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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

The key environmental and social issues associated with this project are hazardous waste management, worker health and safety, and potential harmful child labor.

IFC’s appraisal considered Aihuishou’s E&S management policies and procedures and gaps between them and IFC requirements. Where necessary, corrective measures intended to close those gaps, within a reasonable period of time, are summarized in the paragraphs that follow. Through implementation of those measures, the project is expected to be designed and operated in accordance with Performance Standard objectives.

As there are no major adverse environmental or social impacts expected to result from the proposed project, and it is possible to avoid or mitigate any limited adverse impacts that might result, the proposed investment has been classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects.

PS3 isn’t expected to be applicable because potential pollution prevention will arise among Aihuishou’s recycling partners, and will be managed through their relationships with Aihuishou. PS4, PS5, PS6, PS7, and PS8 aren’t expected to be applicable because sites in China for recycling are well-developed.

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.

Aihuishou wipes all personal data from the electronic devices that it collects. Then, Aihuishou redistributes electronic devices to its recycling partners, which repair, refurbish and resell about 70% of those devices. The remaining amount, about 30%, which aren’t reused, are sent to Aihuishou’s recycling partners to be dismantled and processed in order to recover valuable materials. Such dismantlement and processing involves the most E&S risk, as some recyclers may improperly melt the devices or otherwise improperly dispose of hazardous materials resulting from dismantlement. There are also risks of safety issues for workers, and potential harmful child labor in employment, among both Aihuishou’s distributors and its recycling partners, and among smaller operations to which they may subcontract.



At present, Aihuishou requires its recycling partners to possess a license for processing waste; take precautions against any possible environmental pollution; maintain clear and clean workplaces; and ensure safety in decomposing and recycling waste. Under IFC’s investment, Aihuishou’s recycling partners will also be required to develop and implement a documented E&S management system tailored to the risk of their operations. Aihuishou’s recycling partners will be required not to allow any hazardous or contaminated electronic waste to enter any non-hazardous solid waste landfill, and to ensure that their own operations and any smaller operations to which they may subcontract will not use any harmful child labor.



More generally, Aihuishou’s E&S management is committed to comply with national laws, rules, and regulations, and Aihuishou includes E&S terms in agreements with recyclers. However, it has no formal, documented E&S policies and procedures consistent with IFC Performance Standards, which it will be required to develop under IFC’s investment.



Aihuishou’s new E&S policies and procedures will include a screening process to assess the nature and scope of E&S risks and impacts in the operations of each new potential distributor or recycling partner of Aihuishou. Aihuishou’s new policies and procedures will provide for improved E&S terms to be included in agreements with both existing and new distributor or recycling partners as soon as reasonably possible, in compliance with IFC Performance Standards and IFC’s EHS Guidelines for Waste Management Facilities. Aihuishou will also develop and implement new policies and procedures to monitor compliance with those terms.



Aihuishou’s new E&S policies and procedures will provide for a periodic review by Aihuishou of E&S performance by its distributors and recycling patners, at which time potential gaps or opportunities for improvement will be explored, and Aihuishou will advise any distributor or recycling partner who should take remedial measures to do so. If remedial measures by any distributor or recycling partner are unlikely to yield compliance with IFC Performance Standards,
then Aihuishou will terminate its contract with that distributor or recycling partner.



Aihuishou will keep records of any E&S incidents in its own operations and through the chain of custody for the devices that it collects, and will promptly report any such incidents as appropriate. Aihuishou will identify at least one Aihuishou officer to be responsible for E&S management, and to ensure that there is a feedback loop for continuous improvement in E&S management.

Aihuishou has 107 employees (staff and management), all directly employed. 83 are full-time and 24 are part-time. Aihuishou’s human resources (HR) management is committed to comply with national laws, rules, and regulations. However, it has no formal, documented HR policies and procedures, which it will be required to develop and implement under IFC’s investment.



Aihuishou’s HR policies and procedures will provide for appropriate management of health and safety issues, non-discrimination in recruitment and during employment, a grievance mechanism to address concerns of any Aihuishou worker, and screening and monitoring of labor and working conditions among Aihuishou’s recyclers, all in compliance with IFC Performance Standards.

The company does not have any directly affected communities, due to the nature of its business. Aihuishou communicates with the public primarily through its efforts to raise awareness of the environmental benefits resulting from recycling electronic devices. Aihuishou will establish and maintain a simple procedure for external communications that includes methods to receive and register external communications from the public; assess the issues raised; and provide and track responses.

Wenjun Sun
Level 19
Hudong Finance Building
1128 Xiangyin Road,
YangPu District,
Shanghai 200433, P.R. China

Broad Community Support is not applicable for this project

ESIP Aihuishou(35160) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Aihuishou will appoint at least one qualified person at its headquarters to be an environmental and social (“E&S”) coordinator	15-Jun-2014	Completed	Completed	6/19/2014
Aihuishou will develop documented E&S policies/procedures that provide for the following, all according to IFC Performance Standard 1 and IFC’s EHS Guidelines: (a) Aihuishou’s recycling partners will be required to develop and implement a documented E&S management system tailored to the risk of their operations, and also required not to allow any hazardous or contaminated electronic waste to enter any non-hazardous solid waste landfill, and to ensure that their own operations and any smaller operations to which they may subcontract will not use any harmful child labor; (b) a screening process will be developed and implemented to assess the nature and scope of E&S risks and impacts in the operations of each new potential distributor or recycling partner; (c) improved E&S terms will be included in agreements with both existing and new distributor or recycling partners as soon as reasonably possible, and Aihuishou will have policies/procedures for monitoring compliance with those terms; (d) a periodic review will be performed of E&S performance among distributors and recycling partners, at which time potential gaps or opportunities for improvement will be explored, and Aihuishou will advise any distributor or recycling partner who should take remedial measures to do so, and will terminate contracts for those who don’t comply or who are unlikely to comply; (e) records will be kept of any E&S incidents in Aihuishou’s own operations and through the chain of custody for the devices that it collects, and any significant incidents will be reported promptly to IFC; and (e) a simple procedure will provide for registering external communications from the public, assessing issues raised, and providing and tracking responses.	30-Jun-2014	Completed	Completed	7/24/2014
Aihuishou will develop documented HR policies and procedures to provide for, according to IFC Performance Standard 2, the appropriate management of health and safety issues; non-discrimination in recruitment and during employment; a grievance mechanism to address concerns of any Aihuishou worker; and screening and monitoring of labor and working conditions among Aihuishou’s recyclers.	30-Jun-2014	Completed	Completed	7/24/2014