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.

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
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

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

This investment is classified as a Category B project in accordance with IFC’s Policy on Environment and Social Sustainability. Based on information reviewed by IFC, the proposed Project will have limited adverse environmental and social (E&S) impacts that are few in number, site specific, largely reversible and readily addressed through mitigation measures, as outlined in the Environmental and Social Action Plan (ESAP) attached to this Environmental and Social Review Summary document (ESRS).
Issues relevant to PS 6 are limited to the company’s management of living natural resources in a sustainable manner, through the application of industry-specific good management practices (e.g. those relevant to floriculture) and available technologies; as such the expectation is that the company will be certified to globally, regionally, or nationally recognized standards. Applicability to the other requirements of PS 6 was not identified during IFC’s appraisal. Whereas the greenhouses are located close to Lake Ziway (which is itself considered a Key Biodiversity Area (KBA) and an Important Bird Area (IBA)). Interactions with these areas are limited to extraction of lake water for irrigation (see below for a detailed description of the size and nature of such extractions). Effluents, which could impact water quality in the lake, are being treated and re-used within the greenhouses thereby removing this interface between the Group’s operations and the lake (see below for details on effluent management). PS 7 is not relevant as there are no IPs in the areas where the Group’s operations are located and while PS 8 is not applicable as land used for building the greenhouses and packing plants was previously used for agricultural purposes and was/is devoid of cultural heritage

The main E&S risks and issues are related to the following: use of water to irrigate the roses (and therefore the need to ensure that water use is minimized) effluent management (and the need to avoid releasing effluents loaded with nutrients and/or pesticide); labor and working conditions, economic resettlement (and the need to ensure the economic displacement associated with the expansion project is properly managed – while respecting the role of the provincial authority that was responsible for the process); and, also to ensure the appropriate conduct of the large force of security personnel engaged by the company.

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.

Policy, Environmental and Social Risks and Impacts Assessment and Management System

Policies: In summary, Afriflora has described its commitment to manage environmental and social risks and impacts of their current operations and expansion areas in a series of policy statements related to the environment, labor and working conditions and some aspects of community engagement. Some areas for improvement include: (i) social assessment for new expansion areas, (ii) establishment of management programs for impact generated by land acquisition, (iii) monitoring and reporting on environmental, health and safety & social key performance indicators, (iv) disclosure of information, and (v) establishment of grievance mechanisms. As part of this investment, the company will formalize all current policies to address environmental & social risks and impacts and finalize the implementation of an Environmental and social management system (ESMS) which meets the requirements of PS 1. Key performance indicators to monitor implementation and performance of environmental & social aspects will be developed and included in the Annual Monitoring Report to IFC.

Afriflora has developed several processes and programs related to both assessment and management of environmental and social risks and impacts as typically found in large rose growing operations. These elements are combined into a systems approach in most areas and help the Group drive good E&S performance. The Group has assigned resources to operationalize these systems, utilizing competent employees to implement such programs and maintaining documents and records as necessary. Underpinning much of this assessment and management activity are a variety of sector specific certifications and their associated criteria; for example, Afriflora is certified against the FairTrade, Ethical Trading Initiative (ETI), GlobalGAP and MPS (Dutch flower certification) systems in order to meet market and buyers’ requirements while managing on-the-ground E&S risks and impacts. These standards pertain to matters including but not limited to resource use, labor management, and chemicals management. In addition, the Group complies with national environmental law and regulation by commissioning environmental impact assessments (EIAs) using licensed Ethiopian-based consultants.

Afriflora has a committed senior management team, which is updating and adopting relevant E&S policies in line with its business needs. Senior management has also sent a clear message, to all employees at all levels, that E&S aspects are a Group commitment towards its customers and the surrounding community. Management is working to further increase capacity at supervisor level to ensure clear outcomes, reporting lines, and allocation of appropriate resources for the appropriate management of environment, health and safety, social and human resources aspects.

Management Programs: Afriflora has detailed action plans developed to avoid and minimize E&S risk
s and impacts identified under the multiple schemes to which they are certified. Although, these certification schemes cover a broad range of E&S aspects, they do not address all the requirements under the Performance Standards. The Group has initiated and will continue to develop a proactive approach to managing E&S risks and impacts developing specific actions/activities to mitigate impacts. These are addressed in the ESAP.

Training: Afriflora has a recently established framework to determine training and capacity building for all its operations. This approach is based on the: (i) identification of training needs for the Group’s personnel (farm, grading, cold chain operations, supervisor and management level); (ii) development of annual training plans to address identified gaps; and (iii) documentation of the training received. The Group needs to continue strengthening their capacity building efforts for employees especially in areas pertaining to OHS, terms of employment, and grievance mechanisms which will be achieved through a PS 1 compliant ESMS.

Part of that commitment relates to the promotion of individuals to positions of responsibility with respect to assessment and management of E&S risks and impacts. For example, individuals chosen for such duty receive training tailored to such appointments. IFC reviewed the records of such a worker who had been selected for the position of Safety and Environmental Office.

External communication and Grievance Mechanism

Afriflora currently does not have a systematic approach to external communications with communities or the general public which is managed on an ad-hoc basis. In addition, there is no formal mechanism to accept and act upon community grievances. Afriflora will implement an external communication procedure and an effective community grievance mechanism to assess, address, document, and report back on grievances and concerns about the company’s environmental and social performance.

Working Conditions and Management of Worker Relationship

The local labor market is characterized by high levels of young workers and heavy dependence on agriculture. The flower growing industry itself is estimated to employ over 50,000 workers, 70% of whom are women. The main law governing labor standards is the 2003 Labor Proclamation (amended 2006), which addresses all aspects of employment relations, including unacceptable forms of work, occupational health and safety (OHS), freedom of association and working conditions. Its coverage is limited to workers with contracts of employment. There are gaps in the legislation framework in relation to some of the aspects covered under PS2, including those related to grievance mechanisms, forced labor, OHS, and third party workers. The key labor risks for the sector include low wages, informal employment, limited collective bargaining, gender based issues and harassment, and occupational health and safety.

Workforce: Afriflora is the biggest private employer in the Ziway area and provides adequate labor and working conditions for its workers. Such a conclusion was reached by reviewing conditions at the farms and conducting interviews with workers themselves. Further, the multiple certification schemes referenced above include labor and working conditions aspects and audit reports associated with these schemes indicate good compliance on the part of the company.

As of December 2014, Afriflora had 7,860 workers for their operations in Ziway, 660 in Blen farm and 550 in the expansion project in Adamitulu. Average staff turnover rate is 10% per annum. Female workers constitute 80-85% of the workforce distributed in 3 different operation areas: 60% for farm activities, 35% for grading, and 5% for administrative and other activities. In addition, Afriflora employs third-party workers at its sites in non-core functions related to security services for the farms (160 guards), waste removal (10 workers) and greenhouse building operations (75 workers). The Group does not hire day laborers.

Human Resources procedures and structure: The Group has a three-tiered Human Resources structure with the Department Head managing security and human resources aspects. There are 12 HR Coordinators at the farms (Ziway (10), Adamitulu (1), and Blen Farm (1)), reporting to the HR Head. In addition 2 Greenhouses have one HR coordinator assistant and one HR Officer covering approximately 750 workers. The HR function is part of the management team at all operations and has documented procedures for hiring, selection, age verification, disciplinary practices and termination, terms of employment (wages, benefits, working hours, overtime, rest days, breaks, and leave), and for combating discrimination, and sexual harassment. Working conditions and terms of employment are specified in the written contracts signed by employees, provided and communicated to employees during induction.

Working conditions and terms of employment: Af
riflora seeks to recruit, maintain and motivate its workforce by offering performance based bonuses, excellent benefits and a positive working environment. The Group complies with all national legislation limits related to working days per week, rest days and leave. There is no statutory minimum wage in Ethiopia and wages in the floriculture industry are low. The minimum salary paid by the Group, including overtime and bonuses, is 785 ETB ($38.5) per month, approximately $1.70 per day, for harvesting operations and 1,500 ETB ($74) per month for supervisors. Based on the information for the sector and the region, the Group pays above the average minimum salary which is around $0.80 per day. In addition the Group provides performance based bonuses in all operations and employees have free access to health care plan, dental services, pharmacy discounts, pension and education for their children. The average expenditure on health care and education is equivalent to approximately 1,600 ETB per month ($78 per month) per worker.

Normal working hours begin at 07:00 and last until 17:00 and do not exceed 48 hours a week and 12 hours overtime a week. However, national limits only allow for 20 hours overtime per month which the Group is exceeding. Given that overtime compensation is part of the overall salary expected by employees and as highlighted in the certification audits, the Group is in discussions with the relevant authority to find a positive solution for all parties and will be aligned with legal requirements by 2017 through consultation with the company unions and other worker representative while maintaining workers overall payment level equal. The Group also provides access to drinking water and sanitary facilities in all greenhouses. Adequate places to eat, e.g. cantine, and rest areas (e.g. for lactation, pumping) are not currently provided. Afriflora will improve its communication on terms of employment, including clearly salary calculation methods, including bonuses, overtime, leave and wage deductions applied.

Workers’ Organization: National legislation provides the right to organize and bargain collectively and at Afriflora approximately 80% of the workers are unionized under one union. In general, the Group reports positive relations with the two union representatives who are elected every three years; the new election is scheduled for March 2015. HR management has weekly meetings with the union committee to discuss action items and emerging issues. This committee includes 7 members, two of them are women. All action items are captured in summary minutes and one of the key functions of the union representatives is to verbally communicate to employees the working conditions and terms of employment specified under the collective bargaining agreement signed in 2010. The Group has no grievances or lawsuits pending due to labor issues. Since September 2014, the Group has established a Gender Committee with the task to empower female work
ers to access more skilled jobs, develop projects which will benefit the larger workforce and address any gender based harassment. In addition, the Gender Committee has working groups to discuss with the company means to address issues of immediate concern including: (i) establishing an adequate eating area, and if possible providing meals for lunch; and (ii) establishing resting and lactation areas, which might include nursing facilities for infants.

Non-Discrimination and Equal Opportunity: Afriflora has a non-discrimination policy and is working with a local NGO to empower female workers to access better remunerated positions. Pregnancy testing prior to employment will be discontinued and only done as part of the yearly medical check-ups. The Group has a policy statement of zero tolerance of sexual harassment and one recent documented case which resulted in dismissal of the perpetrator. The Group encourages its employees to denounce any violation of this policy through the grievance mechanism or the gender committee. The Group is currently systematizing its approach to this issue and developing a monitoring system to ensure cases are reported, addressed and mitigation measures monitored. Given the large female worker base, Afriflora will work with a third party to develop activities to improve and continue addressing gender specific issues, including sexual harassment, maternity health and protection at work.

Grievance Mechanism: The Group does not have a formal grievance mechanism for worker complaints and will establish one to ensure all types of worker grievances are captured, recorded, communicated and monitored, with records maintained on actions taken and feedback provided on each grievance.

Protecting the Workforce: The Group has implemented an age verification procedure in the hiring process and specifies the minimum hiring age to be 18 years and 20 years for chemical handling activities.

Workers Engaged by Third Parties: As of November 2014, Afriflora had three main contractors on site covering around 265 workers. These third-party workers are engaged in routine, non-core functions related to the Group’s operations such as site security, waste recollection and greenhouse construction. Afriflora has signed contracts with these contractors specifying all relevant national legislation and regulations on labor standards. Afriflora will further strengthen its monitoring system for third-party performance ensuring all contractors’ worker payments and other labor and OHS requirements are in conformity. In addition, the Group will expand the scope of its grievance mechanism to allow third-party workers to have a channel to raise issues or complaints directly to the Group. This is addressed in the ESAP.

Occupational Health and Safety

Afriflora manages OHS risks and impacts by covering the OHS aspects under the certification schemes and performing risk assessments at all operations. Afriflora has established a coherent OHS policy,
which includes issues relating to the proper handling of pesticides and chemicals, and has set up a Health and Safety Committee with both management and workers representatives on board. The main role of the OHS Committee is to review and improve the OHS performance at all farms. As part of the farm management structure, each greenhouse has 1 OHS officer and a trained first-aid staff. Access to drinking water and clean toilets are provided by the Group. Afriflora has implemented an Integrated Pest Management system in order to reduce its use of pesticides and chemicals. OHS procedures have been developed to address the main OHS risks and impacts and the Group is strengthening its implementation across all operations. Personal protective equipment (PPE) is provided to all employees but its usage needs to be enhanced (such as always using gloves while picking roses). Main injuries at the greenhouses are small cuts and thorn prick injuries. Given the nature of these injuries, tetanus vaccination is part of the health screening process. There is limited and inconsistent data on OHS accidents and injuries, and monitoring of OHS, clear communication to employees and carrying out refresher courses are important actions the Group will perform to ensure compliance and improve performance. Given the high percentage of female employees, in collaboration with the gender committee the Group will continue to strengthen their activities to address gender-specific health concerns.

Resource Efficiency

Water use for irrigation is bound by the following regulation Article 11 of the Ethiopian Water Resources Management Proclamation (197/2000). The Group has obtained the necessary permit (latest dated May 2014) for irrigation water from the Ministry of Water, Irrigation and Energy; potable water is supplied by the Ziway town water supply system.) The Ministry is currently assessing the renewal of the water permit to include the extension site, based upon a submitted ESIA

The Group has addressed consumption and effluent management in a near closed-loop system that has been designed to treat and re-use wastewater so as to reduce the need for raw water abstraction (make up water) from Lake Ziway. Currently, the existing farm consumes approximately 5.5l/m2/day; this equates to a total use of 5.37 million m3/yr. Use of a small scale pilot program to treat effluent (using a reed bed/activated carbon filtration system or constructed wetland) and returning it to the fertigation system for use in irrigating the roses has reduced this amount by 5%. Full roll out of this technology, which the Group will do by 2017, is expected to reduce overall consumption to a level of 4.1l/m2/day, equating to 4.02 million m3/yr. This treatment and recycling technology will also be used in the expansion farm; the completion of such installation will be required by IFC in the investment agreement. In addition to this initiative, the Group is installing recirculation pumps into the rainwater drainage channels (found between and at the end of the greenhouses) so as to collect and use rainwater during the wet season. Whereas this approach has yet to be fully quantified regarding its impact upon abstractions, it is expected to have a further 10-20% reduction on the amount of ‘make-up’ water that will be required to be taken from the lake.

The expansion project is estimated to have an annual need for some 4 Million m3 of water. Water sources will include direct abstraction from the Bulbula River, rainwater harvesting and wastewater treatment and reuse schemes as described above. As a result of these, annual abstraction from the river is expected to be in the range of 2.2 to 2.6 million m3.

IFC has reviewed a number of studies on water usage in the Lake Ziway catchment that provide context to these water consumption figures. A lake-scale water balance based on data from three studies conducted in 2007, 2008 and 2011 by Wageningen UR, Ministry of Water Resources (MoWS), and Report to the Ethiopian Wildlife Protection Authority’s Sustainable Development of the Protected Area System of Ethiopia Program respectively) concludes that current net abstractions represent around 2-3% of the estimated annual abstraction from the lake, and around 2% of the estimated lake water balance. These figures will be reduced by the water conservation measures described above.

The new farm will draw water from the Bulbula River which flows from Lake Ziway. Expected abs
traction amounts to approximately 1.7% of the long-term annual average flow in the river, though abstraction does amount to around 6.2% of the most recently reported reduced flows in in the river in 2003-04.

Most studies report a decline in average Lake Ziway water levels since 2002, and consequently a significant reduction in outflows to the Bulbula River (although published data are not available beyond 2006 to confirm this trend). The various studies conclude that it is not commercial floriculture with its closed, drip-fed irrigation systems that are the cause of the decline in water levels in the lake; rather, state run horticulture (tomatoes, grapes) and less efficient but extensive smallholder open-field irrigation systems are by far the main causes.

On completion of the expansion project, Afriflora’s total abstraction is estimated to be less than 3% of the total water abstraction demands in the Lake Ziway catchment area.

The full implementation of the water and effluent management measures as described above, for both the existing and new expansion, will be required as per the investment agreement. IFC will closely track the company’s performance regarding these issues.

Pollution Prevention, material and waste management

Fertilizers and Nutrient use: Inputs are carefully managed at the Group’s operations. The raw water is treated to address pH; nitric acid is used to reach a target pH of 6. Other micro-elements (e.g. zinc sulphate, iron) are also added to the fertigation system. Electrical conductivity is also adjusted. Such additions to the water are dependent upon the exact soil type in which the roses are to be grown. Soil analysis to determine exact amounts to be added is undertaken by laboratories in both Holland and locally in Addis Ababa. As such, only the minimum additions are made.



As noted above, the irrigation effluent is subject to treatment and reuse in a near closed loop system; effluent that has been treated that may have to be discharged (such as that following a high rainfall event that would fill available storage) has been tested and results show effluents would be in compliance with WBG/IFC Guidelines for effluent discharge. Sanitary wastewater from all staff facilities located at the farm is channeled to lined septic tanks, where it is routinely collected and disposed on by licensed, third party contractors.



Waste management: A variety of solid wastes are generated in the growing of roses. The main types of waste (and their method of reuse, treatment and/or disposal) that are found at Afriflora’s operations are as follows: spent sheet plastic used as greenhouse covering (given to workers for use in their houses, etc); plant waste such as leaves, stems, etc. (now composted in a pilot program being run by a Dutch company with a view to the compost being returned to enhance soil quality in the greenhouses); residual crop protection products – minimal (treated in dedicated soak pits with sludge being compos
ted); empty CPP containers (incinerated); and, spent fluorescent tubes (disposed of by licensed contractor).

Integrated Pest Management (IPM) and Pesticide Use:

With regards to agrochemical use (specifically pesticides) the Group has implemented an Integrated Pest Management (IPM) Plan (managed by a Dutch IPM company and recognized leader in the field) that has significantly reduced (by 60%) the use of such chemicals over the last 3 or so years. Teams of scouts are deployed to look for the presence of pests (e.g. spider mite, mealybug and thripps); once detected, individual roses are tagged and predators (e.g. predatory mites and ichneumon wasps) are later released in those areas and subsequently attack the pest species. As noted above, application of excess nutrients is avoided through the targeted use of drip fertigation, controlled by modern technology located within each greenhouse. These mixing machines ensure that only the minimum amounts and types of fertilizers – as required by different stages of plant growth – are mixed into the raw water supply and pumped and piped to the root zones. Drainage from chemical storage and mixing areas is directed towards charcoal and sand lined soak pits designed to filter out contaminants.

A reduction in the use – and type of – chemical fungicides has also been achieved. More environmentally friendly alternatives have been sourced with the Group collaborating with suppliers to seek out and test new microbial and other natural products to reduce chemical residuals. Herbicides use has been eliminated as weeding is carried out manually. These measures are audited under the MPS-A certification scheme (discussed above); weekly sampling for residual chemicals is undertaken as a means to verify appropriate levels of application.

Greenhouse Gas Emissions: The Group measures the (minimal) use of diesel and electricity use (used to run pumps, lights, etc.); results are audited as part of the MPS ABC certification. Results from calendar year 2013 indicate a net 198 tons of CO2 equivalent being released from fuel use and 14 from the use of electricity (as supplied by the largely hydropower-based grid).

The Group will further enhance procedures to ensure the third-party transport company (that transports roses from the farms to the cargo facility at Addis Ababa International Airport) minimizes community health and safety risks, including accident prevention measures, such as appropriate speed limits and safe driving practices.

Security Personnel: Afriflora has both internal security guards and external security contractors for the site security. The security personnel conduct routine ID check at the gates and security monitoring. There are approximately 160 security guards at the operations a number of whom are armed. Security personnel are trained by the police and receive periodic training every 3 months.

The Group has a broad security policy and will develop further the procedures to ensure proper usage of security personnel. As a first step they need to perform a risk assessment of the use of security personnel at their operations, this will include background checks, clarify the circumstances under which armed security contractors are authorized to use their firearms or other force and to investigate any incidents involving private security personnel, including how such cases will be referred to law enforcement authorities in light of local legal requirements. The grievance mechanism as specified under PS1 will also include and address grievances related to security personnel.

The applicability of this PS is limited to the company’s management of living natural resources in a sustainable manner, through the application of industry-specific good management practices. As noted elsewhere in this document, the company has obtained certification to recognized international standards in the floriculture industry such as FairTrade, Ethical Trading Initiative (ETI), GlobalGAP and MPS (Dutch flower certification) systems. The company will maintain such certifications as a matter of good business practice and to provide continual access to premium markets where such certifications are required and to drive good E&S practice in keeping with the requirements of this PS and those of other applicable PS as described within this document.

Afriflora has a very close and healthy relationship with the surrounding community, primarily developed from a Corporate Social Responsibility (CSR) perspective. Afriflora is the biggest employer in the area and provides accessible health care and education facilities for all community members. Specifically, the Group founded and maintains a full service hospital which is currently providing services for all community members and promoting health care in the region. In collaboration with the government, the Group is also engaged in family planning initiatives, nutrition and HIV prevention. The Group also started and maintains the Sher school, which serves approximately 5,000 students both from employee families and those in the general community.
Regarding PS 1 requirements, the Group has assigned a person responsible for interaction with communities and other relevant stakeholders. Afriflora will further ensure a more proactive and systematic engagement with all relevant community actors to ensure environmental and social impacts and risks – and community concerns, are understood and managed accordingly and to help identify any future issues which could negatively affect the trust, credibility and local support which the Group currently enjoys. Proactive engagement with communities and other stakeholders also provides the opportunity to highlight the positive aspects of the Group’s presence in the area. Specifically, the Group will strengthen its stakeholder engagement activities by mapping all relevant stakeholders, prioritizing them by any potential negative impacts that could be created, and developing a plan for how to further enhance engagement with them.

Sher Ethiopia PLC
PO Box 399
Ziway, Ethiopia
mailto:sherethiopia@ethionet.et

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Further formalize existing processes and programs into an Environmental and social management system (ESMS), which meets the requirements of PS1	12/31/2015
External Communication and Grievance Mechanism: Assess its current communication strategy and grievance mechanism, further enhancing operational capacity and internal coordination mechanisms for ensuring appropriate communication with communities and other interested parties, including any grievances related to security personnel	07/31/2015
Stakeholder and Community Engagement Plan: Integrate and formalize a stakeholder and community engagement plan scaled to project risks and impacts and tailored to the characteristics and needs of the community members.	07/31/2015
Worker Grievance Mechanism: Assess its current workers’ grievance mechanism, further enhance in compliance with IFC’s PS2 requirements and make accessible and communicated to workers and contractors. The grievance mechanisms should be appropriate to the localities and shield workers from retribution, allow for timely response and feedback, and be gender sensitive.	07/31/2015
Training and communication: Further enhance clarity of communication of terms of employment to workers (e.g. salary calculation methods, including bonuses, overtime, leave and wage deductions applied).	07/31/2015
OHS monitoring: Enhance the OHS monitoring plan including clear communication to employees and performing on-going refresher courses. • Include performance indicators to systematically track accident statistics • Training courses should address main OHS risks, accidents/injuries, and gender related aspects	07/31/2015
Working hours: Agreement on alignment with legal working hours. This agreement should include worker representatives, Government and Group representatives and will maintaining workers overall payment level equal.	07/31/2015
Contractual provisions for contractors:	07/31/2015
Gender specific issues: With the support of a third party undertake detailed assessment of gender related issues and further develop activities/projects to address gender-specific issues and any related health concerns.	07/31/2015
Resource consumption and pollution prevention: The company shall complete the implementation of both water saving measures and those designed to protect the quality of water resources	07/31/2017
Risk assessment on Security: Assess and enhance the company’s policies and procedures for managing the use of security personnel, (in-house and third-party) including: vetting of personnel, written code of conduct, training, grievance mechanism, investigation and police referral procedures in the event of incidents, and adequate managing use of force.	07/31/2015
Socio-economic survey and analysis of displaced households: Based on the list provided by the Government entity, the Group will undertake a socio-economic survey of these displaced people and analyze the appropriate mitigation measures to ensure livelihood restoration. As a risk management measure, Group will continue to identify the other displaced households and report yearly on additional households identified.	07/31/2015
Livelihood Restoration Plan: Based on the results of the socio-economic assessment of identified displaced people, undertake a gap analysis and identify the mitigation measures to ensure livelihood restoration. Design a plan and implement identified restoration measures. The plan should describe in detail the measures taken that together will seek to restore livelihoods, including employment opportunities and the provision of other forms of assistance for land-based livelihoods and special measures to improve the livelihoods of economically vulnerable households. The Group will continue to include newly identify displaced households and report yearly on measures undertaken.	12/31/2015
Monitoring & Evaluation for Livelihood Restoration Plan: The Group will develop a monitoring plan and a final third-party resettlement completion report that will be made public. After 3 years of the resettlement.	12/31/2015