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

The potential adverse Environmental, Health and Safety (EHS) impacts of construction and operation of buildings are limited and can be readily addressed through mitigation measures and, hence, this Project is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The key E&S issues have been identified as: (i) the capacity of Eterica’s E&S management system to manage E&S issues across on-going and future projects including the adoption of necessary mitigation measures; compliance with a Life and Fire Safety (L&FS) requirements; management of labor & working conditions and OHS risks during construction; contractors management; permits; community health, safety and security; pollution control measures during planning and operations, waste management, particularly including construction waste; hazardous materials management. Key environmental and social (E&S) issues and relevant mitigation measures are described in detail in the paragraphs below. In addition, Eterica will implement an Environmental and Social Action Plan (ESAP). The ESAP is focused on priority mitigation measures to achieve compliance with IFC’s PSs.
While all Performance Standards (PS) are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the Performance Standards 1-4. IFC’s due diligence did not identify project issues related to matters covered by PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous People and PS8: Cultural Heritage. The Project does not involve any involuntary resettlement and economic displacement. The land plots are located adjacent to main highways or close to the Minsk outer ring road have been and used mainly as an industrial and agribusiness areas. No issues have been identified in relation to PS6 and PS7 since project sites are located in urban areas of cities and no indigenous people are known to be in the area or affected by the project. Also, this project is not expected to encounter issues covered by PS8 Cultural Heritage as the current and potential project sites do not have any features of historic or cultural value. In the event that issues anticipated by PS 5-8 arise, the Company will engage with IFC to ensure these are adequately addressed.

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 Assessment and Management System, Policy, Identification of Risks and Impacts

Eterica has a well-defined sustainability vision built in the Company’s EHS Policy which defines the E&S principles, objectives and responsibility such as responsible use of water resources, proper waste management, efficient usage of energy.

Eterica performed a comprehensive due diligence for each project site including a review of land plot; legal due diligence; technical studies including geotechnical engineering investigation, infrastructure and electricity survey, life and fire safety assessment of buildings’ design. The Government of Belarus owns all the land plots and distributes them through auction in accordance with Master Plan. Eterica has a well-defined assessment for land acquisition and site development including assessment of topography; proximity to protected areas; radiological investigation; checking of previous use of the site; soil-vegetable condition; access to transportation; and availability of public services etc. Environmental assessment of land plots is carried out by licensed company in accordance with local regulations. Final land allocation for construction is possible only upon obtaining of positive opinion on project’s documentation issued by state regulators. Eterica will be required to provide a copy of the Building Permits for the proposed projects, as per ESAP.

Eterica will carry out all construction work by contractors selected through a public tender process according to local procurement law. The bidding documents used to select the contractors include selection criteria ensuring effective implementation of environmental, health and safety performance by the winning bidder. The contract with winning bidder includes necessary conditions related to HSE compliance with national laws. Eterica will be required to include into contracts an obligation to inform the Company of any significant HSE accidents and events among subcontracted project workers, as per ESAP.

Public consultations for this type of development are not required by local authorities having regard for the limited potential for adverse social and environmental impacts arising from the project.

Management Program, Organization Capacity and Competency: Eterica has developed an Environmental, Health and Safety (EHS) policy and procedures based on policy commitments and long term aims are developed. Eterica has a dedicated Environmental, Health and Safety (EHS) Officer leading the responsibility for environmental licensing and monitoring EHS matters of Eterica’s projects, including construction, operation and maintenance contracts. Eterica has a well-defined process for overall project management and supervision of the project development as well as establishing and developing relationships with contractors/construction, nominated subcontractors, designers, architects and obtaining permits, approvals and licenses from authorities.

Emergency Pr
eparedness and Response: Eterica has an emergency preparedness and response plan applicable to both construction sites and office in case of natural and man-made emergency and security services. Relevant requirements for emergency response are defined in the safety manual and contract for sub-contractors. Construction sites are equipped with extinguishers, first aid kits and communication mechanism in case of emergency.

Monitoring and reporting: Eterica’s project management involves various types of monitoring and reporting including assessments of contractor performance, assessment of safety conditions, and training. Eterica will develop a system in place to monitor and review key performance indicators (KPIs), including statistics on accidents, injuries, near misses, spills / leakages, waste management issues, community complaints on a regular basis, as per ESAP. The external reporting is carried out in accordance with local legal EHS requirements. Internal reporting on EHS issues is provided to the Company management on a regular basis. Reporting to IFC on continuous improvement of E&S performance and the EHS management system will be provided within the context of the Annual Monitoring Reports (AMR).

Ongoing Reporting to Affected Communities: As per the ESAP, Eterica will be required to establish an external communication and grievance mechanism in line with PS requirements and provide a copy of the documented procedure to IFC. Eterica will share information related with the progress of the projects on its website through annual performance reports.

Human Resources Policies and Procedures: Eterica has 78 employees involved with concept design, development of construction, sales & marketing, and in facilities management (security, cleaning, etc). Eterica has developed HR policy and proceudres covering recruitment, payment, vacation, benefits, promotion, etc. All HR regulations are available via Intranet. Disciplinary procedure is a part of the HR practice. Generally, the HR practices implemented by Eterica are consistent with Performance Standard 2 and host country labor laws. The Company will amend its current HR policy to include a formal employee grievance mechanism, specific statements regarding non-discrimination provision, equal opportunities, and disseminate revised version by internally, as per ESAP.

Working Conditions and Terms of Employment: All employees have written contracts. Terms of employment including salary, working time, illness and vacation, safe working conditions, promotion and bonuses, training, social benefits are addressed in the contract with employee. Upon appointment, personnel are provided initial induction that facilitates employee’s familiarization and awareness of responsibilities, disciplinary requirements and rights, conditions of work and induction OHS training.

Workers’ Organizations and Grievance Mechanism:

Belorussian laws stipulate employee rights to form and join trade unions/ professional associations and maintaining a collective agreement between selected worker’s representatives and administration. Eterica’s employees do not belong to workers’ organizations or unions, and there has not been such request among the employees. There was no evidence of discouragement of the development of worker organizations. The management team of Eterica confirmed that they would not prevent employees to organize or participate in workers’ organizations. Eterica regularly conducts an annual survey among their employees on HR issues.

Eterica has an informal grievance mechanism for workers to raise workplace concerns. Employees’ grievances are managed through the direct supervisor and the regional HR manager. As per ESAP, Eterica will develop a documented Grievance procedure for employees to express their grievances and have interests represented.

Protecting the Work Force: According to the local labor code and Company’s Social Responsibility policy, Eterica does not employ children below 18 years of age and is not engaged in any form of business activity that employs forced labor.

Occupational Health and Safety:

Occupational Health and Safety is an issue of concern primarily during the construction phase of the project. To address this risk, Eterica applies its existing E&S and OHS control for contractors obliging to adhere to Belarussian core Labor and OHS laws during the project construction phase. Occupational health and safety rules and other working conditions, in accordance with the IFC PS2 requirements are included in contractor’s agreements. In addit
ion, Eterica established a regular inspection mechanism to ensure compliance of contractors with the contractual requirements.

Contractor’s HSE performance is considered during tender selection process by Eterica. All contractor’s workers received training and are qualified to deal with specific risks of their workplaces. Mitigation measures such as usage of personnel protective equipment, work equipment improvement, training, etc. related with the workplace risks were implemented.

Health and safety conditions are strictly regulated by national legislation. During the last 3 years, the Group had no fatality accidents, which represents creditable performance.

Workers Engaged by Third Parties: Eterica verifies that companies contracted for the construction work are legal entities with licenses issued by the statutory authorities; and has established procedures for managing and monitoring the OHS performance both for contractor’s employees and third party employers. In addition, explicit clauses regarding labor and working conditions, occupational health and safety requirements are included in the contracts with subcontractors. No migrant workers employed directly or by subcontractors.

Resource efficiency: During the construction phase and when the facilities are in use, water is supplied from the municipal networks, electricity is from the city grids and the heating will be provided by boilers with natural gas. Both water and energy (electricity and fuel) consumption are monitored and reported internally. Eterica will provide the figures to IFC through Annual Monitoring Report.

Resource efficiency measures have been considered in the design of the developments such as double glazing for windows, thermal insulation, cross (natural) ventilation, low water–use fixtures, LED lighting systems and blinds for shadowing. In addition, Eterica is also investigating the technical and financial opportunity of installing Energy Efficiency features such as solar collector panels, individual control of heat energy consumption, usage of power saving equipment, which are considered to be implemented on new projects.

Greenhouse Gases (GHG): At the time of appraisal, the combined Greenhouse gas emissions from Eterica office was estimated to 4,608 tons of CO2 equivalent. Eterica will quantify direct and indirect emissions from these facilities on an annual basis in accordance with internationally recognized methodologies and will provide to IFC these figures through Annual Monitoring Report.

Pollution Prevention: Environmental impacts and mitigation measures during construction and operation phases are identified in the Environmental Impact Assessments (EIAs), impacts are mainly related to land preparation, air emissions (heavy equipment, vehicles, generators), noise, dust, sewage from domestic use, and waste management. There is a construction management plan in place to mitigate identified impacts.

Waste and Hazardous Materials Management: Construction wastes are contractually assigned and managed by sub-contractors. For ongoing projects, sub-contractors have a well-defined waste management system including waste segregation, using certified construction materials, washing of vehicles in proper defined site, dust abatement measures. The excavation wastes, hazardous chemical packages, domestic wastes, Solid wastes are sent to municipality landfill area via licensed company. Mercury lamps are separately collected and removed by the licensed company.

Project’s design of buildings is in accordance with national building codes and design standards of Belarus, which covers life&fire protection standards, drainage, waste disposal, conservation of fuel and energy and access for disabled people among others. Local authorities inspect the projects, including fire safety provisions. The projects consider the access to basic services such as electricity and water which are available in the urban area. Other impacts to the community such as noise, air pollution and exposure to industrial activity both during construction and operations are identified in the EIAs and as needed mitigation measures are identified. These impacts to the community will be assessed and monitored to mitigate those impacts and monitoring data for noise and air pollution will be provided to IFC by Annual Monitoring Report.

Eterica implements a proper safety measures on construction area to protect the community, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors. Each construction site has so called “Passport” of the construction site with the Company’s contact information.

Emergency Preparedness and Response: Emergency response in case of natural and man-made emergency and security services in construction phase are provided by the construction contractor as part of the construction management plan. This includes infrastructure, equipment and hazardous material safety for the nearby communities and general public. For the operational phase the operator will have emergency plans in place to respond to various emergency situations.

Life and Fire Safety: Eterica is in compliance with Belarus Fire Code to design, construct and operate buildings by implementing the following L&FS requirements: presence of escape routes; a fire detection/alarm system throughout the entire building; fire-extinguishing and smoke removal system with manual control buttons; fire suppression, hydrants and sprinklers system; and exit signage. The relevant state controlling bodies perform pre- and post-construction inspections to affirm that the buildings’ construction incorporates all elements of the L&FS engineering design and perform regular inspections during operational phase. As per ESAP, Eterica will confirm a compliance with internationally-accepted Life and Fire Safety Code by qualified professional acceptable to IFC to certify that life&fire protection aspects of the building’s design meet IFC''s guidelines. Any remedial measure, if any, needed to bring buildings into compliance with IFC guidelines will be completed within a timeframe agreed with IFC.

Eterica has an informal external grievance mechanism where local communities can raise their concerns and will improve an external communication and grievance mechanism via its website where all interested parties can address their complaints and concerns. Information boards are installed next to the Project’s sites.
After disclosure Eterica will be open for any project related enquiry by local stakeholders and be ready to address any critical concerns raised in relation to the project’s construction or operational phases.

Tatsiana Zhuk
Position: Chief Financial Officer
Address: 223053, Minsk district, village Borovaja,7, Belarus
Phone: +375296160220
Fax: +375 17 2 33 33 33
Email: Zhuk@A-100.ву
http://www.a-100.by; http://www.a-100development.by

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Provide a copy of the Building Construction Permits	10/15/2015
Review contracts with sub-contractors to incorporate an obligation to inform the Company of any significant HSE accidents and events among subcontracted project workers.	11/30/2014
Improve an external communication and grievance mechanism via its website where all interested parties can address their complaints and concerns: to develop a system to record complaints from community near its project sites	11/30/2014
Publish the information related with the progress of the projects on the website through annual performance reports	12/31/2017
Develop a system in place to monitor and review key performance indicators (KPIs), including statistics on accidents, injuries, near misses, spills / leakages, waste management issues on a regular basis	11/30/2014
Amend its current HR policy to include specific statements regarding non-discrimination provision, equal opportunities	11/30/2014
Develop a Grievance procedure for employees to express their grievances	11/30/2014
Confirm a compliance with internationally-accepted Life and Fire Safety Code by qualified professional acceptable to IFC to certify that fire protection aspects of the building’s design meet IFC's guidelines. Any remedial measure, if any, needed to bring buildings into compliance with IFC guidelines will be completed within a timeframe agreed with IFC	11/30/2014
The qualified Life and Fire Safety professional acceptable to IFC shall provide a professional certification affirming that facilities construction faithfully incorporates all elements of the engineering design	12/31/2017