impacts associated with the company’s activities. PEL’s HSEQ Policy applies to all company’s employees, contractors and subcontractors. PEL has also developed an Integrated Management System Manual, which are based on ISO 9001, ISO 14001, and ISO 18001. PEL’s Occupational Health and Safety Management System (OHS-MS) presents procedures for planning, organization, execution and evaluation of all measures related to the protection, preservation and improvement of workers’ health and safety. PEL’s OHS-MS includes three main sub-programs 1) Preventive Medicine (medical surveillance and measures to prevent occupational hazards and diseases); 2) Industrial Hygiene (measurement and controls at the work place); and 3) Industrial Safety (identification, reporting and controls to prevent OHS accidents). Contractors and subcontractors are contractually compelled to comply with all national OHS and environmental requirements as well as specific requirements included in PEL’s HSEQ Policy and management systems. Prior to being accepted to provide services to PEL, all contractors’ workers and subcontractors must present evidence of periodic medical examination, vaccinations, qualification to perform their duties, and certifications, as needed. In addition, each contractor must prepare an OHS plan that identifies the risks associated with the services provided (e.g., working at height, handling of hazardous substances, transport of hazardous cargo, exposure to radiation, live-wire works, use of communication/photography and video equipment). In addit
ion, contractors and subcontractors must include road safety measures since the operation and maintenance services require road trips along the transmission line and to substations. Contractors must conduct and maintain records of inspection of vehicles, tools and pieces of equipment.



PEL inspects and audits contractors to verify contractors’ performance and to review records. Contractors and subcontractors must also prepare an emergency response plan tailored to the risks of the services they provide. PEL will require a weekly report from each contractor with information regarding total number of km covered by the contractor, total personhour, and number of accidents and other OHS performance indicators. PEL also require that contractors and subcontractors submit monthly and quarterly reports with OHS performance indicators.



CT: EXMAR will conduct risk assessments across all activities to ensure that Health and Safety risks are fully assessed, addressed, and communicated to all workers, both in training as well as in day to day communications and flyers.

The Company will develop and implement an induction system and occupational health and safety training program for all of its personnel and contractors. The program will cover training in measures to prevent, avoid, mitigate and manage the range of potential environmental, social, health and safety risks and impacts of each activity; application and use of personal protective equipment (PPE); the environmental setting, sensitive areas and any restrictions and conditions established in the ESIA and license; life and fire safety; contingency planning and emergency preparedness and response.

EXMAR will establish a formal health and safety incident reporting system to document and track incidents, implement and track corrective and preventative measures as required. As part of the ESMS Exmar will develop OHS policies, procedures and performance indicators in line with PS2 requirements.



In terms of labor issues at the corporate level, PM will develop a Human Resources Policy in accordance with Colombian labor laws and IFC’s PS2 requirements which will clearly define the rights and obligations of employees and the employer, including: compensation and benefits; working hours, overtime and leave policy; occupational health and safety policy; grievance redress procedure; rights to join worker’s organizations and to bargain collectively. According to local labor laws, all employees must receive copies of their contracts upon being hired. Additionally, as stated under PS1 above, PM will develop an integrated ESMS which will be applied across all of its operations and sub-projects. The ESMSwill include Occupational Health and Safety (OHS) as an integral component, and as a minimum, will assure that: all work processes and tasks’ OHS hazards and risks are well identified; safety risks are evaluated based on the nature of the hazards, magnitude of the risks and consequences, frequency and pro
bability of exposure/occurrence, and potential severity of harm; and these potential hazards are managed in compliance with GIIP. Management strategies will include appropriate process design, mandatory use of personal protection equipment, definition of minimum qualification, training and restrictions, success indicators and clear supervision and reporting mechanisms.

Atmospheric Emissions, Including Greenhouse Gases (GHGs)



PEL: Through the implementation of the 230-kV line that connects the Chivor Substation to the Rubiales Field the project has resulted in significant reduction of diesel power generation stations that were used to support oil field operations at the Rubiales and Meta Fields. The Chivor Substation now delivers cleaner electrical energy from the Chivor Hydroelectric Power Plant to Rubiales and Quifa Substations. This results in overall reductions in annual GHG emissions of 180,000 tons. Additional sources of GHG emissions include PEL’s vehicle fleet. The Company has a vehicle maintenance program that also applies to its contractors and subcontractors. This program aims at maintaining vehicles operating at optimum working conditions, which results in more efficient and cleaner emissions.

Sulfur hexafluoride (SF6) is used for isolating purposes in switching equipment at substations and maintenance shops.  SF6 is a greenhouse gas with a significantly higher global warming potential (GWP) than CO2, therefore its use should be minimized. . In alignment with GIIP, the Company will develop procedures to detect leaks and prevent emissions.

CT: (Gas Pipeline-Offshore and LNG Terminal) - Air emissions during the construction of the offshore component of the project are expected to be punctual and of short duration. The project will maintain a monitoring plan and implementation will be checked on a regular basis. The monitoring plan will include the adequate maintenance and functioning of all vessels equipment and machinery in the direct area of project influence. The plan will also ensure that proper air emissions certifications are updated on a regular basis. Annex VI of MARPOL 73/78 establishes the standards for vessels with regards to atmospheric emissions, although the Government of Colombia has not ratified these standards it is expected that all foreign vessels have the appropriate certification. Verification of all equipment will be conducted prior to installation so to meet operational specifications. Once installed and during operations air emissions testing will be conducted on a regular basis.

The emission rates of Greenhouse Gases (GHG) associated with the project were calculated with direct as well as indirect emissions of GHG. For the calculation, the IFC Carbon Emission Estimation Tool was used in conjunction with the appropriate Global Warming Potential coefficients (GWPs). The annual GHG emission rates for the project have been estimated to be 197,000 ton/year, attributed to the refrigerant compressor gas turbine as the main source of emissions. Electrical generators and fugitive emissions have a lower contribution to the GHG, and associated emissions are considered negligible for the project. The Project will establish a monitoring program for their GHG emissions and identify cost-effective GHG reducing measures.

Management of Waste Streams



PEL: During the const
ruction of the transmission line and substations, a waste management plan was implemented in accordance with the procedures described in the Environmental Management Plan.,. Liquid wastes generated during construction were treated prior to discharge to the environment. As per conditions of the environmental licenses, soil and groundwater were monitored to demonstrate that the discharges did not adversely impact the environment. Results and evidence of the implementation of the waste management plan during constructions were submitted to ANLA in the Environmental Compliance Reports (ICA – Informes de Cumplimiento Ambiental).

During operations, some industrial and domestic wastes are generated. Domestic wastes generated at PEL’s offices (e.g., paper, cardboard, plastic bottles, organic waste, etc.) will be segregated for recycling and non-recyclable wastes will be disposed at municipal landfills. Industrial operations generate used light bulbs, batteries, used filters, used oil, electric wires/cables, used transformer oil, etc. Good waste management practices described in the Environmental Management Plan include the return of potentially hazardous wastes to the original product manufacturers for such wastes as old mercury lamps, alkaline and acid base batteries, and used tires from the Company’s fleet. Volumes of wastes generated, stored and disposed will be entered into the Company’s HSEQ-MS and presented to ANLA in environmental compliance reports. Records and reports documenting the transport and disposal of such waste streams will be maintained by the HSEQ Department.

CT: (Gas Pipeline-Offshore LNG Terminal) - As part of the construction of the offshore and onshore facilities PRE has established programs for the management and monitoring of solid waste, liquid waste, and any hazardous waste generated.

All vessels (FLSU, FSU and carriers) will be required to have decantation tanks, system for separation of water and hydrocarbons, and a filter system. The project will generate no contaminated effluents. The bilge water will be stored on board for transportation to authorized onshore facilities for final treatment and disposal. The project will comply with the standards set by MARPOL 73/78. The management of sewage, bilge and ballast water will be conducted in accordance to GIIP and relevant local, national and international regulations, whichever are the most stringent.

The project has established management plans that include evaluation of the sources of solid waste and defines the procedures for the reduction, handling, storage, transportation, recycling and final disposal.

During the operation phase of the FLSU there will be discharges of water to the sea due to the refrigeration and condensation process of the liquefaction system. Modeling of the dispersion of the thermal plumes from the liquefaction cooling circuit and the engine room cooling outlets was carried out using Computational Fluid Dynamics (CFD) techniques, in orde
r to assess potential impacts from thermal discharges and confirm compliance with applicable WBG EHS Guidelines for LNG Facilities (temperature increase of no more than 3° C at 100 m from point of discharge). The heat exchange system of the liquefaction unit cools the gas, rejecting heat to the open seawater circuit and subsequently discharging the seawater at an increased temperature back into the sea. Under the credible scenarios modeled (horizontal and vertical discharge, discharge velocity of 2 to 4 m/s, and negligible / 0.25 knots (predominant) current velocity, temperature variations at discharge up to 10° C), the model provided the iso-surfaces of constant temperature at 1, 2 and 3° C above ambient seawater temperature, as well as flow velocity in the region surrounding the discharge points, including at the seabed. The modeling results for all scenarios show that the simulated thermal plumes is well below 3° C within a radius of 100 m of the point of discharge, including near the seabed, due to the relatively low flow rates expected for the discharges. The preferred configuration is horizontal discharge to minimize the risk of potential seabed scouring. Exmar will ensure that the temperature of the seawater discharge is maintained below 40° C at the outlet.



Water Consumption

PEL: During construction the intake of water for workers’ accommodations, temporary offices and in the construction (e.g., concrete) was authorized by ANLA. PEL applied good practices for the uptake of raw freshwater from surface water bodies and for the discharge of treated sanitary effluent to the environment. The conditions of the environmental licenses require that monitoring wells be installed around the substations to monitor groundwater quality and ensure that the discharge of treatment of sanitary effluent as well as from stormwater system at the substations do not adversely impact water resources.. The operation and maintenance (O&M) of transmission lines and substations does not require much water; therefore, the PEL project is not considered a potentially significant consumer of water.

CT (Gas Pipeline-LNG Terminal) - For the offshore component the Project will require the use of marine water during the construction and operational phases. During operation, the amounts used for the liquefaction process (on board the FLSU) will amount to 5,800 m3/h, for the condensation process (on board the FSU) 15,825 m3/h and for the auxiliary systems 860 m3/h. The Project will establish a process of reverse osmosis for the treatment of the water to meet project specifications. The intake of marine water will not cause any adverse impacts to the marine biodiversity or to any local communities.

Most of the water will be used for hydrostatic pressure testing of the pipeline and for cooling systems. The water used in the hydrostatic testing can be recycled for the different phases of testing. Water for domestic consumption will be purchased from external suppliers
(e.g. bottle water) or through local infrastructure, or can be generated onboard the FLSU and FSU.

The onshore pipeline (80 km) will require an approximate volume of 28,107 meter cubic for the hydrostatic pressure testing. PRE envisions recycling the water used in the different pipeline sections to complete the testing; the water will be purchased from the water aqueduct services or public entities. PRE will ensure that entities have the appropriate authorization for the resource. Additionally, PRE will have the possibility of using the excess water generated at the La Creciente Gas field.

Hazardous Materials and Oil Management

PEL: the construction and operations of transmission lines and electrical substation do not require significant qualities of hazardous materials. The insulation oils used in the transformers are of mineral origin. In addition, in alignment with GIIP, the power transformers, which contain the greatest quantities of oil, are constructed on top of containment structures that can hold the contents of the transformer in the event of an accidental release.

Based on the information presented in the Environmental Management Plan, RoW and grounds maintenance will include mechanical controls (i.e., vegetation trimming or suppression), without the use of pesticides or herbicides.



CT: Sludge and used oils will be collected and transported for disposal and/or recycling by Oil Recovery Systems Company (ORCO) an authorized company with the appropriate facilities for final treatment and disposal. PRE has conducted audits of ORCO’s facilities as well as the vehicles that will transport the waste and is satisfied that ORCO meets the requirements under Colombian regulations for a service provider, including training of personnel, and emergency plans.

PEL and CT have developed Emergency Response Planning procedures addressing safety and emergency preparedness and response, based on a rigorous assessment of risk to the health and safety of affected communities and external receptors from activities. They coordinate closely with local authorities for response planning and communities are trained in emergency response through the stakeholder engagement program.

All companies focus on road safety and during construction and transportation of goods through defensive driving training of both staff and contractors. The traffic accident indicators have been very low during construction and operational phase for all companies

Security Personnel

PRE has an explicit commitment to respect Human Rights in all aspects of their operations and to manage stakeholder engagement on the basis of the UN Guiding Principles on business and human rights and the Voluntary Principles for security and human rights. Use of armed public and private security forces is managed in line with the requirements of the Voluntary Principles.

PEL has not had any security incidents during the construction and operational phase of the project. PEL has negotiated an agreement (Convenio) with the armed public forces to provide peripheral protection in line with the requirements of the Voluntary Principles. The agreement includes training on human rights for the units involved in the protection of the transmission line. Prior to the construction phase a security assessment was conducted which was updated for the operational phase.

CT: When project activities are initiated, EXMAR and PRE will ensure that all third party contractors hired to secure the offshore project facilities and its workers have received the proper training in the use of weapons and force with civilians or other personnel, in alignment with PS 4 on Security Personnel. Where military personnel are involved in providing support in security matters, EXMAR and PRE will ensure that the agreements are in line with the Voluntary Principles.



PM as part of this investment will adopt a corporate level Security Forces Management Policy and Procedures to ensure that any engagement of public or private security forces to protect the facilities where PM has majority interest will follow the requirements of IFC PS4 and the Voluntary Principles. The current agreements (Convenios) for assets with majority and minority interest will be assessed by an independent third party to ensure compliance with the Voluntary Standards In the case that any gaps are found for the assets with majority interest PM will ensure these gaps are closed within a feasibly timeline and for the assets with minority interest best effort will be applied to address the identified gaps.

The PEL transmission line ROW (Right-of-Way) corridor crosses savanna and low grasslands but also more sensitive areas such as gallery forest and ‘morichales’. The ESIA concludes that impacts are generally moderate and are adequately managed through the management plans. Loss of vegetation is compensated at a ratio 1:5 and a program was developed to rescue the epiphytals impacted throughout the ROW.

The ESIA for PEL did not identify any species being classified as globally Endangered or Critically Endangered (IUCN Red List of Threatened Species). The ESIA has identified a few species listed as endangered and critical endangered by Colombian regulation in the project area of influence. Although, these species will not qualify the area as critical habitat these species will be included in the monitoring program.

The construction and operation of the PEL transmission line does not impact critical habitat but does cross areas of natural habitat. The transmission line was realigned to avoid crossing the ‘Parque Natural Municipal Yucao’ and now runs parallel to the park.

Prior to initiating the construction phase PEL conducted an inventory of all trees located in the ROW including those which had to be cut or relocated.

The mitigation requirements for no net loss of biodiversity are being met by the project through avoidance of sensitive areas and minimization of impacts (e.g. avoiding development of access roads and using mules for transportation, realignment of the transmission line to avoid a Natural Park), rescue and relocation of fauna and restoration of impacted areas at a ratio of 1:5.

The continuous monitoring of PEL’s operations will track and evaluate whether the restoration efforts are successful in achieving no net loss of biodiversity. The monitoring program will include assessment of potential impacts on bats and birds from collisions with the transmission line.

PM will develop, as part of the corporate ESMS, a Biodiversity Conservation and Sustainability Management of Natural Living Resources Framework, that will be applied across all PM business activities to assure that any project affecting either natural or critical habitat will comply with the requirements of PS6 by fostering the protection and conversation of biodiversity, maintaining the benefits from ecosystem services and promoting the sustainable management of living natural resources through the adaption of practices that integrate conservation need and development priorities.



CT: According to the Marine and Coastal Continental Ecosystem Maps for Colombia the area of influence of the project is located within the Tropical Atlantic region of the Caribbean Sea. Analysis conducted by the Project did not identify any vulnerable or sensitive ecosystems with respect to marine vegetation or coral in the area of direct influence of the project. Assessments of the area were conducted during dry and wet seasons through the period of November 2011- March 2012, for the cha
racterization of the biodiversity and ecosystems of the region of direct and indirect influence of the project.

Studies conducted in the Gulf of Morrosquillo and vicinity indicates the presence of five marine mammals that use the area as migratory route. Species such as the Estuary Dolphin and Bottlenose Dolphin were sighted in the south and middle part of the Gulf. However, during the process of consultation, communities indicated that the Manatee is not common to the area of the Gulf but it resides mostly in the areas of the swamps and estuaries.

Based on the Colombian national classification, one vulnerable species -the Dolphin Sotalia guianensis- and two threatened species the Bottlenose Dolphin and Spotted Dolphin are present in the Gulf area. Additionally, within the larger study area four types of turtles were identified but only one has been sighted by the communities in the area of influence of the project. The project is not located within any of the protected areas or natural reserves that are along the Gulf of Morrosquillo.

The Project will implement monitoring and management plans including: (i) prohibition of fishing and capture of marine species, (ii) training programs on environment and biological resources with employees and community members, (iii) incorporation of protection system in the marine water intake to minimize capture of fish, (iv) rescue, monitoring, and relocation of turtle nest if encountered during construction, and (v) monitoring of marine mammals by marine observers during all phases of the project. The implementation of these programs will include capacity training, regular inspections and review of reports.

The onshore pipeline in the majority of RoW will not cross any of the areas of Protected Areas or National Parks, however, according to the ESIA there are some areas that fall under the classification of natural protected areas. In the area of influence of the project there is a species of fauna classified by IUCN as in danger, and two are vulnerable. The Project has management plans in place which includes among others the management of fauna, proper use of vegetation, and a re-vegetation program. The plan calls for a 100% training of PRE/contractors personnel in the protection of biodiversity and environmental aspect along all activities of the project.

The IP certification process in Colombia is conducted by the Minister of Interior and is a well structured and documented process that includes site visits, community consultation, and participation of qualified anthropologists. The process provides adequate safeguards for communities’ rights and uses IP identification criteria that are consistent with IFC PS7. The Process of ‘Consulta Previa’ as per Colombian legislation follows the process and achieved objectives that are consistent with Free, Prior and Informed Consent.



CT: The Ministry of Interior confirmed the existence of five (5) communities of Indigenous Peoples San Miguel (246 families), La Peñata (110 families), Maisheshe (90 families), Cabildo (244 families), and Puerto Viejo (112 families) in the area of influence of the onshore pipeline through the ESIA process.



Through this process the Colombian Government certifies that these IP communities have collective rights to their territories and traditional collective political organizations such as cabildos and consejos comunitarios, and distinct cultural identities. Colombian law (Law 70 of 1993) requires that Indigenous Peoples be treated in accordance with the principles of ILO Convention 169 (Indigenous and Tribal Peoples Convention), granting these groups tribal and indigenous status and rights. A key component of the process is the right to Prior Consultation ‘Consulta Previa’ which is a thorough and systematic process that is carried out prior to requesting the environmental license. The process of Prior Consultation consists of a range of participatory workshops with the objectives to ensure i) fully understanding of the project and its potential impacts, ii) allow for identification of community related impacts and iii) define mitigation measures including change in project design that are acceptable to the IPs. The process is only deemed successful when an agreement is reached between the parts and confirmed by the regulating authorities. The Ministry of Interior participates in all steps of the process of Prior Consultation ‘Consulta Previa’ and acts as a guarantor of the rights of IPs and the integrity of the Prior Consultation process.

Project related impacts identified through the ESIA process and consultations with the IP communities are temporary of nature related to the construction phase and mitigated and managed through the use of GIIP. Through the process of Prior Consultation ‘Consulta Previa’ each IP community identified the main risks and impacts relevant to their community and identified acceptable mitigation and management measures for each activity. The IPs concerns and recommendations were collected and documented as part of the Prior Consultation ‘Consulta Previa’ process described in the ESIA and integrated into the pipeline routing and ESMPs.



One of the mitigation measures agreed on is participatory monitoring during the design and construction phase to identify and avoid impacts on sacred grou
nds and medicinal plants.

The engagement process carried out by PRE with the IP communities is consistent with the principles and requirements of IFC’s PS 7 requirements and allows for documenting the free, prior and informed consent (FPIC) by the affected IPs of the project.



As part of the corporate ESMS, PM will develop procedures to ensure adequate management of impacts and engagement with Indigenous Peoples in any of the project with PM majority ownership as per Colombian Regulation and in line with IFC PS7.

CT: Archeological studies were carried out in the area of influence of the onshore pipeline in accordance to terms and conditions provided by the Colombian Institute of Anthropology and History in archeological license No. 1986 of 21 February 2011, No. 2799 of 26 June 2012, and No. 3727 of 23 October 2013.

As part of the archaeological assessment in the area of influence, consultation with communities were conducted to reconstruct the regional and local aspects of archaeology as well as inspections to the total length of the pipeline, and 1013 sample points were collected, The field assessment were conducted in two stages from November-December, 2013 and January 2014. The impacts to the archaeology in the pipeline route will mostly be during the construction phase. The ESIA has identified four (4) archaeological sites along the pipeline route in the municipalities of Tolu, San Antonio de Palmito, Since and San Pedro. The Project will conduct the appropriate rescue of the artifacts of these sites in accordance with the Colombian regulations. Part of the objectives of the rescue will include the constant monitoring of the area during the striping of soil and opening of the trenches, in addition, training of the value of archaeology will be conducted with the employees as well as the communities in the area. The Project will have an archaeologist on site to monitor the rescue activities. Once the archaeological artifacts are rescued and register, the Project will make this information public and they will be stored in appropriate places selected by the Colombian Institute of Anthropology and History (ICANH). The Project has established preventive methods for the preservation of archaeology in the area of influence.

At the offshore site, scientists covered 10 areas, up to depths of 70 m below sea level, no artifacts or findings of archeological importance were discovered.

The ICANH cleared the findings on the basis of the implementation of legal procedures and requirements established by law, the Archeological Program in the ESMP, and the “Chance Find Procedure”. The project will ensure that the Archeological Plan considers and aligns with IFC’s requirements on PS 8 on Cultural Heritage.

PRE follow a systematic stakeholder engagement process aligned with the corporate social responsibility policies and procedures established at the corporate level. Each project has a stakeholder engagement plan (SEP) which is prepared to meet the specific stakeholder engagement needs of each community. The project hires qualified social experts to carry out the socializations. Upon mapping stakeholders, PRE establish contact with local authorities to identify and better understand the socio-cultural profiles of each community and how best to engage and address their needs. The underlying principles guiding the process are to establish open, transparent and participatory dialogue with the parties in a culturally appropriate manner. Stakeholders are informed of the project and its potential impacts, and invited to provide comments on mitigation and management measures. The outcomes of all consultations are adequately documented.
PEL: The transmission line crosses 47 communities who were all included in the consultation process which was initiated during the phase of project design as required by Colombian legislation and continued throughout the construction phase. Apart from focusing on project design, identification and mitigation of impacts the consultation process focused on local recruitment, local procurement and social investments. PEL has a widely disseminated grievance mechanism where communities can raise concerns related to the project and contractors.
CT: The stakeholder engagement strategy and process is in line with the principles of Informed Consultation and Participation (ICP) and the requirements under PS7 on Indigenous People. The project will maintain ongoing, open and transparent dialogue with affected stakeholders through the construction phase and into operations of the projects.

Exmar and PRE will have a Grievance Mechanism in place to address concerns and complaints raised by stakeholders during the construction and operations phases of a project. The grievance procedures are disseminated effectively to affected stakeholders. Exmar will enhance the documentation and management of grievances to ensure timely recording and response to grievances and to fully integrate the grievance mechanism into the ESMS to ensure that grievance trends will provide guidance for management decisions and allow for identification of root causes of ongoing grievances.
External stakeholders will be identified as part of the ongoing stakeholder mapping and receive information about the project as needed through the most appropriate communications medium (e.g. Radio, internet, local newspaper, town hall meetings, etc.).

ODL: Stakeholder engagement is an integral part of the ODL management system. The Social Management Plan requires continuous engagement from the early phases of project design throughout the construction and operational phases of the project. The Social Management Plan outlines procedures for training of project staff and contractors to ensure ongoing implementation of the social policy at all levels of the organization. In addition to the regular stakeholder engagement designed in relation to the specific activities annual meetings with relevant stakeholders are conducted to provide an overview of project development and implementation of mitigation plans and social investments. The grievance mechanism is a central part of the stakeholder engagement plan and corporate management system. Senior management receives a grievance status report on a monthly basis and trends are analyzed to identify and address root causes for grievances.
Community investment strategy focuses on education, health, culture and sports, institutional strengthening and income generating projects. All community investments are defined in close consultation with affected communities and measures are taken to ensure sustainability.
OB: The stakeholder engagement plan for OB is aligned with the strategic management plan of Ecopetrol. The strategy involves early engagement with communities in project areas of interest focusing on the dissemination of project related activities, environmental and social management plans, local recruitment and procurement and community investments. Continuous interaction with local authorities and communities in the area of project influence is done through workshops on the above topics including workshops to engage with contractors, emergency response plans and project closure plans as well as workshops related to ESIA development and management plans as required by the authorities. Meetings with stakeholders in the area of influence take place at least on a monthly basis. A Grievance Mechanism is part of the social management system, grievances are responded to within 10 days and senior management is provided with monthly reports on the grievance status to ensure that root causes for grievances are addressed at the appropriate levels. Community investments are focused on recreational infrastructure, education, basic social infrastructure, income generating project, health and institutional strengthening,

Name: Julio Bucci
Title: Operations Manager
Company: Pacific Midstream
Address: Calle 110 No. 9-25 Piso 15
Tel: +571-5112000
Mail to: mailto:jbucci@pacificrubiales.com.co
Website: http://www.pacificrubiales.com

IFC has determined that there is overall Broad Community Support (BCS) for the onshore La Creciente - Tolu Pipeline being developed and operated by PRE which is one of the assets being managed by Pacific Midstream. IFC’s determination of BCS took into account: i) the level of impact and risks related to the project in the construction and operational phase and the vulnerability of affected communities, ii) the level of community engagement conducted to date commensurate with the impacts related to the development and operation of the pipeline; and iii) the review of project documentation and outcome of interviews conducted with key stakeholders within the area of influence. As part of its regular supervision of the Project, IFC will verify that PRE conducts an ongoing process of Informed Consultation and Participation (ICP) as per PS1 through the construction and operational phase of the project. *ICP - Information Consultation and Participation **BCS - Broad Community Support

Title	Anticipated completion Date
Pacific Midstream Pacific Midstream will assign specific responsibilities for E&S issues to a qualified personnel within PM’s organization with the adecuate authority and budget to implement the HSEC Mangement Program.	07/31/2014
Pacific Midstream will develop and implement a corporate integrated environmental, social, labor, health, safety and security policy and management framework.	08/30/2014
Hire an external environmental and social advisory consulting firm (ESAC) to monitor and confirm the environmental, social, health safety and security policies and IFC Performance Standards.	08/30/2014
Pacific Midstream will screen current agreements with security forces (private and public) for all assets against the requirements of PS4 and the Voluntary Principles. For assests with majority interest PM will amend the agreements to address any gaps identified for assests with minority interest PM will apply best effort to close any identified gaps.	12/15/2014
For La Creciente pipeline and the offshore facilities Pacific Midstream will: Enhance the current Grievance Management System and include a specific procedure for grievance management for Indigenous Peoples Communities	07/31/2014
Prepare a schedule for the development of Management Plans required for the construction phase for all Project components. The schedule will outline the delivery timeframe, scope and resources required to produce each of the Management Plans. The content of the Management Plans will be agreed with IFC prior to construction commencing on the relevant Project component.	07/31/2014
The Project will prepare a schedule for the development of Management Plans required for the operations phase for all Project components. The schedule will outline the delivery timeframe, scope and resources required to produce each of the Management Plans. The content of the Management Plans will be agreed with IFC prior to the operations phase commencing on the relevant Project component.	03/31/2015
The Project will develop a register to track status of each of the commitments made in the ESMP. It will outline how the Project intends to meet the commitment including relevant information such as: respective management plan, procedure, action plan and/or strategy.	07/31/2014
Carry out a completion audit of land/easement acquisition	07/31/2014
Develop an Influx Management Plan for the construction phase	07/31/2014
Review and update the risk studies performed since 2012 and carry out a Quantitative Risk Assessment, with due consideration of pipeline detailed design at crossings with existing active lines and in sections where the proposed pipeline is parallel to other lines, to ensure that risks, including potential domino effects in case of an accident, are mitigated.	09/30/2014