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
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS 7 “Indigenous Peoples”, and PS 8 “Cultural Heritage” are not expected to be applicable to this project, as there are no loss of biodiversity anticipated, nor direct impacts to Indigenous Peoples, nor any identified impacts on cultural heritage sites.

The Project is categorized as B according to IFC’s Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.
B-Port will operate within an area of a large existing private port development (within the South Port Terminal of Port Açu) and will benefit from existing established infrastructure. The key environmental, social, health and safety risks and issues associated with this proposed investment include: the Company’s capacity to properly manage Terminal operations for offshore oil services vessels, including how environmental and social consequences are incorporated into B-Port’s management practices and systems; stakeholder engagement; fuels/hazardous materials storage and handling; emergency response planning and preparedness; labor and working conditions, including employee health and safety, management of hazardous wastes from vessels maintenance; and E&S management during construction.

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. To address Risks and Impacts from this Port development in Brazil, the client is committed in implementing an Environmental and Social Management system based on international management standards, ensuring construction contractors are following Brazilian environmental, OHS and Labor legal requirements and consistent with international best practices.

Environmental and Social Assessment – ECO operates its business in Brazil seeking compliance with E&S legal requirements and Brazilian mandatory E&S standards. In the United States (the Sponsor’s headquarters), ECO’s operations are managed under an Integrated Management System (IMS) covering Quality Assurance, Environment and Occupational Health and Safety (OHS) and following internationally recognized standards (ISO 9000, ISO 14000 and OHSAS 18000), for which ECO has obtained respective certifications. ECO has E&S and ESMS (Environmental and Social Management System) Policies disclosed on their corporate web page (http://www.chouest.com/hse.html). Going forward, as set forth in the Project ESAP, B-Port will develop and implement a Project-specific E&S management system consistent with ECO’s corporate approach and IFC PS1 requirements. As such, the Company will conduct detailed aspects/impacts and hazards/risk assessments for both construction and operational phases, will make an assessment of all legal requirements and risk prioritization (including those described in project’s EIA and PBA); define an E&S management structure and responsibilities; develop and implement appropriate management programs, including E&S procedures (system and operational procedures), E&S objectives and targets; develop and implement monitoring and reporting programs, including Key Performance Indicators (KPIs), site inspections routines, internal and external audits; develop and implement an E&S reporting program; develop non-compliance treatment and accident investigation procedures; establish stakeholder engagement procedures; and establish appropriate budgeting and senior management performance review.



Identification of Risks and Impacts

Brazilian environmental regulations require the preparation of detailed environmental and social impact assessments (ESIAs) as part of a stepwise environmental licensing process applicable to major industrial activities. The State of Rio de Janeiro Environmental Institute (Instituto Estadual do Ambiente -INEIA) is the entity responsible for reviewing ESIAs prior to issuing Preliminary License (Licença Prévia or LP) and Installation License (Licença de Instalação or LI) required prior to the start of construction activities of any major projects. This is followed by the issuance of an environmental operating license (Licença de Operação or LO) issued after regulatory inspection of the fully constructed project, just before initiation of operations. Prior to issuing the respective environmental license, INEIA is responsible for requesting comments on the ESIA from other public agencies with environmental or social competencies including those agencies responsible for the regulation of agriculture, water resources, public services, and Indigenous Peoples, among others. Input from these public agencies must be considered in INEIA’s decision to issue an environmental license, including any relevant input for inclusion in the term
s and conditions of such license.



An environmental and social impact assessment (ESIA, or EIA in Portuguese) was prepared by Prumo as part of the Brazilian environmental permitting process of the South Port Terminal at Port Açu. The ESIA was prepared by the environmental consultancy CRA, in accordance with the terms of reference issued by INEIA. The ESIA is dated May 26, 2011 and includes a list of proposed environmental, social and health and safety monitoring programs contained in the environmental and social management plans (Plano Básico Ambiental or “PBA”, in Portuguese).



The ESIA presents initial baseline studies for the main environmental and social aspects, including geology, soils, land use, water resources, flora, fauna, marine aquatic fauna, noise, air quality, traffic, cultural resources, and socioeconomic aspects of neighboring municipalities and communities. The socioeconomic baseline information is principally based on secondary data and regional statistics and includes information on demography, economy, main institutions and infrastructure services for some of the nearby municipalities, as well as identification of relevant local communities within the area of influence of the Terminal .



The ESIA documented the assessment of location alternatives for the South Port Terminal which included a series of environmental and social siting criteria, including the following: identification of bays, estuaries and inlets appropriate to the Terminal’s characteristics; proximity of other existing port terminals under development or operation; road access; proximity of industrial hubs; availability of water resources, and energy supply. In addition some specific environmental and social aspects were also considered such as: potential impacts to environmentally protected areas for biodiversity conservation; coastal morphology and related potential of impacts; areas of natural vegetation fragments; land use and land use change patterns; land tenure restructure; local social economic dynamics and also the adherence to local legal land use policies as defined in the municipal land use and development plans (Planos Diretores Municipais, in Portuguese). Through assessment of site conditions, five candidate sites were considered for a more in-depth analysis. The selected site was the one that presented the most favorable environmental conditions and had the potential to cause fewest potential social impacts.



The ESIA also considered potential cumulative impacts, mainly focusing on potential cumulative effects to air quality and water quality from planned developments in Port Açu. The analysis included potential impacts to air quality from the adjacent steel industry, air emissions from ship loading and diffuse emissions sources as iron ore piles and truck traffic.



INEA has issued both LP and LI for the South Terminal Port outlining its general characteristics and defining specific conditions of the licenses that includes the imple
mentation of all management programs (PBA) as defined in the ESIA, implementation of a fauna monitoring program, conditions for native vegetation clearings during construction, threshold limits for noise, water and air emissions, among other requirements.



Based on South Port Terminal Environmental License for Installation Prumo has dredged a 6.5km long, 300m wide 18m deep inland canal that will serve as the basic infrastructure for the future port development in the area. Wastes from dredging operations (mainly sand) are being disposed over port’s ground that will serve as embankment.



Following the agreed licensing strategy with INEIA, all individual developments in the South Port Terminal will have to request respective licenses (installation and operation), supported by the existing South Port Terminal EIA. As such, Prumo had requested a separate installation license (LI) for the Terminal (Base de Apoio, as denominated in the license) within the general South Port Terminal, referenced in the existing EIA and port licenses.



Finally, Prumo transferred the LI of the Terminal to B-Port to develop the Project. From a total of 23 environmental programs designed to mitigate the impacts from South Port Terminal, B-Port will have to implement 8 programs within the area of influence of offshore service operations. As defined in the land leasing agreement, Prumo holds ultimate responsibilities to ensure all management programs and obligations from the whole South Port Terminal operations are met. B-Port will have to request INEIA an update of the existing LI to incorporate the upgraded Project design and capacity as well as additional mitigation measures, if necessary.



Management Program –

As described above, B-Port will develop and implement an ESMS to ensure that all existing management programs approved by INEA will be implemented accordingly, as follows:

Environmental management Program

Management Program for Construction Phase

Risk Management Program

Solid and Liquid Waste Management Programs

Noise Emissions Monitoring and Control Program

Potable water monitoring Program

Environmental Education Program

Local work-force capacity development

Local Supply Chain Development Program

Traffic Safety and Management Program.



In addition, the Company is required to develop and implement specific programs to meet Brazilian OHS legal standards from the Ministry of Labor (Normas Reguladoras de Saúde e Segurança do Ministério do Trabalho or “NRs”, in Portuguese), which also include:

Injury Prevention and Health Monitoring Programs (PPRA and PCMSO, in Portuguese)

Workplace Environment in the Civil Construction industry

Noise exposure monitoring and Rearing Protection Program

Hazardous work (High, Heat work and Confined Spaces)

Heavy Cargo Lifting

Electrical Safety

Ergonomic Program

Chemical Storage and Handling

Machinery Guarding and Protection

Fall Prevention Program



Organization – E&S matters are coordinated at the co
rporate (ECO) level in Brazil by a manager reporting to the administrative director. The Company also has an OHS engineer at the corporate level supporting operations.

At the operational level, B-Port will rely on one E&S technician during the construction phase to supervise the contractors’ work. The contractor will have its own team of E&S professionals coordinated by an E&S leader. During the operational phase, the Company will rely on three OHS technicians coordinated by an E&S leader reporting to an E&S corporate manager overseeing all aspects of ESMS implementation.

Training programs will be defined in a specific ESMS procedure, and organized by the ECO Human Resources department based on mandatory job training requirements (i.e. working at heights, working in confined spaces, forklift, crane and heavy machine operators, etc.) and yearly evaluations of staff training needs. During construction, the Company will verify all mandatory trainings from contractors’ staff before granting access to the site.

Monitoring requirements will be defined in a specific ESMS procedure, covering key environmental, health, safety and social indicators applicable to Project operations and including all monitoring programs defined in the PBA as described above. In addition, OHS monitoring activities will include workplace exposures to noise, vibration, heat and chemical agents consistent with Brazilian regulations. Accident rates will also be monitored and reported to the relevant (social security) authorities. B-Port is required to have a workplace inspection program with periodic field inspections, in which near-misses and major non-compliances are monitored, recorded and corrective actions followed up. The Company will also have a schedule of internal and external ESMS audits. The Company will institute a government required joint health and safety committees (CIPA) with representatives from the workers and management who supervise and report on health and safety issues encountered during work. CIPA committees are also responsible for investigating and analyzing occupational accidents, incidents, and health issues.

Reporting requirements will be defined in a specific ESMS procedure, and results of E&S monitoring activities will be compiled into internal reports that must be reviewed by the Operational Manager and Administrative Director who have ultimate operational responsibilities. As a minimum condition, reporting procedures will include relevant information such as OHS accident rates, number of periodic inspections, key near-miss or major findings, status of corrective actions implementations, progress of management programs implementation, updated KPIs and respective objectives and targets.

- Working Conditions and Management of Worker Relationship:

The Project is expected to require 180 workers during the two years construction period. Once operations commence, the expected total workforce is expected to be about 250 workers.

ECO’s operations in Brazil follow human resources policies that are based on sound procedures and aligned with local labor laws. Brazil is a signatory to numerous international labor conventions and treaties including: the International Labor Organization (ILO) Convention 3 on Maternity protection; (ILO) Convention 138 on minimum age; (ILO) Convention 14 weekly rest; (ILO) Convention 26 on Minimum wage; (ILO) Convention 29 Forced Labor; (ILO) Convention 52 on Annual Leave; (ILO) Convention 96 on Fee-Charging employment agencies; (ILO) Convention 98 Right to Organize and collective bargaining; (ILO) Convention 100 on Equal Remuneration; (ILO) Convention 101 on Discrimination in Respect of Employment and Occupation; the International Covenant on Civil and Political Rights; the American Convention on Human Rights; and the International Covenant on Economic, Social and Cultural Rights.

Although forced and child labor, discrimination and harassment are crimes under Brazilian law, and people are generally aware and discouraged to disrespect these basic values on workplace, as set forth in ESAP for the Project, B-Port will develop a code of conduct for its employees in Brazil with specific provisions enforcing its commitment with the law preventing potential misbehave across staff.

The terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity leave, vacation and holiday, are established by national labor regulations. Although Brazilian workers are generally familiar with the national terms of employment, during the recruiting phase the Company also informs candidates and newly hired workers about the specific terms of their job positions. Additional workers’ benefits include medical assistance, social security, meal and transportation vouchers, among others. - Worker’s 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 Employment and Labor Ministry. There are representatives of Marine and Shipbuilding Worker’s union working as active members of the union within existing ECO operations in Brazil, although not in a large number. 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 ECO supports employees’ rights to freedom of association and collective bargaining in compliance with Brazilian law. Although ECO follows sector collecti
ve bargaining agreements they also negotiate directly with local unions more detailed agreements. They negotiate with the naval industry union directly, which provides a more stable working environment that has resulted in no strikes in the last ten years.

- Grievance Mechanism – ECO’s employees are currently able to lodge complaints internally through the Human Resources department and company management. Grievances can be placed on email or toll free phone line, which allows anonymous grievance reporting. Complaints are sent straight to the sponsor’s family in the United States and investigation is required. Going forward, and as set forth in ESAP and part of ESMS implementation in connection to the Project, B-Port will create and implement a formal Project internal grievance procedure which will allow: (a) any employee grievance by individuals or groups (including anonymous complaints) to be presented verbally or on in writing, without the risk of reprisals; documented and reviewed by Company management and subject to a timetable for formal response and resolution; (b) B-Port will provide appropriate response to all complaints, taking in account labor related confidentiality issues. The Company will make the grievance procedure available to all existing and new employees at the time of hire (as part of its Human Resource Policy or other document). - Protecting the Work Force – ECO complies with legal minimum age of work requirements by requesting valid documentation of age in the employee contracting process. Following a federal mandatory program “Menor Aprendiz” ECO must employ young workers (16 years old) part-time to do non-hazardous work under supervision. The participants must be attending classes at a regular school and minimum performance is required.

- Occupational Health and Safety – Under ESMS implementation, the Company will develop a robust OHS program including 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, the Company will implement programs and requirements applicable to its operations including those related to the identification and monitoring of chemical, physical and biological hazards through a Workplace Environmental Risk Prevention Program (PPRA or Programa de Prevenção de Riscos Ambientais, in Portuguese), use of PPE, emergency preparedness and response, medical surveillance program (PCMSO or Programa de Controle Médico de Saúde Ocupacional, in Portuguese), as well as ergonomic, hear and respiratory protection programs. Specific procedures for hazardous work will also be implemented such as working at heights, working in confined spaces, hot/heat work, heavy cargo transport and lift and so forth.

Contractor management: As set forth in ESAP and part of ESMS implementation described above, the Company will include specific provisions in the
construction contract enforcing compliance with Brazilian OHS standard for construction (Norma Regulamentadora do Ministério do trabalho NR18) as well as the management program for construction phase required by INEA (environmental authority). The Company will assign a full time qualified EHS professional to supervise contractor’s EHS performance during construction, adherence to Brazilian legal requirements as well as World Bank/IFC General EHS guidelines. As a minimum, the Company will develop a periodic work place inspection program, permitting system for hazardous work (confined spaces, working at heights, hot/welding, energized parts, heavy material lifting, trenching and excavation), injury and illness prevention programs (Programa de prevenção de riscos Ambientais-PPRA and Programa de Controle Médico Ocupacional – PCMSO, in Portuguese), environmental noise monitoring and wastes management programs. The Company will also monitor contractor’s accommodations for workers following Brazilian specific standard NR24.

B-Port’s Integrated ESMS (Policy, procedures and programs) will include relevant recommendations to manage the following aspects of their operations consistently with IFC PS3, as described:

Office wastes generated at the Terminal operations (e.g., paper, cardboard, plastic bottles, organic waste, etc.) will be segregated for recycling purposes and non-recycling wastes are disposed at licensed landfills in the region. Records and reports documenting the production and disposal of such waste streams will be maintained by the Company, as defined in the Solid Wastes Management Program.

Hazardous wastes collected from ships and maintenance work (doc waters, used lubricant oil and filters, used hydraulic oil) will be either disposed at licensed controlled landfills (Class I: Hazardous materials) or reprocessed as appropriate. Dangerous hazardous wastes such as lubricant oil and fluorescent lamps must be segregated for recycling, as defined in the Solid Wastes Management Program according to the Company’s license requirements.



Sanitary wastewater will be treated in a compact wastewater treatment facility and storm water will be collected by the plant’s drainage system, which will be deployed with oil and greases traps. After treatment wastewater will be discharged to the sea, as defined in the Wastewater Management Program.



No significant air emissions are expected from the Project and typically some noise emissions can be expected during construction phase as a result of driving piles works. Although the Project will take place within an industrial port terminal and 5 km far from nearest community and on a sparsely populated area, the Company will monitor noise emissions according to its license requirements, as part of a port-wide noise monitoring program.



Resource conservation and efficiency - water will be used for potable water supply for boats as well as boat and floor washing, and on site human consumption. Expected water consumption is 4,100 m3/day and supplied from existing licensed deep wells in the area. Total installed power capacity will be 2500KVA, which means an expected consumption of 15,330 megawatts-hour per year. Energy will be supplied by local power company Aggreko and purchased from the grid.

B-Port’s Integrated ESMS (Policy, procedures and programs) will include relevant recommendations to manage the following aspects of their operations consistently with IFC PS4.

Emergency Preparedness and Response: As required by the Project’s environmental licenses, the Company will develop an emergency plan covering different possible scenarios, such as fires, chemical spills, medical emergency as well as emergency contact numbers and communication procedure, emergency equipment and execution of emergency response procedure. The Company will also form a trained emergency response brigade and conduct annual fire drills. B-Port will implement a fire fighting and prevention project, approved by local fire authority and, after implementation and final inspection, will be granted with applicable fire permit (AVCB – Auto de Vistoria do Corpo de Bombeiros, in Portuguese). The Company must also have an emergency boat deployed with hard/sorbent booms and/or portable skimmer to contain and collect from sea any unintentional environmental spills of oil from ships.

Hazardous Materials: The Company will store significant amounts of fuel to supply boats at the Terminal. Fuel storage tanks will be identified and placed outdoor on naturally ventilated area, with secondary containment, on a sealed floor and with restriction of access. Fuel stations will follow Brazilian safety requirements (as established by the National Agency of Petroleum, Natural Gas and Biofuels, or ANP) and the floor must be sealed, deployed with containment walls, channels and oil box. Electrical systems must be intrinsically safe and no underground fuel storage tanks are expected. Small volumes of chemical substances and lubricating oil will be stored in adequate storage areas at operating facilities. Operators will be trained and emergency drills will be conducted on an annual basis.

B-Port will mainly rely on Prumo’s security and access control schemes for the South Port Terminal as well as a small number of unarmed security staff personnel to protect their facilities and control access of supplies and personnel.

The closest town to the Project is São João da Barra (25km distant from Port Açu) with 30,000 habitants, and largest town in the area of influence of the Project is Campos dos Goytacazes (33km distant from the Terminal) with 434,000 habitants. The closest human settlement is Mato Escuro 5 km distant from Port Açu and with approximately 520 habitants.
As part of licensing process, Prumo has conducted in 2011 two public hearings in the region: one in São João da Barra and another in Campos dos Goytacazes municipalities. Consultation was supported by an executive summary of EIA and a project presentation, including the expected impacts from both construction and operational phase. As a standard requirement in Brazil for large project licensing, local mayors must provide their agreement with the project in a format of a consent letter.
B-Port’s activities (logistics services for offshore oil operations) are expected to have very limited impacts on local communities. Nonetheless, under the ESMS umbrella and as set forth in ESAP, the Company will develop a stakeholder engagement procedure including appropriate provisions to adequately and actively engage with affected communities (e.g. fishermen, nearby settlements affected by truck routes) in accordance with IFC PS1 requirements. Significant impacts to local communities were identified during the overall Port Açu implementation, and these are being mitigated and compensated by Prumo under existing management programs associated to the South Port Terminal EIA (and PBA),
The procedure will include an external grievance mechanism, defining a process of documenting grievances received and, responses provided (such as the name of the individual or organization; the date and nature of the complaint; any follow up actions taken; the final decision on the complaint; how and when relevant project decision was communicated to the complainant; and whether management action has been taken to avoid recurrence of community concerns in the future), and reported back in an appropriate manner to the affected communities periodically. The Company will structure a proper communication channel to which project-related views and concerns of the affected community can be addressed.

Mr. Ricardo Chagas
E-mail: mailto:ricardo.chagas@chouest.com
Tel: +55 21 3970 9150
Fax: +55 21 3970 9179

Broad Community Support is not applicable for this project

ECO Brazil(35464) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Implement an Environmental and Social management System consistent with IFC PS1 requirements and following the most relevant internationally recognized E&S management system standards, such as ISO 14001, and OHSAS 1800 as described in ESRS.	30-Mar-2015	Completed	Completed	12/31/2017
Construction Contractors Managment - The Company will include specific provisions in the construction contract enforcing compliance with Brazilian OHS standard for construction (Norma Regulamentadora do Ministério do Trabalho NR18) as well as the management program for construction phase required by INEA (environmental authority).	30-Mar-2015	Completed	Completed	12/31/2017
The Company will assign a full time qualified EHS professional to supervise the contractor’s EHS performance during construction.	30-Mar-2015	Completed	Completed	12/31/2017
The Company will develop OHS management programs described in ESRS.	30-Mar-2015	Completed	Completed	12/31/2017
The Company will develop a code of conduct for its employees in Brazil with specific provisions enforcing its commitment with the law regarding forced/child labor, harassment and discrimination, as described in ESRS.	30-Mar-2015	Completed	Completed	12/31/2017
ECO will develop a stakeholder engagement procedure including appropriate provisions to adequately and actively engage with affected communities in accordance with IFC PS1 requirements.	30-Jun-2015	Completed	Completed	12/31/2017
ECO will create and implement a formal corporate internal grievance procedure which will allow: (a) any employee grievance by individuals or groups (including anonymous complaints) to be presented verbally or on in writing, without the risk of reprisals; documented and reviewed by company management and subject to a timetable for formal response and resolution; (b) the Company will provide appropriate response to all complaints, taking in account labor related confidentiality issues. The Company will make the grievance procedure available to all staff.	30-Mar-2015	Completed	Completed	12/31/2017