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

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

This is a category B project according to IFC’s Procedure for E&S Review of Projects because a limited number of specific E&S impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards and guidelines.

Key E&S issues and risks associated with this category B Project are: Company''s social, environmental, occupational health and safety management system and performance at corporate level; design plans for the new schools and the use of applicable internationally recognized life and fire safety code for such; emergency preparedness and response planning; efficiency of water and energy use in company''s operations; pollution control; labor and working conditions; management of contractors and suppliers (during construction and operational phases) and land acquisition for the future school campus development.

Maple Leaf’s operations (i.e. residential school campuses) are all located in newly developed urban areas – usually the new economic zones on the outskirts of cities. Therefore, impacts related to PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected for this investment.

The company has presented the information about how the E&S issues and impacts are being addressed, to ensure that the Project complies with the applicable E&S requirements including: the host country laws and regulations; IFC’s Performance Standards; and the relevant World Bank Group (WBG) EHS General Guidelines This information is summarized in the paragraphs that follow.

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 & Social Assessment:



As per Chinese regulations, an Environmental and Social Impact Assessment (ESIA) study is required prior to developing a new campus for residential schools. However, the extent and depth of the study varies from province to province and also depends on the size and scale of the proposed campus. At times, a full-fledged ESIA is required, while in other cases a preliminary environmental review is adequate. Maple Leaf conducts the ESIA study commensurate with its operations, as per the local regulatory requirements, and complies with all the permit conditions, in order to mitigate any E&S impacts identified by the study.



Since all Maple Leaf schools are located in the newly developed economic zones, a separate and comprehensive ESIA is also prepared for the entire economic zone development by the local government authorities. The ESIA studies conducted by Maple Leaf are thus in addition to the larger area ESIAs and focus on specific issues and local impacts associated with its campus.



In addition to ESIAs, Maple Leaf procures necessary approvals and permits for its campus design from the local government’s Planning Committee and the fire authorities.



- Management Systems:



Over the past 20 years, Maple Leaf has developed and demonstrated its expertise in managing residential schools with international curriculum and is recognized for its best practices in China, at par with international standards.



Maple Leaf has centralized its management to efficiently develop and operate multiple schools in different cities. Maple Leaf thus centrally manages the academics, HR, finance and information technology (IT) capabilities across all the campuses. Necessary policies and standard operational procedures (SOPs) are developed for this purpose.



As Maple Leaf has moved towards “asset-light” model, increasingly third parties (especially local governments) are responsible for developing the campuses for new schools. For this purpose, Maple Leaf has developed standardized format of cooperation agreement for developing new schools by third parties. This development agreement specifies the infrastructure requirements (including life and fire safety and waste management) for new schools, in line with local regulatory requirements.

Going forward, Maple Leaf will document its E&S objectives and principles in a form of an overarching EHS / Sustainability policy. The policy will articulate the Company’s commitment to comply with the applicable laws and regulations as well as compliance with IFC Performance Standards.



Moreover, Maple Leaf will review the format of development agreement, and identify any gaps vis-à-vis the requirements of IFC Performance Standards and/or the applicable WBG EHS Guidelines. Company will accordingly amend this template of cooperation agreement for developing all the future schools.



- Organization:



To support the top management team, the company has put in place a team of s
easoned mid-level managers, including headmasters, curriculum chancellors and academic directors.



At corporate level, Maple Leaf has three main divisions reporting to the President, viz.:

Administration,

New Schools Development Committee and

IT/Networking.



Corporate Administration division comprises of Marketing, Physical Resources and School Construction Project Office, General Affairs, Chinese academic program and Canadian (British Columbia or BC) academic program divisions.



For developing new schools, New Schools Development Committee is responsible for determine target schools and location based on market research; decide on the type of cooperation: asset light model vs acquire/ build own schools; finalize the agreements with cooperation partners and establish the operations team for the new schools.



Once the new project is finalized, the Project Office takes over and is responsible for design and construction of schools (either by Maple Leaf itself, or by a partner under asset-light approach). Project Office overseas the tendering for facilities and equipment as well as the construction of the new schools. At the same time, Marketing Team formulates the marketing plan and provides training to Operations Team.



The Operations Team of 6 people (viz. the Headmaster, Academic Director, English Teaching

Director, Admission Director, General Affairs Director and Financial Officer) has the responsibility to apply for licenses, obtain approvals, organize training, execute marketing plan, student admissions and formulate the teaching plan. This team is also responsible for day to day operations of the school. General Affairs Department Head at each school has the responsibility for the day-to-day management of campus infrastructure, who reports to the Headmaster as well as the corporate Administration / General Affairs division.



- Monitoring & Reporting:



Maple Leaf has instituted an internal monitoring system, to ensure the consistency and high quality of education and operations across all its schools and campuses. A set of key performance indicators (KPIs) has been developed which each school is required to monitor regularly and report to corporate office. For instance, daily operational status covers KPIs related to academic performance, social issues such as student quarrels / fights, fire safety, food safety in the cafeteria, emergency preparedness and response, etc. Financial reports are submitted by schools to the Chief Financial Officer on monthly basis, while any issues related to logistics and infrastructure are reported on case by case basis.



An Investigation and Evaluation team, led by the Group Vice President and the Chinese Studies Superintendent from the corporate office, has the responsibility of visiting each school every semester and reviewing the operational performance – with a focus on academics, safety and costs.



- Emergency Preparedness and Response



Maple Leaf places a very high em
phasis on ensuring a safe and secure environment for all its students on its campuses. For this purpose, the Board of Directors together with all the school principals has recently published the “Regulations on Campus Safety”.



This document articulates the rules and regulations for day to day operations as well as the emergency response procedures covering earthquake, fire, social unrest and food safety related emergencies.



Necessary training is provided to the concerned staff and regular drills are conducted, with active involvement from the students. (Further described in Fire Safety section under PS4). Moreover, the company purchases adequate insurance cover for its students, as per the Chinese regulations.



As mentioned earlier, outcomes of these drills are reported to the corporate headquarters on a regular basis, and the same are also audited by the Investigations and Evaluation team during their site inspection every semester.



- Community Engagement:



All Maple Leaf schools and students actively engage with their neighboring communities as part of curricular or co-curricular activities. Various special activities and events are planned by each school as per the local situation. These include, for instance, community service such as cleaning the beaches, visiting senior citizen homes, visits by high school students to local primary / elementary schools as volunteer teachers, volunteering during public events and festivals for traffic safety etc.

As of August 2014, Maple Leaf employs around 2,530 employees. The manpower comprises of around 380 expatriates and about 120 part-time teachers/assistants. Female employees constitute approximately 60 % of the total workforce, across all levels.



- Human Resource Policy, Management



Maple Leaf has developed elaborate documented HR policies and operational procedures for expatriate teaching staff as well as locally hired staff. These are in line with the Chinese labor law requirements and the BC school certification requirements.



The HR Management System Manual documents the corporate level policies and procedures for recruitment, compensation and benefits, leave and attendance, transfers, training, retirement, confidentiality requirements etc.



All employees receive a copy of the Employee Handbook at the time of joining, together with their appointment letter and contract. Separate staff handbooks have been prepared for Chinese and expatriate staff members.



- Training



Maple Leaf has instituted a formal training program for all its teachers and employees. Induction training is provided to all the new recruits at Maple Leaf’s headquarter and Dalian campus, followed by on-the-job training for teachers. In addition, the teachers regularly engage in subject-wise group discussions in teaching contents, and the Chinese teachers regularly participate in the national level teacher training programs organized by government agencies. Similarly specialized trainings are designed for expatriate teachers, which includes among others cross-cultural training for their easy onboarding and integration in the local environment.



Safety training is an integral element of the training calendar at each school. All levels of employees and students participate in safety trainings and drills. Every year, selected security personnel participate in week-long special trainings on fire-fighting and first aid organized by the local fire department.



- Child and Forced Labor



All employees are hired through open recruitments and based on the candidate’s qualification. The minimum age of hiring is 18 in line with China labor law requirement.



Contractors are also required to hire only employees older than 18 year of age, and comply with applicable Chinese labor laws.



- Freedom of Association



Currently, a trade union of Chinese teachers and employees is in place Maple Leaf. There is no association or union for expatriate teachers, though the Company does not restrict employees’ freedom of association.



- Grievance Mechanism



A formal and documented grievance redressal mechanism is available for Company employees to raise any workplace concerns. This includes: anonymous letter drop box on campus; anti-fraud email address circulated across the staff; and email address directly linked to the Chairman’s office – where staff can raise their grievances.



- Occupational Health and Safety



Managing a residential school campus does not pose
significant occupational health and safety risks to its staff and students. Moreover all the Maple Leaf campuses are designed following the BC schools guidelines and are based on the Canadian design style and safety standards.



In addition to specific fire safety related design features described below, school design provides for safe height of stairs appropriate to the age of children, cafeteria design to maximize food safety and electrical installations with high safety standards. Laboratories are well designed to provide for proper storage of chemicals as well as adequate ventilation in case of any fumes or emissions; thereby minimizing any health hazards to the students and staff due to laboratory chemicals.



As mentioned earlier, Maple Leaf’s Board of Directors have issued campus safety regulations, which addresses key occupational health and safety issues such as fire safety and food safety. Company has dedicated staff to oversee the food safety aspects of the food served in its cafeteria, which are managed by external contractors in most cases.



All campuses have on-site clinics or infirmaries staffed by medical doctor and/or trained nurses to take care of any medical issues for the staff and students.



- Labor and Safety Compliance by Contractors



Maple Leaf outsources most of its catering operations and the housekeeping, catering, and gardening services in some campuses to licensed contractors. As 90% of the students live on the campus, Maple Leaf does not provide transportation services. In case of a few day-boarding schools or kindergartens, parent committees collectively organize the transportation directly with a transport service provider and the company does not get involved in the arrangement in any way.



The staff from HR and General Affairs departments oversees the performance of various contractors, including their labor and safety compliance. Special attention is given to cafeteria contractors and their food safety management.



For the development of future schools, Company will develop standard contract clauses for its civil construction contractors, specifying requirements related to compliance with applicable labor laws, living conditions for the construction workers and safety on the construction site. For the new schools being developed under the asset-light model, the company will include these requirements in the revised template for cooperation agreement, being developed as per the ESAP.

- Pollution Prevention and Resource Conservation:



For the development of newer schools, the company is increasingly adopting measures to enhance resource efficiency and minimize the waste generation. For instance, some of the new buildings in Wuhan campus have solar water heating in the dormitories; or in most campuses the company is gradually shifting to energy efficient compact fluorescent lamps (CFL). While many of these changes are driven by the local regulation, the company is actively exploring the ways to enhance its efforts towards higher resource efficiency.



For future, the Company will review the international best practices for developing “green school campus” and include any possible measures in its design specification template for new schools to be developed in future.



- Water, Wastewater and Emissions



Maple Leaf’s operations do not result in significant air emissions, generation of large amounts of solid/hazardous and liquid wastes, noise or other significant risks to the local ambient environment and nearby communities.



Water for the domestic use and gardening is sourced from local government authorities and wastewater is discharged in municipal sewers. Raw water and wastewater quality is regularly monitored as per the local regulatory requirements.



Some campuses have coal/diesel fired boilers for cafeteria, resulting in small quantities of emissions, which are also regularly monitored by a third party agency.



- Energy Sources and GHG Emissions:



Primary energy requirement for the project is that of electricity, which is procured from the national grid. Small capacity diesel generators are installed as backup, for use in the rare case of power failure.



The GHG emissions of the Project are, therefore, dominated by those due to the electricity consumption, diesel consumption and a small contribution from loss of refrigerant from HVAC systems. The project had estimated emissions of 14,700 tons of CO2e.



- Solid Waste Management



The domestic waste generated from the campus is collected and disposed of through the local government waste management services. In accordance with newly introduced requirements, the newer campuses have provided for a solid waste storage room, for proper handling, storage and disposal of the solid waste.



Food waste from cafeteria is disposed by the catering contractor. Much of the food waste is sold to animal farms as feed or else disposed of through local government waste management services. Going forward, Maple Leaf will conduct a feasibility study of on-site composting of the food waste and / or producing biogas from this organic waste.



As part of ESAP, the company will implement a solid waste segregation program across all its campuses by providing separate color-coded bins to segregate household hazardous waste such as used CFL lamps, empty chemical bottles, batteries etc., and dispose of properly through the designated waste handling and management servic
es.

Maple Leaf’s operations (i.e. residential school campuses) are all located in newly developed urban areas – usually the new economic zones on the outskirts of cities - which are well connected with wide road network. Moreover, since all the schools are residential, no significant vehicular traffic is expected during day-to-day operations.



Maple Leaf has its own team of unarmed security guards who are also trained for fire safety and handling other emergencies.



- Infrastructure and Equipment Design and Safety



Maple Leaf designs and develops its campuses in accordance with Chinese national standards, as well as requirements for BC schools, and covers earthquake resistance, fire protection standards, drainage, waste storage and disposal, among others.



An accredited architect or engineer endorses the design, including structural and fire safety aspects, before it is submitted to the local authorities to obtain necessary permits. Local authorities inspect the projects, including fire safety provisions; after ascertaining that the buildings are as per the sanctioned plan, and the project architect/engineer has confirmed completion, an Occupancy Certificate is issued.

During construction measures are implemented to protect the nearby community, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors.



- Life and Fire Safety



Each school has been designed and equipped with adequate firefighting equipment in accordance Chinese fire safety requirements, as well as those for the BC school system. The architectural design of schools and dormitories provide for wide corridors, multiple exits, compartmentation with fire rated doors and fire water storage tanks. The campus does not have high rise buildings and none of the buildings has more than 5 floors. The fire-fighting systems at each school has a combination of smoke detectors, alarms, emergency exit signage, fire hydrants, extinguishers and sprinklers in designated locations, provided as per the local fire safety regulations.



The architectural design and provision of firefighting equipment varies from school to school and is based on specific provincial/local fire safety requirements. Some additional upgrades in the firefighting system were also made as required by the BC certification requirements.



Each school conducts an unannounced / surprise fire safety drill involving all students at least once a semester. All the firefighting equipment is regularly inspected and maintained by the company’s staff or external vendor. Local fire authorities undertake annual fire safety inspection of all the premises.



Going forward, Maple Leaf shall develop standard requirements for fire safety systems design and operation which will build upon the stringent requirements of local fire safety regulations and an internationally recognized fire safety code such as British, Ca
nadian or US National Fire Prevention Association (NFPA) codes.



For all the new campuses being developed under the Project, the company will commission an independent fire safety professional, acceptable to IFC, to review the site specific architectural design specifications and confirm that all the life and fire safety related aspects of design are consistent with local and an internationally recognized fire and life safety code guidelines, as required under the life and fire safety section of the WBG EHS General Guidelines.



Following construction, the fire safety professional shall inspect the newly constructed buildings. Maple Leaf will submit to IFC certifications from this professional that each facility is designed, constructed, and operated in full compliance with local building codes, local fire department regulations, and all life and fire safety aspects of the previously approved Architectural Brief.

As mentioned earlier, the company organizes several activities to engage with the neighboring community. Going forward, as the company gets listed on the Hong Kong Stock Exchange; it will publicly disclose the relevant information to its shareholders and general public through its annual reports as well as its website.

Public disclosure of this ESRS in local language will constitute an important step in the company’s stakeholder engagement activities.

Maple Leaf will disclose this ESRS locally at the following address:

Maple Leaf Educational Park, Jinshitan, Dalian, Liaoning, China 116650

All inquiries and comments may be directed to:

Bin (Ace) Xu
Tel:(+86)411-8790-6897
Fax: (+86) 411-8790-6887
Email: mailto:xubin@mapleleaf.net.cn

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Establish an overarching sustainability policy defining its objectives and principles that will guide the Company to achieve sound EHS performance of the Project – including compliance with the applicable local laws and regulations and the IFC Performance Standards.	03/31/2015
Review the template for development agreement to identify any gaps vis-à-vis the requirements of IFC Performance Standards and/or the applicable WBG EHS Guidelines and amend this template of cooperation agreement for developing all the future schools. The revision of this template will specifically focus on life and fire safety related requirements and aligning with international best practices for “Green campus development” as described in the ESRS.	12/31/2014
Conduct a feasibility study of on-site composting of the food waste and / or producing biogas from this organic waste.	12/31/2014
Develop and implement a solid waste segregation program across all its campuses by providing separate color-coded bins to segregate household hazardous waste such as used CFL lamps, empty chemical bottles, batteries etc., and dispose of properly through the designated waste handling and management services.	03/31/2015
Develop a land acquisition due diligence procedure to ensure that the land acquisition carried out by the government agencies is consistent with the PS5 objectives.	03/31/2015
Commission an independent fire safety professional, acceptable to IFC, to review the site specific architectural design specifications for all the new campuses being developed under the Project, and confirm that all the life and fire safety related aspects of design are consistent with the design specifications	12/31/2017