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

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

IFC has categorized this equity investment as a Category A project, according to its Policy on Social and Environmental Sustainability (January 1st, 2012). The rational underlying this categorization is based on the well documented significant adverse biodiversity risks associated with soybean sourcing in the ecologically sensitive Humid Chaco in Argentina and Paraguay, and in the Amazon and Cerrado biomes in Brazil.

Key E&S issues associated with this equity investment are: (i) corporate EHS policies, operational licenses and permits for all the industrial facilities and farms under direct management; (ii) environmental, occupational health and safety (OHS), food safety and social (including labor) management systems and related procedures, including ISO 14001 / OHSAS 18001 certification at industrial facilities (PGSM, Saforcada) and the seed processing facilities (Venado Tuerto, La Ballenera and Chacabuca), ISO 22001 at crude oil refinery (Valentin Alsina) and RTRS certification at farming operations, EHS organizational structure and internal technical capacity for effective environmental and social management system (ESMS) implementation, monitoring and reporting of Nidera and country-level’s EHS management system and performance; (iii) adherence to country-level labor law, working conditions, standards and OHS risk prevention and management, including employees (permanent and casual), contractors and nearby communities; (iv) emergency preparedness and response, including Life and Fire Safety (L&FS) provisions; (v) use of public utilities (water supply and energy) and sustainability, water and energy use efficiency at industrial facilities and farms through design and adoption of best agronomic practices, including no-tillage and mulching, storage, use and handling of Crop Protection Products (CPPs), including pesticides; (vi) wastewater collection and treatment, solid waste disposal, noise, air emissions from generators and boilers, including greenhouse gas emissions (GHGs), potable water quality, treatment and monitoring, hazardous material (ref. used oil) storage, handling and disposal; management and control of pest and rodent; (vii) engagement with communities, community health, traffic safety; viii) land acquisition/leasing process, consultation and compensation; ix) supply chain risk assessment on ecologically sensitive biomes and potential biodiversity loss; and, x) social performance.


Key environmental and social issues and mitigation

To ensure that Nidera complies with its own corporate policies, country-level’s environmental, labor, OHS, and social laws and regulations, IFC’s Performance Standards (PSs) and WBG EHS Guidelines (General and sector-specific vegetable oil production and processing), Nidera will implemented the measures summarized below, and in the attached Environmental and Social Action Plan (ESAP) which has been agreed upon by Nidera and IFC, and which will address any compliance gaps with the PS requirements.

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 Policies. At Nidera, social and environmental responsibility is part of everything the Companies does. It is a combination of developing its activities in an ethical manner, treating peoples fairly, with dignity and respect, constructing stable relationships with its supply chain, preserving the environment, and assuming strong community engagement. In order to operationalize its corporate values of integrity, efficiency, commitment, respect and accountability, Nidera has adopted a series of corporate policies, procedures and programs under five pillars: 1) for its corporate governance, a Social Responsibility Policy, a Code of Conduct (under review in 2014) and an Employee Grievance Mechanism (under review in 2014); 2) for its direct and contractual employees, a Human Right Policy, a Human Rights Due diligence procedure and a corporate Workplace Health and Safety Policy; 3) for its value chain, Standards for business partners; 4) for the environment, a corporate Environmental Policy; and, 5) for communities neighboring its operations, a School of Values Program, a Talented Youth Program and a Rural Values Program. Nidera?s values, pillars, business principles, and policies fit into its integrated approach to CSR, which is based on acquired knowledge, experience, the recommendations of international standards, such as ISO 26000 and the OECD Guidelines for Multinational Enterprises, and the Global Reporting Initiative (GRI) Guidelines. The policies have been approved by Nidera?s Management Board and Supervisory Board in June 2011 and updated in January 2013. Performance based requirements of these policies commit Nidera toward compliance with legal regulations in countries of operations, as well as standards to which Nidera subscribes, including the IFC?s Performance Standards and the RTRS. In addition, plant-level?s environmental and occupational health and safety (EHS) policies have been subscribed by Nidera?s Argentina president as part of the ISO 14001 and OHSAS 18001 certification process.

As mentioned above, the corporate Code of Conduct for its employees and the accompanying Employee Grievance Mechanism is currently being updated. It has been recently re-launch through two road shows, the first one held in Rotterdam targeting Nidera? senior managers in Europe, US and Asian operations, and the second held in Buenos Aires for Brazil, Uruguay, Paraguay and Argentinian senior managers. These documents have been recently endorsed by the Corporate Management Team. The updated Code of Conduct and grievance mechanism are already available in Nidera?s webpage and will be soon accessible on Nidera?s intranet and translated in 8 languages. Nidera has established in 2011 an internal CSR unit, advised by a CSR Action Committee in Rotterdam, which is identified in its corporate organogram and accountable for the effective implementation of the CSR?s corporate policies and annual action plan, including ensuring a communication strategy to all employees (specific CSR training reached more than 1,400 employees since Nov. 2011), suppliers and stakeholders through CSR training sessions, development and publication of Nidera?s Corporate Responsibility Report since 2011, including meeting newest Global Reporting Initiative 4 requirements (comprehensive GRI quantitative performance indicators).

Environmental and Social Assessment and Management System. In accordance with applicable country and/or state legal and regulatory requirements, Nidera commissioned, as needed, the preparation of Environmental and Social Impact Assessment Reports for its industrial facilities (Argentina, Saforcada, PGSM, - crushing plants, Terfe Necochea ? unloading & fertilizer plant, Valentin Alsina ? oil refinery plant; Brazil, castor oil & derivatives production plant and Canoas port terminal in Rio Grande do Sul), its seed facilities (Argentina, Venado Tuerto, La Ballenera and Chacabuco); and its elevators (Argentina: Victoria, Bayauca, Granda, Balcarce and Intendente Alvear). The main EHS impacts and risks associated with these facilities include mostly air emissions, effluents management, solid and hazardous waste management and OHS risks and nuisance to communities due to truck traffic. The port terminal operations also include impacts to aquatic species due to dredging activities and impacts to artisanal fishing, when it does exist. Samples of Environmental Certificates for Argentinean and Brazilian operations have been provided during appraisal, including ISO 1400 and OHSAS 18000 certificates of Santos Port terminal in Brazil.

In addition to this plant-level EHS risk assessment and management process required by country/state requirements, Nidera demonstrated leadership in further formalizing its corporate policies commitment on environment and occupational health and safety and supporting procedures through the implementation of Integrated Environmental, Occupational Health and Safety, Social and Quality Management System in accordance with ISO 14001, OHSAS 18001, ISO 9001 standards and IFC?s Performance Standards, especially for its facilities representing the highest EHS risks, namely the industrial and seed facilities. In 2013, certification obtained included ISO 14001 and OHSAS 18001 for Nidera Argentina?s Seed Division (Venado Tuerto, La Ballenera, and Chacabuco), ISO 9001 and ISO14001 at Nidera?s elevator in Mercedes, TSCC certification for Nidera?s grain terminal in Ipswich and ISO 14001 certification for its trading, storage, and grain management operations; vessel loading and discharge activities, and its haulage fleet operations, which include a grain terminal in Ipswich and an elevator in Barmby Moor, Pocklington. In total, 9 ISO 14001 certifications have been granted so far at the following facilities: Venado Tuerto, La Ballenera, Chacabuco, Saforcada, and Valentin Alsina (all of which implemented IFC PSs requirements), Montevideo, Mercedes, and the Ipswich grain terminal elevator in Barmby Moor and Santos Port Terminal in Brazil; 4 OHSAS 18001 certifications in Venado Tuerto, La Ballenera, Chacabuco, and Valentin Alsina; 4 ISO 9001 certifications for quality management in Valentin Alsina, BOM, Montevideo, Mercedes, and Santos Port Terminal in Brazil; 1 ISO 22001 certification for Valetin Alsina; Dutch?s GMP + FSA certifications for food safety management for Saforcada and PGSM; 1 TASCC certification for Ipswich grain terminal. Copies of all these certifications have been provided during appraisal. Nidera plans to achieve ISO 14001 and OHSAS 18001 certification for PGSM in August 2014 while reaching OHSAS 18001 certification in 2016 for Saforcada.

For its farm productions operations, Nidera has gained its membership with the Round Table on Responsible Soy (RTRS). The company met 96 out of the existing 98 requirements related to the RTRS?s five main principles, namely legal compliance and good business practices, responsible labor conditions, responsible community relations, environmental responsibility, and adequate farming practices. The company has presently more than 50,000 ha which are under its direct farming management control (through land lease). Out of these, more than 27,000ha are used for soybean cultivation which 13,000 ha are RTRS certified. Nidera is committed to progressively increase, on an annual basis, this certified production by 15-20%.

Worthwhile to underline that Nidera received in 2011 financial support for its operations in Argentina from a Development Financial Institution (DFI) applying IFC?s Performance Standards and WBG EHS Guidelines. This explained the performance based reference to PS requirements in Nidera?s corporate and plant-level EHS management systems, including its corporate policies and procedures. E&S action plan?s items completed as of March 31, 2013 included, among others, i) full compliance with Argentinean?s EHS legislation and document registration, ii) Nidera and Argentinean plant-level EHS management systems, development of supporting EHS procedures, comprehensive EHS training and monitoring/reporting framework, including capturing IFC?s DOTS related indicators (OHS, water and energy efficiency) and worker and community grievance mechanism, etc.

In Brazil Nidera operates mainly through third parties (regional cooperatives and small traders) assets in which they have long term contract but no management role. At its own facilities, Nidera manages EHS aspects of its operations seeking compliance with local legal requirements and based on their own experience. Going forward, as set forth in ESAP, Nidera will further develop and implement formal ESMS procedures applicable for all owned sites, commensurate with the level of the environmental and social risks and impacts, which may include, for example aspects/impacts and hazards/risks identification and gap analysis; internal reporting; training, workplace risk assessment, inspection and internal auditing; non compliance and deviation treatment; EHS monitoring; stakeholder communication and engagement. In addition, and for leased assets not related to purchase contracts, Nidera will also develop an EHS checklist for its long term partners covering main legal and regulatory requirements and, based on results, Nidera will rank and work with their long-term partners to improve EHS performance and reduce operational risk.

As part of its expansion program in Brazil, Nidera is/will be constructing several new plants, including warehouses and port terminals. As set forth in ESAP, while constructing these plants Nidera will include in EPC contracts provisions to ensure adherence to E&S requirements (EHS, Labor and Community), including those defined in EISAs and respective Environmental licenses and the right to audit EPC contractors (construction firms) concerned as part of daily business.

EHS Management Programs. Nidera has demonstrated high-level management commitment to establish the foundation of a comprehensive corporate CSR agenda and an integrated environmental, OHS and social management system applying to its operations since the last three years with priorities defined on a risk-based approach (ref. targeting industrial facilities and seed processing plants). In addition to the corporate EHS policies mentioned above and the systematic risk identification and impact assessment at plant level (done through the national/state environmental assessment process and the ISO related management system), Nidera?s CSR and country-level EHS team has been developing management programs to ensure continuous EHS performance improvement. At CSR level, an annual action plan is developed and discussed with Nidera?s CEO and then reviewed and approved by Management Team and Supervisory Boards. For FY 2014, main action items on the CSR agenda was: i) update and re-launching the Code of Conduct and Grievance Mechanism, ii) undertaking a materiality sustainability analysis as required by GRI 4 (external consultant has been recruited to assess CSR risks and impacts of Nidera?s operations, ref. the scope of the analysis will include stakeholder dialogue and internal review of EHS reports (corporate and plant-level), iii) increasing global compliance with CSR policies and procedures in all countries of operations through CSR training, iv) supporting the rolling-out of the Standards for Business Partners (a two-pager document requesting all Nidera?s business partners to comply with applicable laws and regulations, respect human and labor rights throughout their own supply chains, and adopt appropriate E&S principles all along their own value chains). The principles and standards laid out in this document are based on those contained in the Nidera?s Social Responsibility Policy and its Code of Conduct applicable to its own employee. To date, more than 2,074 Nidera customers and suppliers worldwide have received this document and more than 62% returned a signed copy; v) completion of the EHS performance tracking at all operations (from 86% in 2013 to 100% in 2014) and strengthening EHS standardization monitoring program; vi) increase CSR training to all employees from a baseline of 45% in 2013.

From a specific EHS standpoint, annual action plan agreed upon in 2014 was to i) standardize tracking of EHS indicators, with the objective in 2015 to establish EHS and resource efficiencies benchmark for similar type of plants; ii) strengthen implementation effectiveness of integrated EHS management at industrial and seed facilities through further capacity building of EHS officers and technicians; iii) further reduction of OHS incidents through OHS program to change worker behavioral change.

In Brazil, on an operational level, Nidera has specific OHS mandatory programs such as workplace risk prevention plan (PPRA ? Programa de Preven??o de Riscos Ambientais, in Portuguese); Worker?s health and monitoring program (PCMSO ? Plano de Controle M?dico e Sa?de Ocupacional, in Portuguese), Emergency plans, Hazardous work procedure, including working at heights, confined spaces, working with heat and hazardous materials; machinery protection; Electrical systems safety, including explosive atmospheres and grounding. Going forward, as set forth in ESAP, Nidera will further develop OHS related programs such as Respiratory Protection Program (Programa de prote??o respirat?ria, in Portuguese), Hearing protection Program (Programa de prote??o Auditiva, in Portuguese) and Ergonomic Program (Programa de Ergonomia, in Portuguese). Nidera?s sites also have solid and hazardous wastes management program that includes proper segregation and disposal of wastes.

Organizational structure and technical capacity. At corporate level, Nidera has established a five-member CSR team, that reports directly to the CEO (Chairman of the Corporate Management Team). This team is responsible for: i) developing and implementing CSR policies, ii) developing and implementing Nidera?s annual CSR action plan, as outlined above, iii) coordinating CSR activities at all international locations and monitoring their implementation, carrying out CSR reporting to management and external stakeholders, including quarterly progress report on the company?s CSR Action Plan and main achievement and priorities. In addition, 15 CSR coordinators work with Nidera?s offices worldwide in raising awareness about Nidera?s corporate EHS policies. Finally, a CSR Action Committee and local representatives in key facilities actively participates in the design, development, launch, and implementation of CSR initiatives and programs.

In Argentina and Brazil, where existence of industrial operations represent the highest EHS risks, Nidera has established two positions of EHS managers in its country-level organogram. Specifically, in Argentina, Mr. Julio Ruffa reports to the General Industrial Director (Mr. Alejandro Figueroa) who reports to the Country Manager (Mr. Jorge Correa), and Marcos Pepe Bertoni who has shared responsibilities as new project manager and EHS. All seed and industrial facilities in Argentina have EHS professionals (industrial facilities) and technicians (seed plants) in charge who report directly to the plant managers and the EHS manager. The EHS coordinators in the elevators are the plant managers given their small organizational structure. These report EHS issues, if any, to the country-level EHS manager. In Brazil, seed facilities have a Quality & EHS manager (Ms. Luciana Apparecida Marques) who reports directly to the Global Operations Director (Mr. Hernan Forte) who is part of the Seed Global Management Board. Reporting to the EHS manager is an OHS engineer (Mr. Marcelo Pires) who has OHS oversight of the two seed plants (Patos de Minas and Cristalina). All associated EHS issues in seed facilities are being directly reported by the plant managers to the OHS engineer. Elevators in Brazil have EHS coordinators reporting directly to plant managers and OHS coordinator (Mr. Leandro Neves), who reports directly to a project manager (Mr. Marcos Pepe Bertoni) whom reports directly to the Country Manager (Mr. Brandon Scott). EHS committees exist in all industrial and seed plants, as per legal, ISO 14001 and OHSAS 18001 requirements. Going forward, as set forth in ESAP, Nidera will hire a dedicated Corporate Social Responsibility / Sustainability Officer for Brazil, full-time functioning, within Nidera?s (corporate) CSR team and organization, among others consolidating and coordinating EHS, CSR, sustainable soy production and supply chain management under its direct responsibility.

Training. Training employees is an integral part of Nidera in order to manage OHS risks, its environmental impacts and good stewardship of natural resources. At corporate-level, more than 1,400 employees (45% of Nidera?s global workforce) have followed the CRS training program which focused on Nidera values and corporate EHS policies and procedures. To date, Nidera has provided a total of 186 hours of employee CSR training. In order to reduce accidents at its operations, employees at 80% of Nidera?s industrial facilities and at 60% of its seed facilities were given 50% more hours on health, safety and environmental training during 2013 than in 2012. Main topics covered in the training session were: use of personal protection equipment, safety for employees working at heights, general overview of environmental management system concepts and IFC Performance Standards, squad training, forklift handling, operating procedures, use of fire extinguishers and how to respond to different types of fires, hygiene, safety and environmental laws, identification, handling and control of hazardous materials, hand and respiratory protection, communications procedures and incident-investigation procedures and behavior-based management.

Finally, as more than 400 employees used Nidera?s Argentina?s fleet of 287 vehicles on a regular basis during the course of their work, driver training workshop have been provided, in cooperation with the Argentine Center for Experimentation and Road Safety (CESVI). In addition, using in-house surveys on employee?s driving skills, results of these were used to plan multimedia safety activities focusing on the perils of driver distraction. Significant reduction of number of road accidents suffered by Nidera employees per 100 vehicles over the last three years is noticeable.

In Brazil, Nidera has mandatory EHS induction for all staff and contractor?s before starting to work at its facilities. Nidera provides mandatory EHS training for its staff (e.g. working at heights, working in confined spaces, machinery operators, safety in electrical systems, etc.) as well as requires certificate of completion from contractor?s staff. As set forth in the ESAP, Nidera will further develop OHS related programs for its on-site and field staff in Brazil.

Monitoring and Reporting. Since 2011, Nidera has significantly consolidated its corporate and country monitoring and reporting framework. From a corporate and Argentinean standpoint, Nidera has completed in September 2013 its fourth annual Corporate Responsibility Report following the Global Reporting Initiative (GRI) guidelines. Its corporate report has achieved first position in the ?trading companies? category based on the Dutch ?Transparency Benchmark?. Nidera Argentina received a Good Corporate Citizen Award from the U.S. Chamber of Commerce in Argentina for being one of the country?s top 10 corporate sustainability leaders. Building on this reporting, Nidera has strengthened in 2013 the standardization of environmental indicators for energy and water consumption and waste output at all 28 of the seed facilities, elevators, and industrial facilities located globally that are wholly owned or controlled by Nidera. Employees at 10 of these facilities (36%) were trained how to properly implement standardized measurement procedures for the company?s environmental performance. Standardization of EHS indicators have paved the way for the eventual development of Key Performance Indicators (KPIs) that will enable Nidera to establish clear resource efficiency goals for reducing the environmental impact of its operations worldwide. Specifically, Nidera? standardization program has allowed to release environmental impact statements for 24 operational units (86%) in 2013. Data on absolute and relative water and energy consumption, hazardous and solid waste, and effluents volume have been shared with IFC for Saforcada? crushing plant, the seed facilities and elevators in Argentina. Resource efficiency benchmarks (KPIs) for water and energy consumption have been established in 2014 for Valentin Alsina (crude oil refinery). These are within the benchmark required by the WBG?s EHS guidelines (ref. Table 3 on Resource and Energy Consumption in the sector specific Guidelines for Vegetable Oil production and processing). Nidera?s operations are also audited by end-customers (e.g. Nestle and Walt-Mart) for current status of its legal compliance and overall EHS performance. Based on information provided during appraisal, Nidera did not incur over the last two years any material regulatory penalties, fines or sanctions for contraventions or non-compliance with statutory obligations. Two fatalities (January 2012 and May 2013) have been reported respectively at its operations at Venado Tuerto?s seed facility and at PGSM crushing plant.

In Brazil Nidera reports internally meaningful EHS performance indicators, such as OHS accident rates and severity, water and energy consumption, wastes volumes and disposal, air emissions from grain dryers and labor ergonomics.

Emergency Preparedness and Response. All industrial and seed facilities in Argentina and Brazil have developed and implemented an Emergency Preparedness Plan, in accordance with local OHS legal standards and OHSAS 18001 requirements, which cover risks due to fire and explosion as well numerous other dangers (e.g. CCP spill at seed facilities). From a normative standpoint, Nidera? crushing operations (PGSM and Saforcada) are required to meet the National (Argentinean) Fire Protection Standard (re. NFPA 36) specifically applying for industrial plants using hexane in chemical oil extraction. Verification of compliance with NFPA 36 is undertaken by insurance company while local fire authorities approved fire prevention and fighting system for the other plants. Fire brigades exist at all plants and for the crushing plants, each member of the fire brigade received specialized training from the ?Centro Argentina de lucha contra incendio?. As mentioned above (see training section under PS1), use of fire extinguishers and how to respond to different types of fires is included within the annual EHS training curriculum of all workers. Fire drill also takes place bi-annually.

Stakeholder Engagement Plan. Aside from the consultation process inherent in the preparation of EIS Studies with surrounding communities, Nidera?s industrial and seed operations are located in industrial areas with no surroundings communities. Same applies for its farming operations under its direct control. As such, due to this limited interface, Nidera has not developed a comprehensive stakeholder engagement plan for its operations. This being said, Nidera has established a "Nidera Channel" (http://www.canalnidera.kpmg.com.ar/) which is a company-wide grievance mechanism following the recommendations of the OECD?s Guidelines for Multinational Enterprises. In Argentina, they have also developed a Community Grievance Procedure, mainly for their facilities and their RTRS soybean certification process. In addition, every year, following the official release of its CSR, Nidera undertakes structured consultation with key stakeholders through dialogues and surveys. A guideline for stakeholder dialogue was shared with IFC during appraisal. Main recommendations from this consultation process are outlined in the CSR. This overall process ensures Nidera to improve its EHS accountability and quality of reporting process. IFC appraisal findings considered that the overall stakeholder engagement demonstrated by Nidera has thus far been appropriate considering the risks and impacts of its operations, including identification of stakeholders, determination of level of interest and influence (by importance and relevance), establishment of appropriate methods for engaging each group, and identifying strategic and forward looking programs and activities to support and partner with affected communities.

Human Resource Policy and Management. At the corporate level, Nidera has adopted in July 2011 a Code of conduct which summarizes the company’s commitment to high ethical standards, which all Nidera’s employees are expected to uphold and practices. The scope of the Code applies to all Nidera employees and its subsidiaries. Contractors, supplier and business partner who work on Nidera’s behalf, are also expected to uphold the principles and standards of this Code. Main principles encompass i) the respect for the law (compliance with law, fair competition, anti-money laundering, anti-corruption and inside information and trading), ii) respect for peoples (compliance with human and labor rights, diversity and equal opportunity, no harassment of any type, safe workplace health and safety, fait employment practices), respect for shareholders and business partners (including product safety and quality). As indicated above, the Code of Conduct and the associated company-wide grievance mechanism (“Nidera Channel”) has been recently reviewed, upgraded and re-launched among top management. In the coming months the company will hold a communicational campaign to re-launch it among all its employees. At country-level, Nidera has adopted Human Resource Policy and procedures which meet the applicable country labor laws and regulations. These are available on Nidera’s Intranet site. Based on the review of the Nidera’s Argentinean HR framework, IFC confirms compliance with all PS2 requirements, including working conditions and terms of employment, freedom of association and collective bargaining, non-discrimination and equal opportunity, worker’s grievance mechanism, prohibition of child / forced labor, protection of contractor’s worker. It is specifically indicated that all HR principles are equally applicable to Nidera’s contractors. HR’ standard operating procedures outlines the following provisions: term of employment and recruitment, values of diversity and dignity at work, hours of work, pay, benefits and pensions, sickness pay provision, leave arrangements (annual, maternity), freedom of association, occupational health and safety, training and development, and separation/retirement. Signed acknowledgements by employees are filed. Human Resources management at Nidera is under the responsibility of a global HR coordinator while HR director and supporting structure (HR chiefs in each business line) are found in Argentina and Brazil. Organogram for the HR department has been received during appraisal. Internal and external HR audits (e.g. Labor Inspector, OHS agency, ISO certifiers) are taking place on annual basis.



As of September 30, 2013, Nidera had a total workforce of 3,174 in 21 countries of operation. Employees by gender are estimated at 78% male to 22% female. More than 92% of employee have permanent contract while 8% as a fixed-term contract. In addition, the company hired a total of 1,333 rural temporary workers in Argentina and Brazil to cover
several of its seasonal industrial and agricultural activities (mainly corn detasseling). Medical health checks are conducted as part of the recruitment process. As per ISO 22001 requirements at Valentin Alsina, Nidera conduct employee health checkups once a year for workers at Critical Control Points in crude oil processing unit as well as workers in farming operations assigned to CPP/pesticide spraying (monitoring of cholinesterase level). Salary grid in Argentina is documented in a “Covenio Commercial”. This grid is regularly reviewed based on labor market dynamic, considering existing high-level of inflation in Argentina. In order to compensate for this inflation, Nidera has recently increased its salary by 15% in March 2014.



Retrenchment Plan. Considering its existing five-year investment plan, Nidera is expected to increase its workforce. As such, there is no retrenchment plan envisioned in the next 5 years. If and when the company needs to reduce its workforce significantly, a Retrenchment Plan, in accordance with national labor law, will be prepared and submitted to IFC, well in advance of the actual reduction of the workforce.



Grievance Mechanism. Nidera is fully committed to establish a strong and consensual social dialogue with its workers to ensure stable and productive working conditions and performance. In cases needed, as per its Code of Conduct and associated company-wide grievance mechanism called “Nidera Channel” (http://www.canalnidera.kpmg.com.ar/), which follows the recommendations of the OECD’s Guidelines for Multinational Enterprises. This mechanism allows employee and stakeholder (e.g. civil society organization, customer, community members. etc.) to share a complaint, raise a grievance or report a possible misconduct. Information concerning this process, a dedicated telephone number allows employees to lodge grievances anonymously while a contact email address are posted on the company’s website. This formal Employee Grievance Procedure available to everyone in the company is designed to facilitate the resolution of situations related to employee grievances in line with the principles of the Code of Conduct. This Code and grievance mechanism has been recently reviewed and updated and was approved by Nidera’s Management Board in June 2014. A communication strategy including two road shows, translation in eight languages and inclusion into worker’s induction session are being held to raise level of awareness and its use across countries of operation, as needed. In its latest CSR report (2013), it has been reported that a total of 15 grievances were reported to Nidera Channel. These grievances were variously linked to irregularities and breaches of duty (54%), staff infractions (20%), labor abuses (13%), and product and sales claims (13%). All grievances were duly investigated and acted upon. To safeguard the privacy of all involved, detailed information about grievances lodged and how they are dealt with is considere
d strictly confidential.



Workers organizations. In Nidera’s Code of Conduct and in national based HR policies and procedures, Nidera fully supports the freedom of association to its workers and right for collective bargaining. In Argentina, Nidera’s workers are affiliated with the “Federacion de Trabajadores Aceiteros” (mostly for workers in crushing activities), the “Confederacion General del trabajo San Lorenzo”, which applies for workers involved in supporting services (e.g. security, cleaning, canteen, etc.) and the “General Sindicato” representing seed facilities workers. Worker organization exists at each plant. Collective bargaining agreement takes place on a yearly basis. Significant number of Nidera Argentinean workers, as groups or individual level, has disaffiliated themselves from union. Open door policy is promoted to discuss any human resources issues.



Third-party workers. Each year, Nidera hired rural temporary workers in Argentina and Brazil to cover several of its seasonal (temporary) industrial and agricultural activities (mainly corn detasseling). In 2013, Nidera recruited more than 1,000 workers. Detasseling is seasonal work carried out from October through March that entails both mechanical and manual operations. The majority of these workers employed in Argentina are from Ojo de Agua’s area, in the southern part of Argentina’s Santiago del Estero province. Due to the distance between the fields and urban areas in the region, Nidera provides living facilities for these temporary workers that strictly comply with all applicable health safety, and nutritional laws and regulations. Following allegations of breaching such legal requirements emanating from four NGOs (CEDHA, SOMO, Oxfam Novib, and Incasur) in June 2011 which was filed with the Netherlands National Contact Point (NCP). Nidera undertook a third-party legal compliance diagnostic in September 2011 for a sample of five camps which findings reveal significant efforts from Nidera to comply with these requirements. Corrective measures were proposed to improve living conditions at camp sites. In November 2011, agreement was reached between Nidera and these NGOs on the following: i) Nidera would upgrade its corporate Human Rights Policy, in alignment with the updated OECD guidelines; ii) Nidera would formalize its Human Rights Due Diligence Procedure for temporary workers involved in corn detasseling activities, and iii) Nidera would strengthen its monitoring over temporary’s working and living conditions. Audit reports of 2012 and 2013, conducted jointly by Nidera and NGO’s representatives, confirmed successful completion of agreed policy and operational corrective measures. Nidera has shared with IFC during appraisal detailed supporting evidences underlying this process and 2014 audit report from Nidera’s consultancy firm specializing in hygiene services and workplace security. Union’s representatives (“Union Argentina de Trabajadores Rurales y Estibadores”) are al
so undertaking independent annual inspection. Each year, Nidera is training all its field supervisors before the detasseling season to ensure effective implementation/enforcement of its policies and procedures, including efficient work planning and schedule, and optimum living conditions of camp sites.



Occupational Health and Safety. Nidera considers the health and safety of its employees as a top corporate priority. A corporate OHS Policy adopted in 2011 has been updated in 2013. OHS risk assessment, management system, supporting manual of procedures, training, monitoring and reporting has been (or in process of) being established at all industrial and seed facilities in Argentina. As indicated earlier, all industrial plants and seed facilities have been OHSAS 18001 certified. Awareness training at all plants in Argentina has been significantly increased (on average, more than 50% more in 2013 than 2012). Nidera’s goal in 2013 was to provide 20 man-hours of training per plant. This goal has been reached for the seed facilities (due to the ISO 14001 and OHSAS 18001 certification process) but felt short for the industrial facilities (10-15 hours worldwide while 8-10 hours in Argentina). Internal workplace accident prevention weeks (SIPAT) took placed in Pato de Minas (Minas Gerais) and in Cristalina (Goias) in Brazil. More than 150 employees participated in these weeklong events organized by Nidera’s internal accident prevention committee (CIPA). In spite of these efforts and for no identifiable reason; there were 3 more workplace-related accidents at Nidera facilities in 2013 than in 2012. One fatal accident caused by human error occurred in 2013 in Nidera’s PGSM in Argentine when an employee entered a grain hopper; just moments after a truck discharged a load of grain, in violation of established safety rules that forbids employees to enter confined spaces. A thorough investigation was conducted in the wake of this tragic incident and the following steps were taken to ensure that this type of accident does not happen again in the future: 1) an emergency response team was formed and trained; 2) all operators working on truck unloading platforms were skills tested and given further specific safety training related to their job description; 3) an inventory of confined spaces was carried out at all facilities; 4) safety warning signs were placed at all confined spaces; 5) safety lockout bolts were mounted on the hatch covers of confined spaces; 6) an alarm button was installed in each facility’s central control room.



Despite this increase, the company’s frequency rate for on-the-job accidents for 2013 remained 50% below the Argentinean average. Nidera recorded 2.43 on-the-job accidents resulting in time off work per 100 employees exposed to labor risks compared to average incidence rates (4.38) published by the Argentine Superintendence of Labor Risks. To make further progress towards Nidera’s goal of lowering accidents rates, a pilot projec
t on behavior-based safety program is being presently conducted in Saforcada and Valentin Alsina until November 2014 and encourages employees to proactively look out for each other’s safety and reduce accident. Number of accidents in Saforcada has been reduced while no significant reduction has yet been noticed at Valentin Alsina. In addition, in cooperation with Ernst & Young, Nidera has been developing a workshop entitled “Instructors’ Technical Training” outlining practical tools to strengthen EHS performance. Provision of PPEs has been sighted during site visit. The EHS engineers and technicians, supported by plant managers and the health’s clinic nurses, undertake regular OHS internal audits to verify compliance with SOPs. External OHS audits are carried out by OHSAS 18001 auditors and off-takers. Nidera Argentina has provided supporting evidence of its Certificate of Registration of a workplace for all its operations. Supporting evidence of OHS requirements into contractor’s contract has been provided.



Supply Chain Risk Assessment and Management. Nidera’s main commodities origination encompass soybean in Argentina, Brazil, Uruguay and Paraguay, corn in Argentina and Brazil, sunflower in Argentina and Europe, wheat in Argentina and Uruguay and sorghum from Argentina and Brazil. Supply chain risk assessment, based on IFC’s internal Global Mapping on Agro-Commodity Production (GMAP), raised concerns regarding potential negative environmental impacts accompanying with the sourcing of soybean, especially from ecologically sensitive biomes, namely the humid Chaco in Argentina and Paraguay as well as the Amazon and Cerrado biomes in Brazil. PS’s related supply chains risks such as harmful child / forced labor and significant OHS risks leading to life-threatening situation is not expected as these commodities are harvested mechanically.



From a corporate standpoint, Nidera has adopted in April 2012 its Standards for Business Partners, a two-page document which required Nidera’s business partners, including soybean suppliers, to comply with applicable laws and regulations, respect human and labor rights throughout their own supply chain, and facilitate the adoption of appropriate environmental and social principles all along the own value chains. From Nidera’s 2,074 customers and suppliers around the world, 60% of those contacted returned a signed version of the document indicating their commitment to respect these principles. Nidera has not yet established any training and/or monitoring framework to verify enforcement of such commitment by its partners. In addition, Nidera’s CSR team has developed a corporate responsibility and sustainability assessment protocol establishing uniform standards for evaluating partner compliance with Nidera’s CSR policies and international accepted guidelines. In 2012-2013, this protocol was tested through a case-study with the castor seed suppliers of the Brazil’s Oleo de Mamona (castor oil and derivative prod
uction). This risk assessment case-study demonstrated that Indian castor seed suppliers complied with laws related to ethical behavior and compliance, human rights, labor rights and environmental, health and safety issues.

Energy use and greenhouse gas emissions. Provision of energy to Nidera’s operations is provided by the national electrical grid, natural gas system and biomass. In addition, back-up generators are found at every processing and seed facilities in case of power outage. Energy consumption is being closely monitored at industrial and seed facilities as well as elevators. Specifically, Saforcada, an oilseed crushing facility uses sunflower hulls and corn rack (from Venado Tuerto de-husking process) as fuel to produce electricity. The plant generates 75% of the energy required for its sunflower seed and soybean processing activities. As the seed hulls discarded during dehulling are bulky and highly flammable, substituting traditional fuels with this material considerably reduces logistical problems related to waste handling and treatment. Valentin Alsina’s oil refining plant surpassed its original goal of reducing its year-over-year consumption of natural gas, gas oil, and fuel oil by 4%. Consumption at this facility dropped from 1.6GJ/ton in 2012 to 1.525GJ/ton in 2013. The installation of a new variable speed air compressor has reduced electrical consumption at Valentin Alsina. During 2013, this facility met its objective of reducing its electrical power consumption in 0.0396GJ/ton – 7% less than it had consumed during the same period in 2012. Sharp drop in energy consumption at seed facilities in 2013 can be largely explained by weather conditions. For example, unusually hot temperatures during the 2013 grain drying season meant that Nidera’s La Ballenera seed facility consumed less LPG during grain drying operations, as corn processed had lower initial moisture content. Going forward, aside from existing KPI’s energy efficiency pilot projects at Valentin Alsina and Saforcada, Nidera is committed to monitor GRI’s related energy indicators (ref. direct energy consumption by primary energy source, indirect energy consumption by primary source, energy save due to conservation and efficiency improvements, initiatives to provide energy-efficient or renewable energy based products and reductions in energy requirements, etc.) at all its sites. Consolidation of the data will lead to establishment of energy-based KPIs for same operations. Total greenhouse gas emissions by weight (in CO2 equivalent / total metric tons of finished product) is 1.16 (1,477,307 tCo2 equivalent at PGSM and Valentin Alsina is 0.19 (30,471.95 tCo2 equiv.) in 2013. All other sites will be covered in 2014.



Air emissions monitoring. Main source of air emissions are the boilers at Saforcada (two high pressure boilers of 60kg/cm2 – fuel: sunflower, soy husks and corn rack), PGSM (three low pressure boilers – 13kg/cm2 – fuel: gas and fuel oil (75%-25%) and Valentin Alsina (two low pressure boilers – 13kg/cm2 – fuel: gas and fuel oil) as well as the boilers in Brazil (BOM plant: 10t/h and 3t/h). Gensets are only used for emergency basis. Boilers and gensets undergo semestrial maintenan
ce inspection to optimize efficiency. Based on data shared with IFC during appraisal, air emissions at industrial facilities (GPSM, Saforcada, Valentina Alsina) are all in compliance with WBG EHS Guidelines for point source emissions to air (PM10: 50mg/Nm³, NOx: 460mg/Nm³; SO2: 2,000mg/Nm³), aside for minor exceedance of PM10 at PGSM.



Water use and efficiency. Water supply is from aquifer and surface water (ref. Parana River at PGSM). Nidera is still in the process of fulfilling GRI indicators (ref. total water withdrawal by source, water sources significantly affected by withdrawal of water and percentage and total volume of water recycled and reused. Nidera confirmed during the appraisal that no water sources have been significantly affected by water withdrawals at any sites. Overall, total water withdrawal in 2013, by m3/MT of product produced in industrial facilities was 0.58 (total real consumption was 1,477,310m3) while it was 0.05 (total real consumption was 2830m3) for seed facilities. Slight water consumption increase at the industrial facilities during 2013 compared to 2012 (1,305,480m3) was due to the installation of boiler feed water treatment at Saforcada. Increased water consumption of this new inverse osmosis system is being offset by a reduction in the use of chemical inputs at this site. Valentin Alsina managed to reduce its water network intake by 36% over the last two reporting periods, a step towards Nidera’s goal of reducing consumption to 0.893m3/ton. Data was no available for elevators as they do not consume water for production purposes. For its direct farming operations, as required under RTRS, Nidera have implemented an integrated water management system that monitors the water use for irrigation, gauges soil moisture content, and evaluates the irrigation levels required by crops in the field. Necessary adjustments are calculated by comparing simulation models to gravimetric analyses of soil samples. By studying the variables, Nidera is able to optimize the dynamics between the soil (supply), crop requirements (demand), and equipment (technological input), and forecast both short-term and long-term needs.



Wastewater Treatment. Crushing plants and vegetable refining oil generates significant amount of wastewater from the oil extraction process. Nidera has installed wastewater treatment plants that include physical chemical treatment unit and a sequence of aeration and polishing lagoons. Wastewater treatment is designed to meet state/local regulatory requirements and WBG effluents guidelines. COD, BOD, suspended solids, temperature, pH, oil and grease are normally monitored. Specifically in Valentin Alsina facility, continuous online monitoring of wastewater quality is monitored at the discharge point (Matanza Richuelo Basin). Wastewater samples are continuously collected by a device installed at the facility’s discharge point by ACUMAR, the government’s environmental protection agency responsible for oversight of
this basin. None of the samples collected and analyzed by ACUMAR on a routine basis throughout 2013 indicated a deviation from the establishment quality standards for wastewater discharges. Based on the data provided by Nidera during appraisal, effluents are meeting WBG’s guidelines, aside from exceedances at PGSM (ref. total suspended particles and total nitrogen). Nidera’s seed plantations, grain elevators, and its industrial facility in Terfe Necochea (Argentina) do not generate wastewater.



Management of solid and hazardous wastes. Wastes from processing and farming operations are characterized mostly by organic (e.g. corn rack) and inorganic (e.g. metal, plastic) waste. Total weight of waste (in absolute) and in ton/MT of product produced has been monitored at the industrial and seed facilities as well as the elevators since 2011. Volume of wastes generated at Valentin Alsina fell by 82 tons in Q4 of 2013. This was due to the conversion of PET bottle preforms from 24 to 22 grams. This facility also sent 51.4% less solid waste to sanitary landfills during 2012 than in 2011. Terfe Necochea has also implemented in 2013 procedures for recycling paper and plastic containers. Saforcada’s laboratory sort recyclable glass which facilitated the reuse of sorted materials throughout the productive chain and reduced the amount of virgin material consumed. All organic waste generated at the seed facilities (e.g. corn rack) is reused in processed related to seed production or by authorized third parties as fuel for energy generation. Nidera is also pursuing numerous initiatives to reduce its waste footprint from its offices, including reduction of paper use. Inorganic waste, such as empty fertilizer and pesticide containers are collected and returned to local suppliers. Nidera does not import, export, handle, or conduct trans-boundary movements of hazardous wastes.



There has been a rise in the volume of hazardous waste in the industrial facilities in 2013 due to the cleaning of fuel oil tanks at PGSM. This operation produced 270 tons of hazardous waste. Apart from this exceptional circumstance, Valentin Alsina facility achieved its goal of generating 48% less hazardous wastes in 2013 than 2012. Used oil is collected in drums and disposed through qualified service provider. Appropriate secondary containment structures consisting of walls capable of containing more than 110 percent of the tank volume have been observed at PGSM and Venado Tuerto.



Cooling and ripening agents. At Valentin Alsina, Nidera uses ammonia as a cooling fluid. As control measures, there is continuous monitoring of this gas. Emissions of ozone-depleting substances by weight (in CFC-11 equivalent / total metric tons of finished product) was only available at Valentin Alsina. For 2013, the result was 0.00000004 (0.006 tCFC-11-equiv).



Pest Management and Control. Nidera has established and implemented an Integrated Pest Management Plan in all countries where it has farming
operations. Nidera do not purchase, store, and use Crop Protection Products that fall in WHO Recommended Classification of Pesticides by Hazard Ia (extremely hazardous) or Ib (highly hazardous). The company has appropriate controls for the distribution and use of Class II chemicals, including personnel being properly trained, equip with PPE. Nidera is participating in the “Agrolimpio” and “Deposito Ok” programs in Argentina which request ensuring that rigid phytosanitary containers are collected, pressure washed three times, and perforated to prevent their further use before being recycled. In line with these programs’ goals, Nidera ensure that its personnel and sub-contractors’ employees wear protective masks and clothing while handling and applying plant production products and maintaining spray equipment. The Deposito Ok program promotes the safe handling and storage of plant protection products and fertilizers in order to ensure the safety of the environment and people who work in this area. Nidera has obtained certification under CASAFE’s Deposito Ok program for 70% of its 13 facilities. Operating responsible also involves ensuring the quality and the correct storage and handling of products. Nidera makes a concerted effort to obtain certification for its international facilities through schemes such as GMP+FSA (Good Manufacturing Practice + Feed Safety Assurance), GTP (Good Trading Practice), or equivalent local programs. The GMP+FSA is a comprehensive scheme designed to ensure feed safety throughout every link of the feed chain. The Code of Good Trading Practices, an EU certification scheme administrated by Coceral, provides a common standard for all food and feed operators and covers every aspect of feed handling from receipt to dispatch.

Community Health and Safety. Nidera operations (industrial, seed, elevators, farms, etc.) are relatively isolated from human settlements. A slight induced increase in road transport may be noticed due to increased activities at farms, but this is relatively negligible. The majority of Nidera’s truck fleet is found in Argentina and United Kingdom. Nidera has adopted a Vehicular Safety Policy (can be downloaded at http://www.nidera/com.ar/NuestrasPoliticas) and supporting procedures, including driver handbook. For its UK operations, in addition to the corporate workplace Health and Safety Policy, Nidera UK maintains a Health and Safety Policy providing a safe working environment, together with training and Fleet Board information which is carried out for all drivers. In addition, Nidera UK provides training on regulat basis to its drivers. Forklift drivers at all sites are recruited based on several years of training and experience. Certificates were available during appraisal. Food safety of Nidera’s consumer products at Valentin Alsina (crude oil refinery) is covered under ISO22001/HACCP food safety management system certification requirements, including traceability. The health and safety impacts of all products handled and services provided in the course of Nidera’s trading and distribution activities are monitored in compliance with REACH regulations and other EU regulations related to feed, food, and sustainability issues. An internal quality assurance manual serves as an employee guide for the implementation and monitoring of all processed.



Community Grievance Mechanism. Every year, following the official release of its CSR, Nidera undertakes structured consultation with key stakeholders through dialogues and surveys. A guideline for stakeholder dialogue was shared with IFC during appraisal. As set forth in the ESAP, and based on its existing Code of Conduct and Company grievance mechanism framework successfully implemented, Nidera will further implement local Community Grievance Mechanism channels and procedures, comparable to those already implemented in Argentina, both in Brazil and any other country of operations, appropriate to Nidera’s level of community impacts. This Community Grievance Mechanism should at least include: a formal procedure to follow every grievance, a local phone number, a grievance book in each facility and, a local contact person, among others.



Security Personnel. Nidera is contracting a licensed security provider (G4S) for the security of its operations. Security personnel are unarmed and are trained to respond to potential threats to Nidera’s facilities, using preventive and defensive measures in proportion to the nature and extent of the threat. It was noted during site visit that factory is surrounded by a 3 meters high fences with barbed wire. A logbook for visitors is also kept at the entrance gate.

Protection and Conservation of Habitats and Sustainable Management of Living Natural Resources. Current farming operations are located in a modified habitat landscape. This assessment has been confirmed by the RTRS auditors during certification process. As indicated above, for its farm productions operations, Nidera has gained its membership with the Round Table on Responsible Soy (RTRS). The company met 96 out of the existing 98 requirements related to the RTRS’s five main principles, namely legal compliance and good business practices, responsible labor conditions, responsible community relations, environmental responsibility, and adequate farming practices. The company has presently more than 50,000 ha which are under its direct farming management control (through land lease). Out of these, more than 27,000ha are used for soybean cultivation which 13,000 ha are RTRS certified. Nidera is committed to progressively increase, on an annual basis, this certified production by 15-20%.



Living Modified Organisms (LMO). Nidera has been working on the genetic improvement of crops since 1988, producing new varieties of corn, sunflower, soy, sorghum, and wheat seeds. Based on PS6 requirements, introduction of LMOs can be considered to be alien species, with similar potential for invasive behavior as well as potential for gene flow to related species. Any new introduction of such organisms should be assessed against applicable formal legal and regulatory protocol and risk assessment in accordance with Cartagena Protocol on Biosafety. Argentina has not yet signed the Cartagena Protocol on Biosafety, while Brazil did. However, Argentina has in place a very strict regulatory framework regarding GMOs evaluation and release, which is outlined and controlled by the "Direction of Biotechnology", an office of the Ministry of Agriculture, Livestock, and Fishery. The CONABIA (National Advisory Commission of Agriculture and Livestock Biotechnology) is the entity that analyses case by case, and provides the corresponding permits to release events to the environment, under strict biosafety protocols and regulations. All the seed companies in Argentina are in full compliance with those regulations, including NIDERA. Regulatory framework can be found in the official website of the Direction of Biotechnology (at: minagri.siia.gob.ar/site/agregado_de_valor/biotechnology/10-DIRECTORATE/index.php. IFC’s seed specialist has checked Nidera’s list of evaluation permits granted by CONABIA (the last one was published in 2010), and NIDERA has been carrying out regulated experiments with non-commercial events (see attachments). That means that they have a team that manages all regulatory activities, which should guarantee the proper compliance.



Supply Chain. Nidera purchases soy from regions with significant conversion of natural and critical habitats, such as Amazon forest, Cerrado and Chacco region in Argentina. In Brazil, Nidera has two warehouses of Mato Grosso State (Am
azon region) and has plans to build five more in the next five years. Nidera also has commercial offices in Bahia, from where they purchase soy from the Brazilian Savanna (Cerrado) region.



In the north of Brazil approximately 5% of Nidera’s soybean needs are originated from producers with whom they have direct contract (pre-finance). Nidera provides the inputs and some working capital and producers are committed to sell the crops under predefined conditions. On the other hand, ninety five percent (95%) of the total soy come from spot market suppliers, which can be either from other small traders or farmers who sell its crops in the market without any contract agreement and from whom Nidera has limited management control and/or leverage and information such as their tax registry number, farm name, and region (municipality).



In Brazil, total soy production area has expanded from 23.5 million ha in 2009 to 29.2 million ha in 2014 and jumped from 68.7 in 2009 to 88 million tons in 2014. Although soy has been growing in all regions of Brazil, the Cerrado Biome is the area with great expansion. Statistical data shows North and North East regions are the areas with highest expansion rates and the peak of soy expansion during the period was in 2012/13 with 25% and 15% growth, respectively.



Although there is no updated information of Brazilian Cerrado Biome annual loss, last available official data indicates 646,900 ha were lost in 2009. The Cerrado once covered over 200 million ha, but around half the natural vegetation has been lost since the late 1950s. According to the Brazilian government, 53 per cent remains relatively intact, though academic researchers estimates are as low as 35 per cent (Klink and Machado, 2005; Durigan et al., 2007) and 21.3 per cent (Conservation International, 2012).



In Argentina, Nidera has three oil processing plants in Buenos Aires, three port terminals in Rio de la Plata and five storage warehouses, none of them located in Chacco Region. However, since soy can travel long distances before arriving to a trader or processing facility, the geographical distribution of Nidera’s assets it is, per se, not an assurance that no or minimal volumes of soy are coming from environmental sensitive regions. In addition, Nidera has long term agreements with local traders in Santa Fé and Tucuman, both in Chacco region. Based on sourcing estimates provided by Nidera during the field appraisal, current sourcing from the Chaco is of importance as Nidera sourced soy from traditional areas of production in the Chaco region, such as Rosario, part of Cordoba and Santiago del Este. Quantification of the importance of this sourcing is not yet available. Worthwhile to underline that this sourcing is sport-based as Nidera does not have any pre-finance farmers in the regions. This limits Nidera’s scope of intervention to request RTRS supply chain sourcing, and as a result suppliers will be mostly uncovered in the region.



In Brazil,
Nidera is committed to the Amazon Soy Moratorium, in which Soy industry has agreed with civil society in not purchasing soy from Amazon Biome deforested after 2006. Monitoring and verification is conducted by a third party, coordinated by soy industry association ABIOVE that provides annually a list of farms that must be banned from soy crushers and traders’ suppliers. It is Soy Moratorium Member’s the responsibility to block these farmers from their cadaster. Appraisal findings identified the need for improved management governance to ensure that Nidera would not be buying from banned suppliers.



It is worth indicating that Nidera, at the request one of its product off-takers assurance of RTRS certified sourcing, has certified its soy traceability system (chain of custody) in Uruguay and achieved 100% compliance records for its segregated (seed) and mass balance (grain) supply chain. Nidera’s CSR team indicated that there is no plan for further supply chain risk assessment going forward, aside if the materiality sustainability assessment under the GRI 4 process request such.



Responses to address biodiversity loss due to soy production expansion can take place mainly in two different levels: public and private sectors. The scope of action in the public sector includes strengthening regulatory framework, monitoring and enforcement activities, while initiatives in the private sector includes, developing market incentives for sustainable soy production (certification schemes) and regional/sector environmental agreements. RTRS, the Round Table of Responsible Soy is a multi-stakeholder initiative with over 150 members from more than 20 countries. These include producers and retailers from the mainstream soy industry, environmental and social NGOs (including WWF), commodity traders, consumer goods manufacturers, the feed industry and banks. Its aim is to produce globally applicable standards to help build a market for responsible soy. It was established in 2006 and the production standard was disclosed in 2010. In 2014 RTRS has achieved 1 million tons of certified soy, which nonetheless is less than 0.5% of global soy production.



In Argentina, Nidera farms’s surface area have reached close to 50% RTRS certification and they have programs to purchase certified beans from farmers that voluntarily engaged in the certification program.



As a standard commodity, soy market is very competitive and price oriented. Nidera is a small player when compared with ABCD (ADM, Bungue, Cargill, and Dreifus) or even when compared with other local players, such as Ammagi. Thus, Nidera will have limited space to implement sustainability requirements across supply chain without challenging their own business, as the other players are not following same standards, and especially regarding soy spot market transactions due to its nature and volatility.



Having that said, as set forth in the ESAP, Nidera will develop and implement a Sustainability Sourcing Po
licy. As a minimum, Nidera pre-financed agro-commodity suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chacco and Cerrado) must respect RTRS cut of dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of dates (June 2006) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land, forced labor list and verification of embargoed areas from IBAMA. In order to effectively implement this Policy, as set forth in the ESAP, Nidera will include within its existing credit review process and requirements additional E&S verification points for its pre-financed agro-commodity suppliers, including training on sustainable agricultural practices, as needed. Finally, Nidera will be monitoring and reporting on its supply chain’s E&S risk assessment and management through its annual Corporate Responsibility Report (CSR).

In line with its commitment to make a positive difference in the communities where Nidera operates, three initiatives have been established, including a School of Values Program, Talented Youth Program and Rural Values Programs. The School of Values program serves fourth-, fifth-, and sixth-grade school children, their teachers and their parents. Nidera’s contribution is to improve the quality of education at 8 schools in 3 provinces of Argentina (Buenos Aires, Sante Fe, and Entre Rios) and offering support for building and renovation projects that enhance learning environments. Partners in this program are Assocacion Concienca, Fundacion Pescar and Fundacion San Genaro. The Talented Youth program, in partnership with the NGO Fundacion Pescar, targeted at-risk young people who may have dropped out of school and students who have received technical training but lack the specialized skills and know-how to qualify for good jobs. More than 600 young people have benefited from this annual program. Finally the Rural Value program, in partnership with NGO Fundacion San Genero, supports projects designed to improve living conditions for Nidera’s temporary workers and their families. Main interventions are focused on schools establishment. Going forward, Nidera will expand these existing community programs to Nidera Brazil and implement comparable community initiatives in Brazil and other countries of operation, appropriate to Nidera´s level of community impact by its local operations.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. Nidera will also be requested to place an advertisement on its website (http://www.nidera/com) to inform the public from IFC’s environmental and social review (ESRS) findings.

Name and Address.
Ms. Julieta Sullivan
CSR Global Head
Av. Paseo Colon 505 Piso 4
Ciudad Aut. De Buenos Aires, Tel: +54 11 4346-8000/8001;
E-mail: mailto:jsullivan@nidera.com.ar

Ms. Aukje Berden
CSR Manager
Willemsplein 492
3016 DR Rotterdam, The Netherlands, Phone +3110 4301713
E-mail: mailto:aberden@nidera.nl

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
E&S Management System. Nidera will further develop and implement formal ESMS procedures applicable for all existing (e.g. Brazil) and future owned sites commensurate with the level of the environmental and social risks and impacts. This may include for example aspects/impacts and hazards/risks identification and gap analysis; internal reporting; training, workplace risk assessment, inspection and internal auditing; non compliance and deviation treatment; EHS monitoring; stakeholder communication and engagement.	12/31/2015
For leased assets not related to purchase contracts, Nidera will develop an EHS checklist for its long term partners, covering main legal and regulatory requirements. Long term partners in this action item can be defined as third party warehouses from which Nidera leases storage capacity on an annual basis (or more) and under contract. Nidera will identify the specific partners that need to be considered under this definition. This EHS checklist will, in principal, not exceed 5 EHS checkpoints, though covering main legal and regulatory requirements. As an example, in Brazil, screening process will encompass (i) Valid Environmental License, (ii) Municipality license to operate (as required by law), (iii) Fire Authority permit (in a form of Auto de Vistoria do Corpo de Bombeiros - AVCB), (iv) Wood Inventory in accordance with Brazilian law (in case of use in dryers) , (v) OHS Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais - PPRA, in Brazil) and (vi) copy of Procedures for working at heights and in confined spaces. Based on results, Nidera will rank and work with their long-term partners to improve EHS performance and reduce operational risk.	06/30/2015
Assessment of Environmental and Social Impacts. As part of its expansion program in Brazil and other locations, Nidera will be constructing several new plants, including warehouses and port terminals. While constructing these plants Nidera will include in EPC contracts provisions to ensure adherence to E&S requirements (EHS, Labor and Community), including those defined in ESIA and respective Terms and Conditions underlying Environmental licenses, and the right to audit EPC contractors (construction firms) concerned as part of daily business.	12/31/2014
Nidera will monitor and document EPC contractor’s performance as part of daily business of its owned sites and reports will be shared with corporate senior management. Nidera will formalize monitoring contractor’s performance as part of job description responsible employee (s) for applicable sites.	12/31/2014
Nidera will hire a dedicated Corporate Social Responsibility (CSR)/Sustainability Officer for Brazil, full-time functioning within Nidera’s (corporate) CSR team and organization, among others consolidating and coordinating EHS, CSR, sustainable soy production and supply chain management under its direct responsibility.	11/30/2014
Nidera will further develop OHS related programs for its on-site and field staff in Brazil, such as Respiratory Protection Program (Programa de proteção respiratória, in Portuguese), Hearing protection Program (Programa de proteção Auditiva, in Portuguese) and Ergonomic Program (Programa de Ergonomia, in Portuguese).	03/31/2015
Based on its existing Nidera’s Code of Conduct and Company grievance mechanism framework successfully implemented, and which is currently being updated and re-launched globally, Nidera will further implement local Community Grievance Mechanism channels and procedures, comparable to those already implemented in Argentina, both in Brazil and any other country of operations, appropriate to Nidera’s level of community impacts. This Community Grievance Mechanism should at least include: a formal procedure to follow every grievance, a local phone number, a grievance book in each facility and, a local contact person, among others.	12/31/2015
In addition, Nidera is in the process of recruiting a CSR/Sustainability Officer for Nidera Brazil (reference: Action item 3) and will expand its existing community program of Nidera Argentina to Nidera Brazil and implement comparable community initiatives in Brazil and other countries of operation, appropriate to Nidera’s level of community impact by its local operations.	12/31/2015
Supply Chain Risk Assessment and Management – Policy. As part of the supply chain component of its corporate EHSS Management System, Nidera will develop and implement a Sustainability Sourcing Policy. As a minimum, Nidera pre-financed agro-commodity suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chacco and Cerrado) must respect RTRS cut of dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of dates (June 2006) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land, forced labor list, and verification of embargoed areas from IBAMA. Consolidating its commitments with regional/sector agreements (e.g. Amazon Soy Moratorium and RTRS) and IFC Performance Standards Requirements, Nidera will ensure that pre-financed agro-commodity suppliers are required to adhere to the Sustainability Sourcing Policy requirements by signing the Nidera Standards for Business Partners which will explicitly outline Performance Standards’ supply chain related requirements, including provisions as stipulated under this action item.	03/31/2015
In addition, to address spot market suppliers, Nidera will develop a program to promote good agricultural practices that is comparable with the set-up of or an extension of its online existing program “Agricultura Consciente” and aligned with RTRS’s principles and criteria across its supply chain. Scope of the program will include Argentina, Brazil and Paraguay, exploring market opportunities and incentives for the adoption of sustainable standard of soy production.	06/30/2015
Supply Chain Risk Assessment and Management – Supplier Database and Monitoring. In order to implement its Supply Chain Policy as defined in this action plan above, Nidera will include in their existing credit review process/requirements for pre-financed agro-commodity suppliers, the following E&S verification points: - Absence from Amazon Soy Moratorium list of banned farmers - Absence from Brazilian official Forced Labor list (from Ministry of Labor) - Farmers must have a valid Registry number in the Environmental and Rural Cadaster (CAR, in Portuguese) or valid Environmental License. - Farms are not enrolled in IBAMA's embargoed list (Brazil) - Farms Should not be encroaching Indigenous People Lands (verifiable through CAR Website, in Case of Brazil and Official Google Maps in case of Paraguay) - Farms were not converted to agriculture in disagreement with RTRS cut of dates and High Value Conservation Areas Mapping (where it does exist, verifiable at RSTS website, Using CAR information and/or land use change information from Environemntal. License in case of Paraguay)	05/31/2015
Supply Chain Risk Assessment and Management - Training on Sustainability Sourcing Policy and Supplier Database Information. Nidera will implement a training program for its field staff dealing with pre-financed agro-commodity suppliers to: 1. Create awareness on - and ensure knowledge of Nidera enhanced Sustainability Sourcing Policy and the adapted Nidera Standards for Business Partners as outlined under point 6;	05/31/2015
2. Provide training of pre-financed agro-commodity suppliers on sustainable agricultural practices to help farmers improve yields, quality, and achieve third party certification of agro-commodities from widely accepted bodies. Set-up comparable with other suppliers through extension of its online existing program “Agricultura Consciente”.	06/30/2015
Supply Chain Risk Assessment and Management - Senior Management / External Stakeholders Monitoring and Guidance. As part of its annual Corporate and Argentinean Responsibility Report (CSR), which are both publicly available and using the Global Reporting Initiatives guidelines, Nidera will define an annual monitoring and reporting status of the implementation of its Sustainability Sourcing Policy, including supply Chain’s E&S risk and management, and sustainability initiatives to senior management and external stakeholders, to allow monitoring of progress of the dynamics of pre-financed supplier’s classification, emerging supply chain’s related E&S issues, determine E&S capacity building needs of field staff and pre-financed suppliers, and ensure a proactive response and periodical realignment of Nidera’s sustainability priorities and mitigation of potential Nidera exposure to commodity business risks in the short and long term. Nidera’s senior management will identify any needed changes in the corporate's ESMS for the management of pre-financed suppliers to reduce, within a commercially realistic way, risks in the supply chain.	05/31/2015
Although fully dependent upon market circumstances, Nidera will, based on a 2014 minimum baseline of 46% total production, continue to further certify its farming management practices against RTRS standard within its direct production in Argentina and in any Latin American countries (e.g. Brazil, Paraguay) where it may have future direct primary production.	09/30/2014