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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

This proposed investment is expected to have limited environmental and social impacts which are expected to be site-specific and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. The project is designed to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with Malawi legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Plantation Crop Production, Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.

Key E&S issues associated with this investment are: (i) operational licenses and permits for the processing plant and farms; (ii) environmental, occupational health and safety (OHS), food safety and social (including labor) management systems and related procedures, including Hazard Assessment and Critical Control Point (HACCP) Principles/ISO 22000 certification at the processing unit and Rainforest Alliance’s (RFA) Principles and Criteria (P&Cs) certification at farms, EHS organizational structure and internal technical capacity for effective environmental and social management system (ESMS) implementation, monitoring and reporting of the company’s EHS management system; (iii) adherence to Malawi 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 (ref. extraction from boreholes at Matumba and from Lake Malawi at Dzuwa and Nyu Nyu farms), water and energy use efficiency at the processing plant and farms through design and adoption of best available technology, including equipment selection (e.g. drip irrigation), 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, including on plantations, community health, traffic safety; viii) land acquisition/leasing process, consultation and compensation; and ix) social performance.

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. Sustainability is not an ?add-on? for Malawi Mangoes; it is what its business model is based on. In order to operationalize this vision, Malawi Mangoes made a conscious decision at the outset to design and build a state-of-the-art processing facility based on lessons learned and best practices from more than 100 fruit processing facilities around the world, establish partnerships with equipment suppliers with highest technical and resource efficiency specifications, and mainstream food safety management requirements in the plant?s lay-out. Based on these stringent requirements, the facility is now in the completion phase for Global Food Safety Initiative/British Retail Consortium (BRC) and HACCP certification and is committed to certification for Sure-Good-Fair (SGF) - SGF is a German-based non-profit organization pioneering industrial self-control in the fruit juice industry ? as well as Halal and Kosher certifications. All certifications are expected to be completed by June 2014. Pasteurization process at the processing plant is also independently verified by the National Food Laboratory. In addition to these industry standards, MM will implement customer specific food safety standards (e.g. Coke, Innocent, Froosh). Malawi Mangoes adopted the Rainforest Alliance (RFA) standard on its plantations in order to mainstream sustainable agriculture practices. Inclusive of RFA requirements is a 30% set-aside of farm areas for biodiversity protection and maintenance of ecosystem services. This will make Malawi Mangoes the only organization on the African continent to have RA certified banana and mango. MM intends to be RFA certified for all its farms. Organic production is being sought for 2015. Global Gap certification may be sought as MM takes on more fresh activities in the future, but this is not a requirement for the processing sector.

Existing environmental, OHS, Food Safety and Social related policies encompass a mix of internally (e.g. Staff Handbook and Occupational Health and Safety) and externally (sector standard related, e.g. HACCP/Food Management and Rainforest) drafted Policies. Going forward, as set forth in the ESAP, Malawi Mangoes will develop, approve and implement its own set of corporate EHS policies which will include; i) reference to performance-based requirements based on Malawi?s laws and regulations, IFC Performance Standards, applicable WBG EHS Guidelines, HACCP and RFA requirements; ii) defining an accountability framework (ref. E&S team) in its organogram for its effective implementation; iii) ensuring a communication strategy to all employees, suppliers and partners (e.g. out growers and communities); and, iv) ensuring internal/external audit for assessing their effectiveness, including meeting quantifiable performance targets and indicators.

Environmental and Social Assessment and Management System. In accordance with Malawi?s Environmental Management Act (EMA) of 1996 and EIA Guidelines (1997), Malawi Mangoes has commissioned the preparation of quality Environmental and Social Impact Assessment Reports for its processing facility (Salima) and farms (Matumba and Dzuwa). Approval of these studies and associated EIA certificate were issued respectively on February 14, 2012, November 23rd, 2011 (Matumba) and April 10, 2014 (Dzuwa) by MoE. Terms and conditions of these certificates included: (i) effective implementation of the Environmental Management Plans (EMPs) during construction and operations phases (ref. main mitigation measures recommended during operations included, among others, solid and hazardous waste management, provision of safe working conditions to workers, efficient use of water resources, monitoring of liquid effluents through the construction of a waste water treatment (WWT) plant, Integrated Pest Management (IPM), Emergency Preparedness and Response Plan, monitoring of air emissions from boilers and generators, Biodiversity plan, and establishment of an Environmental and Safety Management Unit); (ii) regularly report to the MoE on the environmental and social performance of each operation; (iii) notify MoE about occurrences of unforeseen events; (iv) joint field monitoring between MoE and Malawi Mangoes; and, (v) undertake environmental audits and report audit results to MoE on a bi-annual basis. Malawi Mangoes has not been able to provide to IFC during field appraisal any supporting documentation of on-going progress as it related to points (i), (ii), (iii), (iv) and (v). This maybe explains by early operational phase of all assets.

Going forward, as set forth in the ESAP, Malawi Mangoes will establish a matrix format to review and update compliance status for all its existing operations (plant, Matumba and Dzuwa farms) and future ones (e.g., Nyu Nyu), including supporting evidence of meeting MoE, Water Resources Board (WRB) and OHS certificate?s Terms and Conditions, implementation of the ESIA?s Environmental Management Plans (EMPs) at all sites, implementation of HACCP and Rainforest Alliance? Principles and Criteria (P&C), and will present to IFC, for review and approval, a consolidated report on all these mitigation measures, progress/completion status and corrective action plan (CAP) with defined timetable for effective implementation, including center of responsibilities and budgetary allocations for all sites. Once the policies and procedures are finalized for Matumba Farm and the Processing Facility, it will become formality to roll out these policies and procedures to new sites.

Malawi Mangoes has received permits for water abstraction from 16 boreholes at Matumba farm from the WRB on September 23rd, 2013. Supporting evidence has been provided during appraisal. Water at the processing plant is sourced from Central Region Water Board and does not require any water extraction right per se. Water right extraction for Dzuwa and Nyu Nyu farms will be sourced from Lake Malawi. Authorization and/or non-objection from other riparian countries of Lake Malawi (ref. Tanzania, Mozambique) and/or regional lake authority is not required. As per the letter of the Ministry of Irrigation and Water Development of April 25th, 2014, water abstraction from Lake Malawi is governed by the 2013 Water Resources Act and the approving entity is the National Water Resources Authority. Certificate of Registration of a Workplace, under the Occupational Safety, Health and Welfare Act (1997), has been issued for the processing plant for the period of January 22, 2014 till January 30th, 2015. Supporting evidence has been provided during appraisal. Certificate from the Ministry of Health will also be required for the on-site health clinic at the processing plant. Malawi Mangoes will process all applications for relevant licenses and certification, e.g. food license and Building Occupation Certificate, as needed.

EHS Management Programs. Malawi Mangoes has demonstrated high-level management commitment to establish the foundation of a comprehensive environmental and social management system applying to all its operations. In addition to the draft EHS policies mentioned above, MM is committed to undertake systematic risk identification and impact assessment (done through the Malawian? environmental assessment process) as well as timely implementation of environmental, OHS and social management procedures and programs/plans from sector-based standards (ref. BRC/HACCP/food safety and RFA/agronomic practices). IFC appraisal team was informed that BRC/HACCP audit was scheduled by early July 2014 at the processing plant while the RFA audit for Matumba farm is scheduled by end of June 2014. BRC audit initially scheduled in May 2014 was delayed in order to ensure the following: to mainstream other client requirements within the scope of BRC audit, to complete the FDA validation and challenge testing of pasteurization equipment, to ensure a comprehensive gap analysis against OHSAS18001 and ISO 22001 and to ensure the inclusion of HACCP within the scope of BRC certification. Standard Operating Procedures (SOPs) are 95% completed for HACCP, and 80% completed for the RFA standard. Appraisal findings revealed some tangible and measurable implementation progress on numerous mitigations measures outlined in ESIA?s EMPs (e.g. soil/water conservation, Integrated Pest Management, biodiversity set-aside). This being said, MM recognized that overall completion progress for a comprehensive and integrated EHS management system is at 40%.

As such, as set forth in the ESAP, Malawi Mangoes will strengthen its EHS management framework through development and/or review of its own set of EHS policies, as mentioned above, and finalize the development and implementation of SOPs and annual EHS management plans - consistent with ISO 14001, OHSAS 18001, HACCP/ISO22001 and Rainforest Alliance P&Cs. Furthermore, this integrated management system will be in compliance with the structure of IFC?s PS1 requirements and compliant with applicable WBG General and Sector-specific EHS Guidelines.

Organizational structure and technical capacity. Malawi Mangoes has established a very solid EHS team to meet its EHS requirements. Mr. Athanasios Mandis, Director of Technical Affairs and graduate from Tropical Agricultural Engineering has been a key resource-person in ensuring excellent quality control of the ESIA studies as well as being central in progress achieved so far by MM in developing HACCP and RFA?s SOPs. His technical expertise as lead auditor for juice processing plants has been critical in the excellent progress that MM has reached in such a short-time frame. Ms. Elizabeth Maneya, recently named Director of Planning, Procurement and Compliance will take over the overall EHS compliance of MM processing and farming operations. She will be supported at farm level by Ms. Gloria Kasongo, Farm Sustainability Coordinator, who has 6 assistants to support implementation of RFA requirements at Matumba Farm. As Dzuwa and Nyu Nyu farms will be coming into operation in the next few months (after rainy season), she will be assign another team of assistants with overall EHS requirements, including RFA?s P&C. Factory processing manager, farms managers/supervisors, farm irrigation team as well as yet to be established Environmental, OHS, Food Safety and Farm Committees will also be involved in meeting MM?s EHS policy commitment and overall performance. Ms. Maneya reports directly to MM?s Managing Directors to ensure that internal EHS audit?s findings are effectively and timely addressed through annual work plan review and budgetary allocations.

Training. As the processing plant of Malawi Mangoes has yet to enter its full operation while its Matumba farm has been established less than 18 months ago, progress in EHS training is relatively limited so far. IFC?s appraisal team was informed that training on OHS related issues has started at the farm, including handling of chainsaw (extension officers) and plant protection products (CPP). At the processing plant, HACCP awareness and good hygiene practices session have also started. An OHS consultant has undertaken a workplace risk assessment at the farm and the processing facility manager will undertake similar OHS risk assessment at the plant. These risk assessment reports will be critical in establishing training plans. MM has not provided to the IFC team any supporting evidence of a comprehensive 2014/2015 training plan at plant and farms, as required to effectively implement its EHS policies? objectives and plans. Going forward, as set forth in the ESAP, upon completion of the integrated EHS Management System?s policies, procedures and plans, MM will define a comprehensive and multi-year training plan, for IFC review and approval, including center of responsibilities and budgetary allocation for its staffs (permanent and seasonal) and contractors at the plant and farms? operations in order to support effective implementation of its EHS management system and procedures, including EIA?s EMPs, IFC?s ESAP requirements, HACCP/ISO22001 and RFA?s P&C compliance at plant and farms.

Monitoring and Reporting. Malawi Mangoes has not yet defined and/or implemented a comprehensive corporate EHS monitoring and reporting system procedure, including a report format. Malawi Mangoes has made such a commitment during IFC?s due diligence as these are all requirements inherent to the voluntary standards it is aiming to adhere to. Once the foundation of the Integrated EHS Management System is designed and implemented by end 2014, MM will devote increasing interest into this monitoring/reporting as it is a requirement for IFC, HACCP, Rainforest Alliance and off-takers to demonstrate continuous improvement in EHS performance, productivity and resource efficiency (water and energy). In addition, off-takers of MM?s products will also undertake third-party audits, against industry standards, as well as annual inspections from various Malawi?s ministries (e.g. environment, labor, etc.). The IFC team was informed that MM hold Management Review meetings twice a year while there is formal monthly management review on internal audits, including EHS. Going forward, as set forth in the ESAP, MM will define a comprehensive set of Key Performance Indicators (KPIs) in order to monitor on a monthly/annual basis the following EHS parameters: a) Safety ? Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; b) Sustainability ? Carbon (kg/ton), Water Usage (kiloliters/ton) at processing and farm operations, Energy Usage (kWh/ton), wastewater monitoring effluents, noise, air emissions parameters from boiler, use of Crop Protection Products (CPPs) and fertilizers; c) Staff ? Retention/turnover and training days.

In addition, the EHS coordinator will define an integrated EHS report format and based on critical EHS key performance indicators (e.g., compliance with Malawi legal and regulatory requirements, including Certificate?s Terms and Conditions, EHS management system progress report and certification (ref. HACCP and RFA), energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and hazardous waste management and disposal, effluent discharges from the WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, supplier performance and community engagement activities. The company will also report annually to relevant Malawian authorities, off-takers and IFC as part of the Annual Monitoring Report (AMR). Based on information provided during appraisal, Malawi Mangoes did not incur over the last two years any material regulatory penalties, fines or sanctions for contraventions or non-compliance with statutory obligations, as well as not reported any fatalities at any of its plant/farming operations.

Emergency Preparedness and Response. Malawi Mangoes? operation at the processing plant and farming operations could be associated with fire and explosion, including diesel reservoirs and coal storage for the boilers and gensets, as well as numerous other dangers (e.g. CPP spill at farms). As the plant is yet to be fully commissioned, MM is in the process of finalizing the Internal Operational Procedure (IOP) for an emergency preparedness and response plan. It is committed to obtain all fire certificates and/or going through necessary fire audits at all sites. Several consultancy firms have already been contacted to perform fire drills as well as 1st aid training sessions which will cover all MM operational departments. During the site visit at the plant and farms, visual observation of installation of a fire prevention system, including fire hydrant and hose and extinguishers in accordance with Malawi standards, was noted. Dedicated water reservoir in case of fire at processing plant was also sighted. When the OHS Committee at plant and farms will be established, this entity will have the responsibility over fire prevention, response and training. A fire brigade will be established at all sites and coordination with Malawi Defense Force will be established (Salima being a small town and having no fire brigade per se). Extinguishers are available at the farm operations (especially at diesel tanks, pumping house, and at control pest products storage). Evacuation plan and fire accident meeting points have implemented at the processing plant and awareness raising on these will be part of the fire training curriculum. Going forwards, as set forth in the ESAP, MM will provide IFC, for review and approval; i) the Internal Operational Procedure for emergency preparedness and response for all sites; ii) fire prevention procedure and certificate for all sites; and iii) OHS Committee role and responsibility in emergency response, including fire brigade composition at all sites and annual emergency/fire training.

Stakeholder Engagement Plan. During the preparation process of the EIA Studies at all sites, and in accordance with the Malawian?s environmental assessment process, Malawi Mangoes has undertaken stakeholder consultation in order to verify suitability of project site, land allocation granting in accordance with legal and procedures of the Government of Malawi, mitigation measures to be included into project design and benefits of the project. District Commissioner and its team (agriculture, environment, forestry, water resources officers, etc.) as well as villagers from surrounding communities welcomed the project as a source of alternative livelihoods and employment opportunities. List of stakeholders consulted and summary of comments are found in the Annexes of each ESIA?s Study. In addition, comprehensive consultation has taken place during the land leasing process on a willing lessor-willing lessee for Salima plant, and Matumba, Dzuwa and Nyu Nyu Farms) as per the Guidelines of the Ministry of Lands, Housing and Urban Development / Green Belt Initiative (GBI) on conversion of customary land to public land. Progress report received during field appraisal validated this informed consultation and participation from project affected peoples. To demonstrate its corporate commitment toward harmonious relationships with surrounding villages, and in accordance with standards requirements (e.g. Rainforest Alliance), Malawi Mangoes has drafted a Social Responsibility Policy which objectives is to outline its commitment to compliance with Malawi Labor Laws and International Labor Organizations (ILO), provision of job opportunities for the communities around its operations and ensuring conducive and safe working environment, including on-site health clinics in case of injuries. Procedures of MM?s on-going stakeholder engagement, including meeting minutes, were not available during site appraisal. Minutes should be kept as part of the SEP.

IFC appraisal findings considered that the stakeholder engagement demonstrated by Malawi Mangoes has thus far been appropriate considering the risks and impacts of the proposed plant and farming operations. However, this stakeholder engagement needs to be strengthened and formalized to meet the social risks and challenges, especially at the farm level. As set forth in the ESAP, Malawi Mangoes will prepare a combined Stakeholder Engagement Plan and Community Relation Plan for all its sites, in accordance with IFC?s Performance Standard1 (PS1), including identification of stakeholders, determination of their level of interest and influence in the project (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. MM should also recruit or assign a community liaison officer at each operational site. The objective of the plan will be to strategically manage engagement and relations with project stakeholders and locally affected communities on a medium-long term basis.

The main challenge for Malawi Mangoes will be to maintain a motivated and skilled workforce. While labor supply will not represent a risk, managing workforce issues and community expectations will be crucial to maintaining the company’s social license to operate. The business growth is dependent on a large workforce and thus will need to treat engagement and good relations with workers and communities as a priority. Appraisal findings confirmed that MM fully understands these risks.



Human Resource Policy and Management. Malawi Mangoes processing and farming operations employ more than 605 employees, including 520 male and 85 female, where most of the positions are in the agriculture department (ref. 544). With the proposed CAPEX from IFC, a second processing line will be established. This additional shift will required approximately 113 positions. More permanent and seasonal positions will be required at the Dzuwa and Nyu Nyu farms. It is estimated that there is approximately one job created per ha of production. As such, the establishment of these farms should create more than 2,000 additional jobs. MM is committed to reach a 50/50% gender balance in all its operations. In order to support reaching this objective, MM will establish, among others, day care at its farming operations (e.g. Matumba).



In accordance with the Malawian Employment Act (2000) and its amendment, Malawi Mangoes has recently updated and adopted a series of Human Resources Policies whose scope is applicable to all permanent employees with indefinite term of contract with the company. The intent is to apply also these policies requirements to casual and contractual workers. Specifically, MM has adopted in March 12, 2014 a HR Policy Statement, a Staff Handbook and a human resources’ standard operating procedures which outlines the following provisions: term of employment and recruitment, values of diversity and dignity at work, hours of work (40 hours/week to a maximum of 48 hours/week), pay, benefits and pensions, sickness pay provision, leave arrangements (annual, maternity), freedom of association, occupational health and safety, training and development, and separation/retirement. In addition, Disciplinary and Grievances Procedures, contacts and confirmation form of receipt of Staff Handbook are outlined in the Appendix. In addition to this Handbook, MM has adopted a Code of Conduct. Finally, a series of policies, related to non-discrimination and equal employment opportunity, leave administration, HIV/AIDS in the workplace and education, prevention and care, student placement intern (for workers over 18 years old), relocation policy, training, grievance, communication, retirement, etc. These sets of policies are communicated during site meetings and notice boards. Supporting evidence of a PowerPoint presentation on Fair Treatment and good working conditions for employees, as spelled out under Rainforest Alliance requirements was shared with the IFC team during appr
aisal. Malawi Mangoes’ HR policy framework is in compliance with ILO and Malawi’s labour requirements as well as IFC’s Performance Standard 2 on labor and working conditions. Pending actions are the approval of the HR Policy by Malawi Mangoes’ Board of Directors, the establishment of a registry demonstrating acknowledgment of receipt of a Staff HR Handbook from every worker, permanent or seasonal, and the translation of all HR materials in local dialect (Chichewa) for presentation and distribution to all staffs. Internal and external (e.g. District Labor Inspector and sector standard, ref. Rainforest Alliance) HR audits are taking place on an annual basis.



Recruitment process involves the Salima District Authority where job announcements are posted. Even through there are deliberate efforts from MM to recruit peoples surrounding its operations, there is no such explicit reference in its HR policy in order to avoid any discrimination. When job application forms are received, managers and HR officers are mobilized to establish short-listing based on skills outlined in the job description. Supporting documentation requested from all short-listed applicants is the original copy of his/her diploma, driver license, health certificate, ID card (which indicates birth date). A questionnaire is also sent to previous employers for references. Every permanent employee has a signed contract as well as casual workers (in this latter case, the contract is a concise two-pager). Medical health checks are conducted after recruitment. MM will conduct employee health checkups once a year for workers at Critical Control Points in processing unit as well as workers in farming operations assigned to CPP/pesticide spraying (monitoring of cholinesterase level).



Salary grid associated with job grades (ref. General, Technicians and Management and Senior Supervisors) in Malawi Mangoes has been provided to IFC during appraisal. Estimated minimum monthly payment for lowest job grade (which applies mostly to agricultural workers) in Malawi is $29.50 while minimum monthly salary offered at MM farming operations is $35.00, 20% over and above minimum wage. Annual salary increase of 20% is offered to labor in order to mitigate the inflation rate in Malawi. Performance evaluation system will start in June 2014 with mid-year and end of the year review using SMART performance indicators (specific, measurable, assignable, realistic and time-related) which should noticeably introduce performance based bonus systems, especially for workers at plantations. It is envisioned that performance bonuses will not only be cash related but also non-financial related, such as training. As per the new Pension Act, employees contribute 5% of their gross monthly salary and MM contributes 10% of the employee’s gross monthly upon employment. Private Health Service Provider is available for permanent staff, MM covering 80% while employees cover 20%. Generally speaking, there is limited staff tur
nover at MM operations (2% for the period of April 2013 – April 2014) explained by the seriousness of Malawi Mangoes in fully respecting the provisions of its Staff Handbook, the company’s salary scale and benefits, and positive and harmonious relationship with the Company’s worker organization which is presently under development. MM subsidized maize purchase for its employees during a three month basis.



Human Resources management at Malawi Mangoes is under the responsibility of the HR Manager which is supported by two assistants. The HR unit is under restructuring process and the HR manager will be assigned to Salima’s processing unit while HR assistant officers will be assigned to Matumba, Dzuwa and Nyu Nyu farms. Changing rooms, toilets and shower facilities are available for workers and in excellent condition at the processing plant and respect gender sensitivities. Canteen is also being provided at the Salima’s processing plant. All farms will have changing rooms for CCP sprayers, including showers.



Retrenchment Plan. Considering CAPEX and future expansion of processing and farming operations of Malawi Mangoes, additional employment will be available. 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 will be prepared and submitted to IFC, well in advance of the actual reduction of the workforce.



Grievance Mechanism. Malawi Mangoes 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 Grievance Policy and procedure, it has established a formal and structured grievance mechanism procedure. This procedure includes steps to be taken by workers to manifest any concerns, engage in a mediation process, contact responsible persons, and provide timely feedback. Awareness on the grievance mechanism procedure is taken place during the worker’s induction session. This mechanism met IFC’s PS2 requirements. This grievance mechanism is applicable to permanent, casual and contractual workers. Reports of complaints may remain anonymous, as needed, and analysis of systemic issues are documented and addressed.



Workers organizations. MM fully supports in its HR principles the freedom of association to its workers and right for collective bargaining. MM is in the process of engaging with the Ministry of Labour to explain the process of formation of worker grouping, their roles and responsibilities. A worker organization exists at the plant but has not yet reached union stage. Workers at processing and farming operations will be covered and be represented by the Malawi Congress of Trade Unions (MCTU). Collective bargaining agreement will then take place on a yearly basis.



Occupational Health and Safety. Malawi Mangoes is strongly committed to ensure safe and healthy working conditions of all its workers, i
ncluding through the HACCP and RFA certification process. Specifically, in its Staff Handbook of March 2014, it has adopted a Health and Safety Policy whose scope of application encompasses MM employees (permanent and casual) and contractors and which seek to meet all legal OHS provisions defined in the Malawi’s Occupational Safety, Health and Welfare Act. As mentioned above, a workplace risk assessment has recently been taken at the farm while the plant processing manager will undertake such an exercise for the processing plant. The responsibilities for the effective implementation of the risk mitigation measures and training will be delegated to the processing plant and farm managers, supervisors and employees. In addition, an OHS Committee at corporate and plant-level will be established, which main objectives will be to ensure that the OHS policy and supporting procedures, annual work plan, supported by a training plan, be effectively developed and implemented. MM intends to recruit two (2) OHS officers (at processing plant and farms). There is presently on-going consultation with processing and chemical engineers on the job description. Every worker will be required to sign an Occupational Health and Safety Staff Acknowledgement Form in order to confirm that he/she has received; read; and understood the OHS policy and procedures. It is understood that employees at critical control points (e.g. chemical sprayers and machine operators) are specifically trained on the job on application of the SOPs in order to ensure safe operations. Provision of PPEs (boot, raincoat, and mask) has been sighted during site visit. The OHS officers, supported by processing/farming managers and the health’s clinic nurses, will undertake regular OHS internal audits at processing and farming operations to verify compliance with SOPs. External OHS audits will also be carried out by product-off takers and third-party standards auditors (ref. HACCP and RFA). During appraisal, IFC appraisal team was informed that only 3 accidents has taken placed at Matumba farm (ref. snake bites) in 2013 over 242,800 working hours (ref. 607 employees), resulting in two lost workdays. Malawi Mangoes has provided supporting evidence of its Certificate of Registration of a workplace for the period January 2014-2015 for its processing plant. Supporting evidence of OHS requirements into contractor’s contract has been provided. Malawi Mangoes is required to provide semestrial/annual report to the Salima District Health Authority. Going forward, as outlined in the ESAP, MM will provide to IFC, for review and approval, the workplace risk assessment for the processing and farming operations, set of SOPs applicable to OHS measures for the processing and farming (including extensions officers) operations, annual OHS training, including centers of responsibilities, budgetary allocations and schedule of delivery, findings of external and internal OHS audits which have taken place, Corrective Actio
n Plan (CAP), if required, and consolidated annual OHS performance reports.



Supply Chain Risk Assessment and Management. Malawi Mangoes is sourcing mangoes from local community out growers who will be progressively organized into a cooperative. These out growers totaling over 4,000 smallholders in a 30 kilometer radius of the processing facility are technically supported by MM’s extension team composed of 15 workers who live on a full time basis in the villages of the surrounding districts. Based on US Department of Labor’s List of Goods produced by child labor or forced labor, the agricultural sector in Malawi has been identified as having child labor on occasion. Malawi Mangoes is aware of this risk. In order to address this, MM is committed to expand the certification of its farming operations to a Group level, encompassing its overall supply chain. In addition, in order to pro-actively prevent any incidence of harmful child labor in its supply chain, MM will develop and implement, as set forth in the ESAP, a management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct which will specifically seek to avoid harmful child / forced labor, prevention of life threatening situations, from an Occupational Health and Safety standpoint, and/or expansion of passion fruit producing smallholders into natural/critical habitats leading to biodiversity loss. This code will be mainstreamed into its contractual sourcing agreement with mangoes cooperatives. Effective awareness of this Code will be under Malawi Mangoes’ extensions services.

Energy use and greenhouse gas emissions. Provision of energy to MM’s processing and farming operations (aside from Matumba Farm which rely on gensets but will be connected to the electricity grid by the end of Q2 beginning of Q3 2014) is provided by the national grid (Electricity Supply Corporation of Malawi – ESCOM). In addition, back-up generators are found at every farm units and processing plant in case of power outage (4 in total). As part of the CAPEX, Malawi Mangoes will be assessing the feasibility of establishing a biogas plant at the processing plant and solar panels at farms to ensure energy independency. The boiler at the processing unit is running on coal but will eventually also uses or switchover to biomass. Considering early operational stage, energy consumption is progressively being monitored at all sites but data on energy consumption (in kWh) and diesel (liters) were not available during appraisal. Mass and balance assessment has been carried out to optimize energy efficiency. Energy use should be expected to increase in the context of the CAPEX which include an additional processing line at the plant as well as increased energy need for the pumping station for the expansion of the drip irrigation at all three farms (Matumba, Dwuza and Nyu Nyu). In addition, MM plans to get its own fleet of trucks to move produce from farms and community areas to the factory. The return trip will be used to move factory zero value material (organic waste) to farms for organic fertilizer production. Fuel consumption is estimated at 1 liter per 3 km for a 20MT load. MM’s own fleet will reduce import of Potassium and Nitrogen fertilizers and create more efficient way of producing fruits and taking care of industrial waste.



Air emissions monitoring. Main source of air emissions are the gensets at all sites, the boiler (3,000kg/hr) at the processing plant and planned transport fleet. Gensets are only used for emergency basis. Both boiler and gensets undergo semestrial maintenance inspection to optimize efficiency. This being said, Malawi Mangoes have not yet started monitoring its air emissions. Going forward, as set forth in the ESAP, MM will monitor on an annual basis stack air emissions from its boiler and generators (if being used more than 500 hours/year) at all sites to ensure consistency with WBG EHS Guidelines for point source emissions to air (PM10: 50mg/Nm³, NOx: 460mg/Nm³; SO2: 2,000mg/Nm³) and will report them in the IFC Annual Monitoring Report. During site visit, it was observed that the chimney of the boiler was respecting industrial length (25 meter stack) to ensure effective air dilution of the exhaust gases. This being said, it was observed that exhaust pipe for genset at Matumba farm should be lengthened.



Water use and efficiency. All of MM agricultural production is under drip irrigation, the most efficient water delivery system. In addition, other water conservation measures, such as contouring and mulching are all ai
med at minimizing evapotranspiration (ET) losses as well as run-off. Use of tensiometers are adopted to assist with irrigation scheduling, but given that drip irrigation does not seep outside the root zone, it is difficult to supply excess to requirements. There are, however, times when flushing of salts outside the root zone is required to maintain a healthy root structure, and for this it is necessary to apply excess water to flush out salts. This is a soil management practice and not an irrigation one. Frequency has yet to be determined, but the agricultural team is constantly monitoring any signs of salinity and other causes of crop deficiency that impact agricultural productivity. Soak pits are implemented to prevent any contaminated water flowing into seasonal/permanent watercourses, such as the one on Matumba farm.



As mentioned above, raw water at the processing plant is sourced from Central Region Water Board (Salima Township) and does not require any water extraction right per se. A back-up borehole is also found on site. At Matumba farm, raw water is sourced from 16 boreholes which Malawi Mangoes has received permits for water abstraction from the Water Resources Board on September 23rd, 2013 for five years at a rate not exceeding 86.4M³. Supporting evidence has been provided during appraisal. With an annual rainfall of 1,200 mm in Malawi and limited pressure on aquifer, natural recharge is expected to take place. Water right extraction for Dzuwa and Nyu Nyu farms will be sourced from Lake Malawi where a pumping house has been installed. IFC team was informed during appraisal that water abstraction rights for Dzuwa farm has been obtained from the WRB for 735m3/hr. Supporting evidence of such has not been provided. Potable water meeting WHO requirements is available at the processing plant and farming operations for employee use. MM has also established a drainage evacuation system around its processing plant considering high rainfall in Malawi. Drainage system has also been established at Matumba and Dzuwa farms as these were previously marshlands. In accordance with Rainforest Alliance, MM will undertake a water resources management plan. In going forward, as outlined in the ESAP, MM will install water meter at all sites and will monitor its water consumption from surface and underground water for its processing and farming operations.



Wastewater Treatment. Considering the significant volume of water used during the fruit processing as well as its characterization, a dedicated wastewater treatment plant has been integrated into the technical design of the processing plant. The WWT plant was under construction during IFC’s visit. All water at processing plant will be treated (slow sand filter and chlorination) before being recycled (carbon filter) for industrial use or discharged to external drains. Sludge is collected and given to farmers as fertilizers. Septic tanks exist for sanitary effluents at the plant while latrines have
been installed at farms. MM is committed to comply with Malawian/WHO/Rainforest Alliance and WBG’s EHS guidelines for effluents discharge, whichever one being the most stringent and the WWT plant was designed accordingly. Water analysis of all discharged water, at processing plant and farms, will take place. As set forth in the ESAP, going forward, MM will monitor the performance of the WWT plant which shall meet all effluents parameters found in Table 1 of the WBG EHS Guidelines for food and beverage processing. Additional processing line considered under the CAPEX will ensure meeting wastewater treatment capacity.



Management of solid and hazardous wastes. Wastes from processing and farming operations are characterized mostly by organic waste (e.g., banana and mango peel at processing plant and crop residue at farms). These will be used as mulch, recycled as compost and/or sold as animal feed. In the long term, once there is a critical mass of organic by-product from the processing plant, MM is planning to install a biogas generator (after methane has been extracted, the by-product can still be used for composting). Others domestic wastes, such as paper, cardboard, wood, metal, are collected and disposed in assigned landfill on the farm. Plastics from nursery production (each plant having on average 0.5 m2 of plastic) are collected and recycled by a licensed service provider. Crates are recycled and are replaced as and when damage occurs. The site manager is in the process of identifying local recycling facilities. Inorganic waste, such as empty fertilizer and pesticide containers are collected and returned to local suppliers. In case of imported CPP products and non-returnable, these are triple rinse, puncture and buried in a well-defined pit location at each farm.



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 processing plant. These will be installed at all farming operations (Matumba, Dzuwa and Nyu Nyu) when final construction works will be completed.



Cooling and ripening agents. There is no use of any cooling agents, such as glycol or ammonia. Chillers and compressors are running on R304 refrigerant that does not come into contact with workers. Ethylene gas, imported from South Africa, is used in the eight (8) ripening chambers with 60mt capacity. Like all hydrocarbons, ethylene is an asphyxiant and combustible. Sensors in ripening chamber include Temperature, Relative Humidity, Ethylene concentration and CO2 concentration. Ceiling ventilation system is present to ensure safety conditions for workers against suffocation.



Pest Management and Control. MM’s crop protection product (CPP) list is based on approved CPPs by the Malawian Ministry of Agriculture (ref. Pesticides Control Board), cross-referenced with any restriction, such as RFA and Sust
ainable Agriculture Network’s severely restricted and banned chemicals. Based on feedback from the Agricultural Research, bunchy top virus (banana) is prevalent in Malawi but can be managed. No significant pest issues exist with mango. Going forward, Malawi Mangoes will prohibit the use of WHO recommended classification of pesticides by hazard Class Ia and Ib and restrict the storage, handling and use of Class II pesticides to staff which has received proper training and systematic use of Personal Protective Equipment (PPE), as well as limited access to these personnel. At the processing plant, an HACCP procedure for this issue already exists and is implemented. At its farms, as drip irrigation system are used, MM is using a system to dose liquid fertilizers and chemicals into the drip lines, resulting in a highly controlled and efficient system. Additionally, organic production is a key goal of the farming operations, aiming to use organic certified products in its fertigation system. MM has adopted an Integrated Pest Management (IPM) policy, in accordance with Rainforest P&Cs requirements. Some aspects of this IPM have yet to be fully implemented as procedures and records are being developed and/or improved. As set forth in the ESAP, MM will provide to IFC its IMP plan, when available as well as the final list of PPP used at farms.

Community Health and Safety. Malawi Mangoes’ processing and farming operations 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. MM has not yet adopted a Road Transport Policy and supporting procedures. Forklift drivers at the processing plant are recruited based on several years of training and experience. Certificates were available during appraisal. As set forth in the ESAP, in the context of establishing its own truck fleet, MM will develop and implement a safe driver and transport safety vehicle policy and procedure, including health checks and training sessions for all its drivers. Food safety of MM products is covered under HACCP certification requirements, including traceability.



Community Grievance Mechanism. As indicated in the Stakeholder Engagement Plan under PS1, even though MM is fully committed to harmonious relationships with surrounding communities and response to any potential grievance, MM has not yet formalized a structured mechanism to manage and response timely to community grievances. The communities are using the local leaders who liaise with the MM’s Farm Manager. As set forth in the ESAP, MM will define and adopt a community grievance mechanism to strengthen its consultation and responsiveness with any potential communities’ grievance on the E&S risks and impacts associated with its operations and will assign a community liaison officer at each of the farm operations.



Security Personnel. There is no significant level of security issues in the Salima District where the project is located. For the time being, MM is assigning its own staff for the protection of its farms during day and night. These are internally trained by an ex-paramilitary employee on security issues and are not armed. As the farms will eventually enter into full production, especially for mangoes, MM will outsource security coverage with a security licensed provider using a canine unit and rapid deployment alarm services. Same approach will be adopted for the factory and office premises. 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. Going forward, as set forth in the ESAP, MM will develop and implement, based on a risk assessment, a Security Management Plan which will consist of an Operating Policy and Procedures, including training, on defensive use of force by own and outsourced security personnel. MM has established well defined corridor for passing through its farms by surroundings communities.

Protection and Conservation of Habitats and Sustainable Management of Living Natural Resources. Current farming operations (Matumba and Dzuwa Farms) are located in a modified habitat landscape. This assessment has been confirmed by the Rainforest Diagnostic Report, dated November 2011, for Matumba. This assessment is also confirmed by internal IFC review, using the Integrated Biodiversity Assessment Tool (IBAT). Nearest park from the Matumba farm is the Kuti Community Wildlife Park which is about 10km from the farm. It is expected similar assessment for Dzuwa and Nyu Nyu farms as Malawi Mangoes is committed to certify all its farming operations under Rainforest Principles and Criteria. IFC appraisal team was informed that an afforestation program is under implementation; more than 4,000 indigenous trees (acacia and neem) as well as guava (for monkey) have been planted at Matumba farm since 2013.



Supply Chain. As previously indicated under PS2, MM is planning to extend its sourcing from out growers, which presently totaled more than 4,000 smallholders. In addition to expand RFA certification from its own plantations to all its sourcing, MM will adopt, as set forth in the ESAP, a Supplier Code of Conduct which will specifically seek to avoid harmful child / forced labor, prevention of life threatening situations, from an Occupational health standpoint, and/or expansion of passion fruit producing smallholders into natural/critical habitats leading to biodiversity loss. This code will be mainstreamed into its contractual sourcing agreement with mangoes cooperatives. Effective awareness of this Code will be under Malawi Mangoes’ extensions services.

Malawi Mangoes has established a separate Malawi Mangoes Community Engagement and Investment Foundation through which leading philanthropic and developmental organizations can leverage MM’s reputation in order to carry out crucial water, health and educational services work. It is planned, in the next 18 months, to provide long-term support to a primary school at the village of Matumba, located next to MM’s first farm (the only one in a radius of 10 kilometers), construction of boreholes in surrounding villages, and introduction of bee hives for production of honey. Regular training seminars for technicians and laborers on the benefits of drip-irrigated agriculture, sustainable farming under the RFA certification regime and inter-cropping can be used to broaden family’s nutritional status. Finally, as mentioned above, MM run a subsidized maize scheme where MM buys bulk maize (main staple food in Malawi) during a time of year when it is at its lowest pricing point, and making it available to its agriculture staff through a loan scheme at that same price during the “hungry” season, when the retail price can be three times as much. Socio-economic (employment) and overall development impacts of MM, especially at its farm operations, are significant. Strategic Action Plan of this Foundation should be aligned with pro-actively supporting the Millennium Development Goals within MM’s surrounding communities. MM is also working with RFA in the protection and conservation of the nearly located Kuti Community Wildlife Park.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. The company will also be requested to place an advertisement in a local newspaper in the Salima District as well as its website (http://www.malawimangoes.com) to inform the public from IFC’s environmental and social review (ESRS) findings and ESAP’s corrective action items is available at public sites, such as the District Office in Salima.

Name and Address.
Mr. Craig Hardie and Jonathan Jacobs, Managing Directors
MM (Operations) Limited
P.O. Box 31264, Lilongwe 3, Tel: +265 (0) 1 770 396;
E-mail: mailto:craig@malawimangoes.com; mailto:jonny@malawimangoes.com

Broad Community Support is not applicable for this project

Malawi Mangoes(34816) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Malawi Mangoes will finalize and approve its EHS Policies, design and implement an Integrated Environmental and Social Management System (ESMS) – consistent with ISO 14001, OHSAS 18001, HACCP/ISO 22001, Rainforest Alliance – applying to all its existing and new operations, to be reviewed and approved by IFC, including standard operating procedures (SOPs), plans and accountability framework to enable it to comply with Malawian laws and regulations, including environmental permits’ Terms and Conditions, IFC Performance Standards and applicable WBG Environmental, Health and Safety (EHS) Guidelines.	30-Nov-2014	Completed	Completed	11/30/2014
The ESMS will include mechanisms for the EHS coordinator to report, on a trimestral basis, E&S monitoring results to MM’ senior management who will need to sign off on the reports.	31-Mar-2016	Completed	Completed	3/31/2016
Malawi Mangoes will establish a matrix format to review and update compliance status for all its operations (plant and all farms), including supporting evidence of meeting Ministry of Environment (MoE), Water Resources Board (WRB) and OHS permit’s Terms and Conditions, implementation of ESIA’s Environmental Management Plans at all sites, implementation of HACCP and Rainforest’s Principles and Criteria and will present to IFC, for review, a consolidated report on all these recommended mitigation measures, progress/completion status and action plan with defined timetable for effective implementation, including center of responsibilities and budgetary allocations.	30-Nov-2014	Completed	Completed	11/30/2014
Implementation of ESIA’s Environmental Management Plans at all sites, implementation of HACCP and Rainforest’s Principles and Criteria	31-Mar-2016	Completed	Completed	3/31/2016
Evidence of an EHS unit in MM organogram, assignment of OHS officers at plant and farms, and provision of updated job description of operational managers as it relates to their respective EHS responsibilities to effectively implement the ESMS.	31-Aug-2014	Completed	Completed	8/31/2014
MM will, upon completion of the Integrated EHS Management System’ policies, procedures and plans mentioned under ESAP Action Item 1, define a comprehensive and multi-year training plan for its staffs at the processing plant and farming operations for IFC review and approval, including center of responsibilities for its effective implementation and budgetary allocations.	31-Aug-2014	Completed	Completed	8/31/2014
MM will define a comprehensive set of Key Performance Indicators (KPIs), based on permit’s Terms and Conditions, EMP, and WBG EHS Guidelines, in order to monitor on a monthly/annual basis the following EHS parameters: a) Safety – Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; b) Sustainability – Carbon (kg/ton), Water Usage (kiloliters/ton) at processing and farm operations, Energy Usage (kWh/ton), emissions parameter from boiler, wastewater monitoring effluents at processing plant and drainage waters at farms, noise, CPP used at farms, etc.; c) Staff - Retention and training days. In addition, the EHS coordinator will define an integrated EHS report format and based on critical EHS key performance indicators (e.g., compliance with Malawian legal and regulatory requirements, EHS management system progress report and HACCP/RFA Standard certification, energy and water consumption and efficiency; noise levels and management, solid and hazardous waste management and disposal, effluent discharges from the WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, community engagement activities. The company will also report annually to relevant Malawian authorities and IFC as part of the Annual Monitoring Report (AMR). Annual EHS review will be discussed during the Company’s planning and budgetary management review	31-Aug-2014	Completed	Completed	8/31/2014
MM will develop and implement an Emergency Preparedness and Response Plan for all its operations (Internal Operational Procedure) and seek fire certificates for all sites. MM will recruit an independent fire consultant to perform a Life and Fire Safety (LFS) Audit of all MM operations against the Malawian fire safety code, define the OHS Committee role and responsibility in emergency response, and will have regular annual L&FS training and drills according to the emergency preparedness plan.	31-Jul-2014	Completed	Completed	7/31/2014
MM will prepare and implement an EHS Management System Procedures Addressing Stakeholder Mapping and Community Engagement, including a Community Grievance Mechanism Complying with PS1: Develop and implement a Stakeholder and Community Engagement Plan (SEP) and management system procedure. Provide a copy for IFC of the community engagement procedure, including a grievance mechanism for the communities in the vicinity of its farming, processing and distributions operations. Ensure that the mechanism is clearly communicated by posting on the Company website and included in relevant written public communications at the facilities. The procedure shall also promote engagement with potentially affected villages and homesteads on issues that could affect them and to ensure that MM’s feedback response information is disclosed and distributed among local residents and stakeholders. As part of the community grievance mechanism, MM will provide a means for communities to raise issues about the company’s security arrangements or personnel as outlined in PS4.	31-Aug-2014	Completed	Completed	8/31/2014
MM will strengthen its grievance mechanism to enable anonymous complaints and tracking and analysis of systemic issues	31-Aug-2014	Completed	Completed	8/31/2014
MM will provide to IFC, for review and approval, the set of Policy and SOPs applicable to OHS measures for the plant and farming operations, annual training, including centers of responsibilities, budgetary allocations, and schedule of delivery, external and internal OHS audits which have taken place, Corrective Action Plan (CAP), if required, and consolidated annual OHS performance reports.	31-Mar-2015	Completed	Completed	3/31/2015
MM will develop and implement a management procedure for its supply chain, which will include the development and implementation of a Suppliers Code of Conduct which will specifically seek to avoid harmful child / forced labor, prevention of life threatening situations, from an Occupational health standpoint, and/or expansion of mango producing smallholders into natural/critical habitats leading to biodiversity loss. This code will be mainstreamed into its contractual sourcing agreement with mangoes cooperatives. Effective awareness of this Code will be under Malawi Mangoes’ extensions services.	31-Mar-2015	Completed	Completed	3/31/2015
MM will monitor for applicable WBG’s effluents guidelines, especially for pH, BOD, COD, total suspended Solids, Grease, total nitrogen and total phosphorus at the processing plant’s WWT unit. Quality monitoring of drainage water at farms will also take place.	30-Nov-2015	Completed	Completed	11/30/2015
MM will monitor all its water consumption for its processing and farming operations	31-Aug-2014	Completed	Completed	8/31/2014
MM will share with IFC, for review, a) Signed contract with the qualified service provider for the collection and disposal of used oil. b) Signed contract with contractors for construction of the secondary containment structures for diesel containers at all farms	31-Aug-2014	Completed	Completed	8/31/2014
MM will conduct air emissions measurements at stack for all its boiler and compare parameters with WBG General EHS Guidelines for ambient air concentrations (particulate matter limit (PM10) of 50mg/Nm³; NOx of 460 mg/Nm³; SOX of 2000 mg/Nm³, and submit a report to IFC.	30-Nov-2014	Completed	Completed	11/30/2014
If measurements exceed WBG limits, MM will propose corrective measures, and a schedule to bring all emissions into compliance with WBG limits.	30-Nov-2015	Completed	Completed	11/30/2015
MM will provide to IFC, for review, its Integrated Pest Management Policy, procedures and plan for its farming operations, including training program for its effective implementation. It will also prohibit the use of WHO recommended classification of pesticides by hazard Class Ia and Ib at farms operations, and restrict the storage, handling and use of Class II pesticides to staff which has received proper training and systematic use of Personal Protective Equipment (PPE), as well as limited access to these personnel.	30-Jun-2014	Completed	Completed	6/30/2014
MM will develop and implement a Vehicle Operator Safety Policy, Procedures, and Training Program for its drivers and contractors emphasizing the following: safety aspects among drivers, improving driver skills, licensing of drivers, limits for trip duration, duty roster to avoid overtiredness, avoiding dangerous routes and times of day to reduce the risks of accidents, use of speed control devices on vehicles; and, remote monitoring of driver actions, behavior and performance and overall truck maintenance	30-Nov-2014	Completed	Completed	11/30/2014
MM will provide to IFC, for review, a Security Operating Policy and Procedures, including training, on defensive use of force by own and outsourced security personnel. Procedural directions will include how security forces will be managed in accordance with IFC PS4 requirements as described in paragraph 12 and 13, and will include provisions that all security personnel must have a background check on file that shows they have no record of human rights abuse, and provisions on how to respond to threats guided by the principle of proportionality. It will include the ability to raise complaints regarding security personnel as part of the Community Grievance Mechanism referred to in PS1.	31-Aug-2014	Completed	Completed	8/31/2014
MM will develop and implement a Land Acquisition Policy and Framework for its farming expansion, e.g. Nyu Nyu farm. This will outline the type of social due diligence and possible census/socio-economic studies that the Company will undertake prior to acquiring land, to ensure that the land is not occupied, not being used for economic purposes, or to potentially resolve land tenure issues prior to or during the land acquisition/leasing process. In the future, a RAP or LRP will be completed prior to any physical or economic displacement taking place, to offset any impacts on communities and individual households and provide mitigation measures.	31-Aug-2014	Completed	Completed	8/31/2014
For existing plantation where the lands may have been used for subsistence agriculture (e.g. Dzuwa), GBI and MM will conduct a Socio-Economic baseline survey to gain a more thorough understanding of the current situation of the households located in the 10 affected villages at Dzuwa farm, and their ability to restore their livelihoods. This will be verified through undertaking resettlement audit of land leasing process for families which have been economically relocated to assess restoration of their livelihoods, including benefiting from employment opportunities at Malawi Mangoes operations. If need be, as per PS5 requirements, Malawi Mangoes will carry corrective actions.	30-Nov-2014	Completed	Completed	9/30/2016
MM will certify its farming management practices against a credible recognized sector standard (e.g. Rainforest Alliance) within one year of farm establishment for all its farming operations.	30-Sep-2015	Completed	Completed	9/30/2015