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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
No land acquisition is expected as part of the project. It is for this reason that issues covered by PS5 “Land Acquisition and Involuntary Resettlement,” PS7 “Indigenous Peoples,” and PS8 “Cultural Heritage” are not expected to be encountered during the life of this Project.
Belagricola does not cultivate directly any crop, and rely on a small number of suppliers to multiply soy and wheat seeds. Belagricola also operates with farmers under barter arrangement, in which Belagricola provides crops inputs under a crop supply contract with farmers. Since Belagricola operates exclusively on consolidated areas of grain production in Parana and São Paulo States, it is not expected that there will be any significant land conversion component in this project, either directly from the client, or from the supply chain.
Belagricola produces and sells genetically modified seeds (GMOs) and the genetic material is purchased or licensed from the large crop science multinational companies. All products must be authorized and approved by the Brazilian Biosafety Committee and Registered by the Ministry of Agriculture. Therefore, PS6 “Biodiversity Conservation and Sustainable Management of Living Natural Resources” issues are also not expected to be encountered during the life of this project.

Environmental and social management systems and technical capacity for its implementation, monitoring and reporting; compliance with local permits and licenses including product registration; operation of distribution centers and silos; transportation of agrochemicals; handling, storage, distribution and transportation of hazardous materials; emergency response; labor and working conditions, including occupational health and safety; pest control management strategy and professional guidance to the clients in the use of the products distributed; biodiversity protection in reference to potential deforestation; the distribution of seeds; and, relations with the community.
Potential adverse effects arising from these issues are limited; site specific and may readily be addressed through mitigation measures. On this basis, this investment is therefore a Category B project according to IFC’s Environmental and Social Review Procedures.

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. Belagricola has agreed to take some actions to enhance existing management function and aimed to mitigate environmental and social risks, which includes the following: additional assessment of EHS regulatory requirements and respective corrective action plans of all Silos; Safety assessment of all pesticides warehouses to meet Brazilian safety standards; consolidating sustainability function in one officer and enhancing organizational capacity; reviewing and enhancing monitoring practices; defining environmental, health and safety (EHS) indicators, objectives and goals.

Belagricola has presented information on its current policies, procedures and practices that seek to address the potential E&S risks and impacts and to ensure that, upon implementation, the proposed project will comply with all applicable environmental and social requirements. Applicable social and environmental requirements include Brazilian laws and regulations, IFC’s Performance Standards, and the WBG’s Environmental, Health, and Safety General Guidelines. The information about how these potential impacts will be addressed by Belagricola is summarized in the paragraphs that follow. Additional actions are presented in the attached Environmental and Social Action Plan (ESAP).

-Social and Environmental Assessment: Belagricola has submitted the required Environmental Licensing Application Form (Requerimento de Licenciamento Ambiental) to the Brazilian authorities for all its distribution centers and silos, and in conjunction with this the respective Environmental Control Plans and Environmental Monitoring Plans and Solid Waste Management Plans (Plano de Monitoramento Ambiental e Plano de Gestão de Resíduos Sólidos, in Portuguese). These plans have allowed the Company to obtain all applicable environmental licenses. In addition, Belagricola has developed all mandatory OHS risk prevention plans for its units (Plano de Prevenção de Riscos Ambientais, PPRA) as well as Worker’s Health Monitoring and Surveillance Plans (Plano de Controle e Monitoramento da Saúde Ocupacional, PCMSO). Accordingly, such plans and application forms define existing controls to mitigate potential environmental and occupational health and safety risks. The Company provides reports and updates to the local regulators as defined in the granted permits. Belagricola has also requested and obtained Life and Fire safety Certification (Auto de Vistoria do Corpo de Bombeiros – AVCB) for all silos.

All products distributed by Belagricola, including fertilizers, seeds and agrochemicals have been approved by the Brazilian authority ANVISA (Agência Nacional de Vigilância Sanitária) as well as by the Ministry of Agriculture. The transportation of products follows Brazilian Traffic Code requirements for hazardous materials transport. Belagricola is current on all the licenses and permits required by local law. Belagricola does not manufacture chemicals or develop new products, and its role is limited to distribution of products and seeds production already approved to be used in Brazil.

-Social and Environmental Management Program: Belagricola has policies and procedures to manage human resources, safe transportation of materials, Occupational Health and Safety at workplace, emergency response, and the requirements contained within the above mentioned environmental permits. The Company does not have a formal Social and Environmental Management program or system; however, Belagricola has the basic structure to enable it to comply with local regulatory requirements. Going forward, Belagríc
ola will take the actions described in the forthcoming paragraphs that includes additional risk assessment and corrective action plans; consolidating sustainability function and enhancing organizational capacity; reviewing/enhancing monitoring practices; defining EHS KPIs, objectives and goals.

Therefore, as set forth in ESAP, the Company will conduct an EHS assessment on all silos to meet Brazilian regulatory requirements such as OHS standards (known as NRs – Normas Regulamentadoras do Ministério do Trabalho), as well as to meet newly issued Life Authority standard for Grain Silos (Instrução Técnica do corpo de Bombeiros) from São Paulo and Parana States, where applicable. Belagrícola will also conduct a safety assessment of all pesticides warehouses to meet Brazilian safety standards (NBR 9843 – Agrotóxicos e Afins: Armazenamento, Movimentação e Gerenciamento em Armazéns, Depósitos e Laboratórios; NR6 – Equipamento de Proteção Individual EPI; NR 23 – Proteção Contra Incêndio)

-Organizational Capacity and Training: Environmental, occupational health and safety, and human resources elements are the responsibility of the Chief Operating Officer (COO). On an operational level HR (labor) and OHS are being managed within the HR function; specifically, OHS matters are the responsibility of a team of 9 professionals that includes a physician, a nurse, one OHS engineer and six OHS technicians that support commercial/silos unit managers Environmental issues are managed within the engineering function.

Going forward, as set forth in ESAP, Belagricola will hire an experienced EHS manager to consolidate OHS and Environmental management functions under one same EHS/Sustainability structure and will be responsible to coordinate all EHS aspects of Belagricola’s operations. This professional will be responsible for implementing an EHS management system covering all regulatory requirements, appropriate organizational capacity and accountability, training, definition of key performance indicators, monitoring and auditing, and finally reporting unit’s performance internally to senior management.

-Training: Belagricola has structured training programs that include an EHS induction for new employees (and contractors) as well as mandatory job-specific trainings such as working at heights, working in confined spaces, work as machine operators, welding/hot work, handling and use of pesticides, electrical circuits and energized lines work, etc. The OHS team also provide specific training to selected local unit staff to conduct risk assessment of hazardous works and provide clearance for these jobs. Going forward, as set forth in ESAP, Belagricola will also develop a specific training program for unit managers to better support EHS unit’s objectives and goals.

-Monitoring and Reporting: Belagricola monitors basic environmental and social performance according to the Environmental Control Plans presented to the local authorities. Operational controls, and other mit
igations, are monitored. Both leading and lagging indicators are monitored, and monitoring includes the use of energy and wood (for grain dryers), incidents and accidents with day loss, workers exposure to hazard agents (noise, dust) and of use of Personal Protective Equipment (PPE), fire extinguisher inspections, mandatory training programs, air emissions from grain dryers and air quality. Belagricola does periodic inspections through checklists to ensure proper environmental and safety conditions. However, monitoring practices vary from one site to another and to ensure consistency across all operations, as set forth in ESAP, Bleagricola will review and consolidate its monitoring practices defining appropriate KPIs to measure performance from all sites (such as accident frequency and severity rates, performed vs. required trainings, number of audit findings, energy and wood consumption, number of unsolved regulatory gaps, solid wastes volumes and disposal, complains lodged into its grievance mechanism, and so forth). Based on these KPIs, Belagrícola will define specific EHS objectives and goals for all units that will be under unit manager’s responsibility and performance objectives.

Belagrícola workforce comprises approximately 1,300 permanent workers. In addition, 500 to 700 are hired on a temporary contract basis during the peak of their operations to support the work at warehouses and silos.

-Human Resource Policy and Management:

Through its human resources policies and practices, which are clearly articulated and readily available to workers, Belagricola seeks to abide by all Brazilian legal requirements regarding working conditions and management of the employer-worker relationship, to promote a positive work environment, and to retain and motivate its workforce. Employees are hired on the basis of mutually understood contracts, they undergo an induction and training process, and end-of-employment formalities are carried out in a transparent and orderly fashion. Time clocks are mostly electronic and readily accessible to the workforce, and overtime is calculated and duly paid. Belagricola reported paying all employer social security taxes and legally-mandated benefits, a practice that is monitored by labor authorities through use of a mandatory official web based system for reporting on employer payments of social security taxes and similar payroll.



Belagricola has a suitable code of ethics that covers key elements of PS2. The code makes explicit reference to issues such as non-discrimination and equal opportunity, grievance mechanisms to employees, protection of the workforce, and respect in the workplace. The code is communicated to all employees, and new employees receive a human resources package which contains: the code of ethics with business management principles; internal workplace code; client relationship policy; contractors and service providers policy, competitors engagement policy; OHS guidelines; copy of working contract in which wages, benefits and overtime compensation are described; roles and responsibilities; among other documents.

-Working conditions and Terms of Employment: Labor rights in Brazil are enshrined in the constitution and the consolidated labor laws (known as Consolidação das Leis do Trabalho, or CLT, in Portuguese), and labor relations are highly regulated under the country''s laws and labor practices. Terms of employment, hours of work, breaks, rest days and overtime compensation, leave for illness, vacation, maternity or holiday, minimum wage, benefits and wage deductions are all regulated in Brazil and consistent with relevant ILO conventions and IFC PS2 standard requirements. Belagricola follows collective bargaining agreements with Unions by sector which defines salary increase, profit sharing arrangements, benefit packages, sector specific working hours and overtime arrangements among other things.

-Workers Organizations: In Brazil, all workers must be linked to a union, and contribute one day of wages per year as a mandatory fee. The union the workers are linked to depends on the professional activity and geographical place of work, pursuant to the registries before the Emp
loyment and Labor Ministry. There are collective bargaining agreements which set annual salaries, benefits and terms of employment. There is a national baseline well established by law for certain parameters, such as the minimum wage. The unions are very strong and Belagricola supports employees’ rights to freedom of association and collective bargaining in compliance with Brazilian law. In Belagricola case, the workforce belongs to approximately 14 different unions, divided by occupation, sector and region.

-No Discrimination and Equal Opportunity: Belagricola has explicit codes regarding non-discrimination aspects on its operations and the company applies the principles of Equal Opportunity. No evidence of discrimination based on personal characteristics or gender was found during appraisal, and worth to say, discrimination is a crime under Brazilian law. Fair treatment is observed in the Company, including processes of hiring, promotion and termination of employment.

- Protecting the Workforce: Belagricola scrupulously follows Brazil''s legislation on minimum age. The Company checks the worker''s age at time of application, recruitment, and contracting. For example, the Company''s HR system automatically blocks any attempt to register a new employee below the legal working age. The Company does engage trainees of 16-17 years of age under the Brazilian government''s “Novo Aprendiz” mandatory training program, but it follows all requirements of the program, including limited work hours to allow for participants'' schooling and prohibitions against exposing trainees to any forms of hazardous labor. Belagricola has no cases of child labor or forced labor in the labor courts.

- Occupational Health and Safety – Belagricola has an OHS program which includes a set of operating objectives based on the identification and quantification of workplace risks coupled with applicable legal and other requirements. To prevent workplace accidents and promote the health of its employees, Belagricola implements Brazilian Regulatory Norms (NR) applicable to its operations including those related to the identification and monitoring of chemical and physical hazards through a Workplace Environmental Risk Prevention Program or PPRA (“Programa de Prevenção de Riscos Ambientais”), use of personal protective equipment (PPE), emergency preparedness and response, and medical surveillance (PCMSO or “Programa de Controle Médico de Saúde Ocupacional”). Belagricola made visible investments on their facilities to promote safer working environment such as: identifying and restricting access to confined spaces, lifelines with automatic rope grabs and guardrails for fall protection, intrinsically safe electrical circuits in areas with risk of explosion, process automation to reduce worker’s exposure to risk areas, dust suppression systems on silos. Belagrícola has also invested in worker’s protection providing adequate PPEs when there are no other better options to reduce exposure
to the risk (full body harnesses, ear plugs, respiratory masks, gloves, safety boots, uniforms etc).

As noted above, Belagricola relies on a team of one OHS engineer and six technicians to conduct OHS programs. The team has developed specific procedures that govern hazardous work including a risk assessment and permitting/clearance for the work. They also provide mandatory trainings for selected local unit staff, such as working at heights, welding/hot work, working in confined spaces, electrical circuits and energized lines work, etc. There is also physician and nurse in the team responsible for the implementation of Health Monitoring Program at Workplace that includes baseline, periodic, promotion or contract termination health assessments for all employees. For all workers that have access to pesticide’s warehouses, Belagricola requires blood sample testing on an annual basis to monitor potential intoxication with chemicals. Going forward, Belagricola will develop the mandatory Respiratory Protection Program (PPR – Programa de Proteção Respiratória) and Hearing Protection Program (PCA – Programa de Concervação Auditiva) consistent with local regulatory requirements.

Consolidated data from 2014 shows that accidents frequency rate is above the average levels of other countries, such as United States (Avg US for Warehousing and Storage is 9). Going forward, as defined in PS1 sections, Belagricola will strengthen its OHS management practices to address inherent risks from its operations. In summary, Belagricola must enhance monitoring and enforcing structures from EHS management function that must include higher commitment from senior management of the Company and clear definition of unit managers’ accountability for OHS performance. Specific OHS objectives and goals must be set for all operational units, and periodic monitoring of performance through specific KPIs. OHS conditions at workplace must be also improved after conducting gap analysis to meet local local regulatory standards, and implementing respective corrective action plans.

-Resource Conservation and Energy Efficiency: Belagricola’s activities are restricted to commercialization of agriculture inputs, crop seeds processing and grain collection; therefore, the use of natural resources is limited. The activities do not require water use, other than for sanitary purposes. The silos have drying operations and dryers use wood from planted forests, which is purchased from authorized vendors with Brazilian permits for commercialization of wood. Total annual use of wood is near 67,000 m3 per year for all the operations. Electricity is used to force air into the silos to maintain the optimal temperature to ensure the integrity of the grains and for lighting purposes in all the facilities. Belagricola is innovating in testing/using new technologies to be more efficient in the use of energy.



-Air Emissions: Main source of air emissions are from grain dryers (point source) and fugitive (non-point) emissions from grains unloading and grading operations. Grain dryers use wood as a fuel; power capacity is below 1 MWth which is out of the scope of WBG/IFC General EHS guideline requirements. However, Belagricola is required to monitor air emissions according to Brazilian regulatory requirement CONAMA 382/06. Going forward, as set forth in ESAP, Belagricola will monitor all grain dryer’s emissions on an annual basis in compliance with Brazilian requirements.

-Hazardous materials: Belagricola stores and transports fertilizers and agrochemicals in compliance with local and international regulations. All products are approved by the local authorities (e.g. ANVISA) and have the Brazilian permits required to import and distribute the products. Agrochemicals in Brazil have restrictions on trade and public access. Its sales require a prescription by an accredited agronomist, and Belagricola relies on a team of specialists that visit the fields and provide technical recommendations and prescriptions. All agrochemicals sales are based on prescriptions from accredited agronomist, either from Belagricola team or from the farmer advisor. In addition, technical, environmental and safety information are provided in the leaflet from the products (Bula, in Portuguese) which are regulated and approved by local authorities.

Belagricola has a number of 55 warehouses and some inconsistencies on the safety conditions were found during the visit. Going forward, as described in PS1 section, Belagricola will conduct a safety assessment of all pesticides warehouses to meet Brazilian safety standards (NBR 9843 – Agrotóxicos e Afins: Armazenamento, Movimentação e Gerenciamento em Armazéns, Depósitos e Laboratórios; NR6 – Equipamento de Proteção Individual EPI; NR 23 – Proteção Contra Incêndio).

-Solid Waste Management: The main source of solid wastes from Belagricola operations is dust associated with the storage of grains. As noted above, Belagrícola collects this dust; it is delivered to a centralized facility in Cambé PR where it is processed into b
ricks (briquetes, in Portuguese) for use in dryers.

In Brazil, chemical retailers are required to have means and channels to collect and provide proper treatment, recycle or disposal of used chemical (and pesticides) containers. As a result, industry associations have put together a reversed logistic system for the containers with regional collection hubs and recycling facilities, making Brazil one of the leaders regarding collecting and treatment of empty containers. It is estimated that 95% of the containers are collected under this program. There is a traceability system and national database supporting the program and farmers can only buy new products for next season if they have delivered the same amount of empty containers compared to what they have bought last year.

- Greenhouse Gas Emissions: The main source of GHG emissions is associated with the use of energy from the grid used in moving grains and silo ventilation. Estimated emissions are 2.5 tCO2eq. As described above in the energy efficiency section, Belagricola has several initiatives to control the use of energy, and reduce GHG emissions including the use of biomass (planted wood), storage wastes (soy dust) and wood chips. All renewable sources of energy. In addition, Belagricola has in place an energy efficiency program to reduce and optimize its use.

-Pesticide Use and Management: Belagricola does not directly apply pesticides. Technical assistance is provided to customers by qualified professionals and include proper guidance in the use and application of such products. In addition, clients usually have their own agronomists to advise them in the right use of products. Elements such as registration, labeling, packaging, and storage were observed in accordance to international codes. In Brazil, the production, trade and use of pesticides is regulated in accordance with the Food and Agriculture Organization’s International Code of Conduct on the distribution and Use of Pesticides. As such, and as described above in PS1 section, access to pesticide is very restricted and can only be sold under proper technical prescription from accredited agronomist and used following safety and environmental recommendations. Belagricola follows and promotes the trends and benefits of Integrated Pest Management and is increasing the use of seeds with pest resistance characteristic, and also has been proactive on prescribing less hazardous pesticides when available and technically feasible.

Belagricola relies on a team of specialists that use and disseminate best practices in pest monitoring on fields and follow technically sound thresholds to prevent economically significant pest damage. Belagricola specialists have a tight schedule of field visits and support their clients on pest monitoring, helping them make decisions regarding timing of application of products for pest control. The majority of Paraná State grain production is based on small farm production, which facilitates the pest mon
itoring activities, and IPM control programs are very well disseminated.

After verifying the list of agrochemicals that Belagricola trades, tree (3) products under six (6) different trademarks were identified falling into hazard class Ia and Ib (according to WHO Classification). Going forward, as set forth in ESAP, Belagricola will define a timeframe for phasing out these products based on a feasibility technical assessment and considering the need for specific pests/diseases/weeds, availability of less hazardous products or existence of genetically resistant crop verities.

By default, Belagrícola grain silos and warehouses are located outside urban areas, near main local access roads, in mixed industrial and rural areas. As such, only a small number of neighbors can be found living in close proximity to these sites. Grain truck traffic, noise and fugitive emissions from silos can potentially cause nuisance or negatively impact the neighborhood. Going Forward, and as part of EHS assessment of the silos described in PS1 section, Belagricola will assess existing dust control systems and explore means of improvements (not only for better fugitive emissions control, but mainly for better L&F safety).

-Emergency Preparedness and Response: Belagrícola has a standard emergency plan for silos and warehouses. Training has been provided to the employees in the different distribution centers. All drivers of hazardous chemical are trained on management of emergencies and phone numbers are available to report events. Going forward, Belagrícola will develop individual and site specific emergency plans taking into consideration site characteristics, risks and nearby community. Belagricola will also conduct periodic fire drills, including those that may involve hazardous materials, as part of its overall emergency preparedness.

-Security Personnel: Belagrícola contracts security guards through recognized local security companies and the guards can be armed in some places. The security companies train the employees to guarantee adequate use of the arms and follow up of the procedures. There have not been complaints or reports regarding abusive behavior or improper use of the arms; the Company’s guidance is to avoid the use of force and instead to call for support from police, if necessary. Going forward, Belagricola will elaborate a formal guide of conduct for security personnel, defining right ways to respond to threats and when and how the use of fire gun is allowed.

Belagricola has a Social Responsibility program and contributes with annual donations for social projects in local poor communities in Paraná. Belagricola has a toll free phone number and email for anyone interested in lodging complains. Once received, complains are recorded in a system and delivered for the appropriate department/sector of the company for analysis and feedback.
http://www.belagricola.com.br/fale-conosco

Rua João Huss, 74
Gleba Palhano
CEP 86050-490
Londrina - Paraná - Brasil
Fone: +55(43)3377-8500

Broad Community Support is not applicable for this project

Belagricola(34883) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Social and Environmental Management Program: -Belagricola will conduct an EHS assessment on all Silos to meet Brazilian regulatory requirements such as OHS standards (known as NRs – Normas Regulamentadoras do Ministério do Trabalho), as well as to meet newly issued Life Authority standard for Grain Silos (Instrução Técnica do corpo de Bombeiros) from São Paulo and Parana States. The Assessment must also identify the need of better dust controll systems to mitigate fujitive emissions to nearby householders.	31-Dec-2016	Completed	Completed	3/31/2019
Belagricola will conduct a safety assessment of all pesticides warehouses to meet Brazilian safety standards (NBR 9843 – Agrotóxicos e Afins: rmazenamento, Movimentação e Gerenciamento em Armazéns, Depósitos e Laboratórios; NR6 – Equipamento de Proteção Individual EPI; NR 23 – Proteção Contra Incêndio)	30-Nov-2016	Completed	Completed	3/31/2019
Belagricola will develop the mandatory Respiratory Protection Program (PPR – Programa de Proteção Respiratória) and Hearing Protection Program (PCA – Programa de Concervação Auditiva) consistent with local regulatory requirements.	30-Jul-2016	Completed	Completed	3/31/2019
Organizational Capacity and Training -Belagrícola will hire an experienced EHS manager to consolidate OHS and Environmental management functions under one same EHS/Sustainability structure and will be responsible to coordinate all EHS aspects of Belagricola’s operations. This professional will be responsible for implementing an EHS management system covering all regulatory requirements, appropriate organizational capacity and accountability, training, definition of key performance indicators, monitoring and auditing, and finally reporting unit’s performance internally to senior management.	30-Jan-2016	Completed	Completed	3/31/2019
Belagricola will develop a specific training program for unit managers to better support EHS unit’s objectives and goals.	30-Jan-2016	Completed	Completed	3/31/2019
Monitoring and Reporting: Bleagricola will review and consolidate its Monitoring practices defining appropriate KPIs to measure performance from all sites (such as accident frequency and severity rates, performed vs. required trainings, number of audit findings, energy and wood consumption, number of unsolved regulatory gaps, solid wastes volumes and disposal, complains lodged into its grievance mechanism, and so forth)	30-Jan-2016	Completed	Completed	3/31/2019
#NAME?	30-Jan-2016	In progress	Under discussion with IFC Client
Air Emissions -Belagricola will monitor all grain dryer’s emissions on an annual basis meeting brazilian mandatory environmental requirements.	30-Dec-2016	Completed	Completed	3/31/2019
Pesticide Use and Management -Belagricola will define a timeframe for phasing out class Ia and Ib pesticides (according to WHO classification), based on a feasibility technical assessment and considering the need for specific pests/diseases/weeds, availability of less hazardous products or existence of genetically resistant crop verities	30-Dec-2015	Completed	Completed	3/31/2019
Emergency Plans: -Belagrícola will develop individual and site specific emergency plans taking into consideration site characteristics, risks and nearby community.	30-Dec-2016	Completed	Completed	3/31/2019
Security Personnel -Belagricla will elaborate a formal guide of conduct for Security Personnel, defining right ways to respond to threats and when and how the Use of fire gun is allowed.	30-Dec-2015	Completed	Completed	3/31/2019