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 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
Nuqul’s policy is to obtain unencumbered land for its new developments, generally in industrial zones and urban or peri-urban areas, which is purchased on a willing buyer-willing basis. The land for the construction of the PM5 component of the project will be leased by Nuqul from the Abu Dhabi Zone Corps. For this and all existing facilities, no involuntary land acquisition or economic displacement is planned. Therefore, PS5 on Land Acquisition and Involuntary Resettlement is not considered applicable to this proposed investment. There are no indigenous people in the existing or proposed project areas, and therefore PS7 on Indigenous Peoples is not applicable. Finally, PS8 on Cultural Heritage is not applicable since no cultural heritage resources are known in the vicinity of the existing or proposed project sites.

This is a Category B project according to IFC’s Environmental & Social Sustainability Policy as the E&S impacts associated with the project are limited, generally site-specific and could be addressed through the implementation of standard good international industry practices.
Key environmental and social aspects at all properties are related to the company''s corporate capacity, monitoring and performance to date in terms of environmental, health and safety and social management; facility design, workplace environmental parameters for workers’ safety, water and energy use in the manufacturing process; pollution control, solid waste management and disposal; labor and working conditions; and management of contractors during construction of the new facility.
At the project level EHS aspects for the proposed project are related to general environmental, health and safety and social management; facility design, workers’ safety, air emissions, wastewater management, solid waste management and disposal; land acquisition for new facilities and management of contractors during construction of new facilities.

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



Existing facilities have environmental, health and safety management systems in alignment with PS1 and currently hold ISO 9001 certification for quality management system, 14001 for environmental management system, OHSAS 18001 for health and safety management and ISO 50001 certificate for energy management. PM5 will follow the same management systems under the ISO certification and will be energy certified as well. Environmental and social policies, programs and plans at the corporate level which are applicable to all facilities exist under the requirements of these certificates. Prior to construction of PM5, the company will develop an Environmental, Social and Health and Safety Management System applicable and tailored to the project to manage the risks from the construction and operation activities of the new facility. (See ESAP # 1).



Policy



Nuqul is in alignment with PS1 requirements with respect to its corporate policy. The company has established a corporate mission statement that guides all of its activities at each of its operations. The mission statement includes a formal commitment to adhere to “the strictest ethical and world class standards” and places a “high priority on investing in our human resources and in servicing our communities.” In addition, Nuqul has developed and made public its four Core Values, which are the Group’s guiding principles and include specific references to equal opportunity, integrity, quality, and social responsibility. These broad commitments are operationalized in the Group Standards Manual (GSM), which contains standard operating procedures for carrying out all aspects of its business activities in accordance with best industry practices.





Identification of Risks and Impacts



All existing facilities have developed environmental and social impact assessments (ESIAs) to comply with local permitting requirements and IFC Performance Standards. For the construction and operation of the PM5 project, the company will secure an independent environmental and social consultant to develop an Environmental and Social Impact Assessment (ESIA) to meet local permitting requirements and IFC’s Performance Standards, WBG General EHS Guidelines and WBG EHS Guidelines specific for the Pulp and Paper Mills sector. (See ESAP # 2).





Management Programs



For existing facilities, Management Plans and Procedures exist to address Environmental, Health and Safety (EHS) issues such as workplace conditions, pollution prevention, wastewater, solid waste, health and safety and resources conservation.



For the PM5, based on the findings of the ESIA, Environmental, Health and Safety (EHS) management plans and procedures (ESMP) will be developed for construction and operational phases. (See ESAP # 1)

In addition, the company has agreed to develop a specific Environmental Management and Monitoring Plan (EMMP) to address temperature levels at the workpla
ce at tissue paper facilities in Jordan, wastewater quality at its Jordan facilities and workplace air quality at its Egypt facilities and to make sure these aspects are aligned with WBG General EHS Guidelines and WBG EHS Guidelines specific for the Pulp and Paper Mills sector. (See ESAP #3).



Organizational Capacity and Competency



At existing facilities, the Group Head of EHS aspects of operation is the position reporting to the head of excellence and governance. The head of excellence and governance is responsible for the Corporate Excellence Department. This department has leverage to integrate EHS aspects into the work of all departments across all Nuqul facilities. This restructuring has helped integrate sustainability into all operations.



In terms of EHS management of the planned PM5 facility to be constructed in Abu Dhabi, three layers of management will apply as follows: 1) Project team where a member in the team will be running the project and mobilization of resources, 2) Supporting team with expertise to be available for technical support when needed and 3) A chairman of the steering committee. The steering committee consists of different members with different expertise. This steering committee team reports to top management and board of directors. One person on the project team will be assigned the health and safety tasks.



Specifically for the PM5 project, the company will ensure that there is an on-site environmental and social (E&S) focal point present during the construction phase and that an E&S focal point is available off-site during the operations phase (See ESAP # 4).



Emergency Preparedness and Response



Life and fire safety is one of the main risks at paper milling and converting plants. Given this, the Group devotes significant effort to fire risk identification, assessment and mitigation. An entire module of its Group Standards Manual (GSM) is devoted to life and fire safety, with standard operating procedures in place for regular hazard risk assessment across business units, selection of appropriate fire detection and response equipment, regular inspection of systems and equipment and training and drills. The GSM requires that fire detection and suppression systems (electrical and mechanical) must be inspected by a third party at least annually; portable fire extinguishers must be inspected monthly and refilled/recharged annually; and fire drills must be held a minimum of three times per year. Nuqul managers at each of its operating facilities work closely with local fire authorities to identify improvement to fire safety systems and training to ensure that the Group operates in accordance with global best practice in relation to fire prevention and emergency preparedness. 2014 annual E&S monitoring report submitted to IFC confirmed that frequency of drills, inspections of fire detection and fire-fighting equipment at the existing facilities were adequate. Recently, spill control, Material Safety Data Sh
eet (MSDS) and material handling instructions as well as maximum weight for storage on racks were assessed and reviewed at existing facilities. For the PM5 project, an Emergency Response Plan (ERP) which follows the same requirements will be developed (See ESAP # 5). The plan will include procedures and staff training and supplement the ESMS to achieve establishment and maintenance of an emergency preparedness and response system. In order to complete the ERP in alignment with IFC PS requirements and national laws, Nuqul will need to collaborate with local government agencies and other relevant third parties to facilitate response to accidental and emergency situations and to prevent and mitigate harm to people and/or the environment. Preparation and planning shall include identification of areas where accidents and emergency situations may occur; response procedures; provision of equipment and resources; designation of responsibilities; communication, including with potentially Affected Communities; and, periodic training to ensure effective response.



Monitoring and Review



The sustainability report produced since 2007 was upgraded in 2014 to integrate the GRI topics under the Nuqul values (pride, world and soul). The report is available online on the UN Global Compact website and Nuqul group’s website. The report can be found online at: http://www.nuqulgroup.com/Sustainability/2014.pdf.



Nuqul has a corporate monitoring program. Internally, this is called a corporate impact index. This custom-made index is used to quantify performance and assign a score. The score is based on 3 aspects: Environment (55%), Safety (40%), and sales (5%). This is prepared for top management on a monthly basis with overall trends and they design corrective action plans that are adopted/approved by the EHS manager. Specific indicators are developed to reflect the nature of activity associated with each type of facility. The targets are based on the year prior’s achieved. At the paper mills, Nuqul has surpassed the industrial benchmark and are achieving improvements on their own performance from year to year. Quarterly and half-yearly benchmark reports are presented to top management, operational excellence head and head office, head of operations, head of corporate excellence and the CEO.



Each facility follows the Group Standards Manual (GSM) which contains standard operating procedures for carrying out all aspects of its business activities in accordance with best industry practices. An external consultant is hired to consult with the EHS manager of existing facilities to integrate lessons learned from existing facilities.



In terms of reporting, there is a decentralized approach in administration but centralized in systems implementation. The existing dashboard system will be transferred to the PM5 plant as it is. Monitoring for existing facilities is carried out once a year for all facilities except for KSA since the environmental monitoring devic
es are available in-house. Tests are carried out by third parties and are shared with the operational excellence manager at each of the other facilities. Reporting on incidents takes place internally at each business unit. Any incident that occurs is immediately reported to EHS manager at HQ. Recently, the incident reporting system was upgraded to be more centralized and include the EHS manager at the final stage. PM5 will follow the requirements of the UAE national regulations in addition to the adoption of the Jordan and Egypt existing monitoring procedures if found in line with the national requirements. Monitoring thresholds will be consistent with those referenced in the applicable WBG Guidelines.

Human Resources Policies and Procedures



There is a corporate level Human Resources (HR) policy where issues related to wages, standard working hours, vacations, leave, safety regulations and employee rights are covered. For the PM5 project, a HR policy in line with local requirements and PS2 requirements will be developed. (See ESAP # 6). Nuqul will ensure that basic training on Human Resource policies and procedures are provided as part of induction and will ensure that the EPC contractor / O&M provider provides an overarching E&S training to all employees and contractors.



Around 115 employees are expected including administrative staff for PM5 without the converting plant. Recruitment at the PM5 facility is currently being conducted internally. For the PM5 project, employees with the required expertise will be transferred from Nuqul’s existing facilities to assume similar roles in the PM5 facility. New employees will be added to replace employees transferred to the PM5 projects to fill the positions that become vacant. Preference in employment will be to competent locals.



Announcements for new posts in the PM5 facility will be posted via the internal posting system, over bulletin boards and e-mails where existing employees will be encouraged to apply. For new hires, there is an on-boarding probation period of 3 months in accordance to the national labor law. The full on-boarding program for new hires covers the code of conduct, internal by-laws as well as on job training. In addition, each new comer is assigned a mentor sharing internal information with the new incumbent. An employee manual and print-out of core values and code of conduct are provided to each newly hired employee.





Working Conditions and Terms of Employment



Nuqul follows national Jordanian law that does not allow forced or child labor. Nuqul also adheres to the Jordanian labor law for not hiring workers under 18 years of age. Random checks are conducted by the Ministry of Labor to ensure compliance of all Nuqul facilities in Jordan with Jordanian labor law in terms of working conditions and implementation of terms of employment. The same applies for Nuqul facilities located outside of Jordan based on the respective national labor laws at each country.





Workers’ Organizations



Jordanian Labor Law recognizes the rights of employees to form and join unions of their choice. The company does not restrict freedom of association. Recently, Nuqul signed an agreement with the Union for workers in paper industry which is valid through the end of 2016.



Non-discrimination and Equal Opportunity



The existing HR policy includes principles of equal opportunity, fair treatment and non-discrimination with respect to any aspects of the employment relationship, such as recruitment and hiring, compensation, working conditions and terms of employment, access to training, job assignment, promotion, termination of employment or retirement, or disciplinary practices.




For the PM5 facility, there is an initial idea of the required employment profiles for the required job positions. New positions were incorporated and integrated into a Self-managed work team (SMWT). Testing prior to employment is solely based on normal requirement by national law for communicable diseases.





Retrenchment



There has been no planned retrenchments and all exits recorded in 2014 were voluntary. Some positions were found redundant and eliminated while employees holding these positions were assigned into new ones.



Grievance Mechanism



There are currently three mechanisms for receiving grievances: 1) open door policy at the Human Energy (this is the name used internally at the company to refer to human resources) department, 2) the company’s grievance system implemented at each production facility and 3) the hotline for anonymity where committee reports are produced for the collected grievances and are raised to Nuqul’s board and the CEO. Complaints are handled through the grievance route to prevent escalation. For the outsourced employees, internal supervisors report to the administration or operation manager at the site. The method of handling a grievance is largely governed by the nature of complaint.



Occupational Health and Safety



Nuqul has detailed policies and procedure in place at existing facilities to ensure a safe and secure workplace for all employees. As noted above, the majority of Nuqul Operations units (Egypt, Dubai, KSA) are certified against OHSAS 18001, an internationally recognized occupational health and safety management standard.



Detailed description of the corporate OHS management system is provided in the 2010 ESRS.



The company’s 2014 Lost Time Injury Frequency Rate is well within the sector benchmark at 2.4 against 4.5 injuries per million hours worked.



All of Nuqul’s operations are regularly monitored and audited, both internally by EHS officers and by third parties, to ensure that workplace air quality, noise levels, heat stress and illumination meet host country regulations, IFC requirements and best industry practice.



For identified deficiencies, like elevated heat stress, noise levels and indoor air quality, Nuqul has provided a corrective action plans



For PM5, and as part of the project’s Management System, Nuqul will ensure that a site-specific Occupational Health and Safety (OHS) Procedure is developed for the construction and operations phases of the project (See ESAP # 7). This will include management-approved procedures and a pervasive program to avoid specific classes of hazards in work areas, including physical and chemical hazards, and specific threats to women. This will aim at the prevention of accidents, injuries, and diseases arising from, associated with, or occurring in the course of work by minimizing the causes of hazards consistent with good international industry practice (GIIP), as reflected in internationally recognized documents including Worl
d Bank Group General and Sector-specific Environmental, Health and Safety Guidelines. Additional aspects that will be covered include (i) identification of potential hazards to workers, particularly those that may be life-threatening; (ii) provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents and (v) emergency prevention, preparedness, and response arrangements.





Workers Engaged by Third Parties



Contractors sign an acknowledgement of the internal regulations and receive the necessary training. Work permits are issued even in the case of short periods of time and permits are signed on daily basis based on inspection of the contractor’s tools. Daily workers receive a safety orientation and PPE identical to those received by direct employees. Also all safety instructions on-site are provided through a paper brochure.



For the new facility (PM5) Nuqul is planning to communicate its own Environmental, OHS, HR and other management systems to the contractors through a set template of contract. This contract will be revised according to local laws in UAE before use. The minimum number of local hires will be determined based on the availability of workers holding official work permits and existing social management system.



Management systems that contractors are expected to follow and penalties in cases of non-compliance will depend on contractual requirements. The existing system for contractor management used at other Nuqul facilities will be transferred to be applied at the PM5 project.



No accommodation facilities will be provided for contractor employees on site. Workers for construction and electrical work are usually outsourced from the industrial park that PM5 is located in. In terms of IFC PS2-related issues in the supply chain, Nuqul is a Global compact signatory and all raw material suppliers are centralized. Two checks are conducted, where one is a system check and the other is conducted by the internal audit department to make sure that Nuqul systems are being followed. A GSM audit is conducted at least once a year and can be carried out twice a year to monitor any deviations and develop necessary corrective action plans.

Resource Efficiency



For the new mill, the most recent equipment in paper mills will be installed with the latest energy efficiency technologies. In addition, Nuqul plans to implement resource conservation and energy efficiency measures similar to what is being implemented at the existing paper mill facilities. These measures include stopping motors during peak load time where possible, reduction of motor consumption by process optimization, maximization of motor energy efficiency by running in best operational conditions, utilizing natural elevations where possible to stop motors, reducing factory compressed air leaks, turning off Softwood and Hardwood Pulps during no load operation, automated control of motors using motor performance controllers and the installation of high efficiency belts on electric motors.



Annual electricity consumption at the existing facilities was reported at 1180 KWh/ton of product. In the Egypt facilities annual electricity consumption is 1100 kWh/ton. This falls well within the global benchmark for tissue paper production facilities.



Overall GHG emissions for all Nuqul facilities currently reached 268,610 tons CO2 equivalent per year based on the 2014 Nuqul sustainability report. Quantification of GHG emissions for PM5 will be included in the overall annual quantification of the Group’s facilities.





Water



Nuqul obtains water for all of it operations from ground or surface water sources, for which it has obtained long term permits from the relevant water authorities. Al Sindian water specific water consumption in September 2015 as an average of PM1 and PM3 was 7 m3/ton which is well below the global water use benchmark for the pulp and paper mills sector. Similarly, Nuqul has a water management plan for each facility including water conservation measures. Water at PM5 facility will be sourced from the water network provided by the industrial park where the facility will be located. Same water reduction measures will be undertaken at the PM5 facility for the conservation of water.





Pollution Prevention





Air Emissions and Ambient Air Quality



At Paper mills 1 and 3 that are managed by Nuqul in Egypt, all air emissions measured at the generator stacks are within acceptable limits of the local and IFC EHS guidelines for pulp and paper mills. However, for Al Keena Jordan, the NOx reported measurement exceeded Jordanian law (JS 1140: 2006, JS 1189:2006) and IFC maximum allowable limits. Elevated SO2 concentration comes with fuel composition which is bought from the Jordanian Petroleum refinery. The company will undertake an air quality study and develop a corrective action plan to achieve performance levels in line with the WBG Guidelines values at Al Keena Jordan if necessary. (See ESAP # 8).



For PM5, the client will follow the WBG General EHS guidelines and the Pulp and Paper mills specific EHS guidelines in terms of air emissions.



Wastewater Treatment



Nuqul has wastewater treatment
plants at all of its facilities that treat water to meet both host country requirements and WBG General EHS guidelines and the Pulp and Paper mills specific EHS guidelines. Annual E&S monitoring reports are submitted by Nuqul under earlier IFC investments to confirm that treatment plants regularly meet required standards. Mechanical and chemical wastewater treatment units are installed in both Egypt and Jordan facilities. Water from the treatment unit is returned to the process based on demand. In addition, on average, 4 tons of fibers per month are recovered from the waste water and returned to be recycled back into the process.



For PM5, wastewater treatment plant will meet Abu Dhabi local requirements. The UAE Environmental requirements include the Trade Effluent Control Regulations 2010 by the Regulation and Supervision Bureau for the water, wastewater and electricity sector in Abu Dhabi. To date, the process of acquiring relevant permits has not been started by Nuqul.



Solid Waste Management



Consistent with ISO 9001 and 14001, Nuqul facilities have ongoing programs to reduce waste in all aspects of business. Solid waste of all types are monitored annually, and reduction targets are set for each facility. Waste produced during daily operations is stored at designated areas on each site until removed by authorized contractors. Currently, waste products are sold to customers as a third and second grade materials at lower prices than the final product. PM5 will follow the same waste management procedures already established for Nuqul’s other facilities which will consider the “reduce, re-use and recycle” principle. Moreover, authorized contractors will be responsible for removal of waste from site in line with general EHS guidelines on solid waste management.

Community Health and Safety



All existing facilities of the company are operating over 10 km away from the nearest residential community, hence potential impacts on community receptors is limited. A total of two sites are in industrial areas in Egypt. The KSA facility is located in an industrial zone. Also, in the case of Perfect Printing Press facility in Jordan, this is located in the Sahab industrial zone. Finally Al Keena in Jordan is also operating far away from community receptors. SPIC also is located at least 15 km from the nearest community. As for the need for Stakeholder engagement, most Nuqul facilities existed before communities were built around them. For the case of PM5, this facility will also be located in an industrial zone. Hence, impacts on community health and safety is expected to be limited as well.



Transportation related risks of vehicles owned by the company are limited (company only owns and operates two cars and other vehicles for administrative use are outsourced). However, the subcontracted product transportation companies in and out of the facility may pose a risk to people along the transportation routes. The company will exert additional efforts to manage transportation-related risks and, agreed to raise awareness of these contractors on minimizing transportation related risks. This could be done through contractual agreement with subcontractor providing these transportation services.





Infrastructure and Equipment Design and Safety



Existing facilities comply with local seismic construction regulations. According to national law in Jordan, all design drawings need to be approved and stamped by civil defense and after completion of construction, all structures are audited and approved. There are stamps of approval on the Auto-cad designs of the Jordan facilities.



Security Personnel



Nuqul contracts professional third party providers of security services at all of its premises, and regularly monitors the performance of these firms. Security is outsourced based on cost benefit analysis, and in Dubai the company is shifting into outsourcing. The company has had no significant incidents involving security personnel at any of its plants. All security personnel are unarmed.

Supply Chain



Nuqul has a corporate level Supply Chain department that is responsible for purchasing raw materials, including pulp and fluff, for all of its business operations. As part of Nuqul’s commitment to operate in accordance with the principles of FSC and PEFC, the supply chain department has established a list of approved suppliers who meet FSC and PEFC requirements. Nuqul is committed to purchase raw material from suppliers of FSC-approved products. An essential component of both FSC and PEFC certifications is Chain of Custody (CoC) certificates. CoC provides a verifiable guarantee to customers that the products are originating from suppliers that promote sustainable forest management.



This area is undergoing enhancement by the EHS manager. He has included 15% of the sustainability score to focus on FSC licensing of raw material suppliers. Thereby, gradually eliminating suppliers who do not hold the FSC-approved license. At PM5, the same suppliers will be contracted for sourcing raw material with the same requirements applied by Nuqul as for the existing paper mills.

Stakeholder Engagement

Since Nuqul facilities are located mostly in industrial zones or remote areas with limited community presence, stakeholder engagement activities are limited in the areas where these facilities are located.

The Group has been active in the local communities in which it operates for many years, particularly in Jordan where it is headquartered. The focus of these activities is education and healthcare. These programs are overseen by the head of Corporate Relations for the Group. Needs for the communities are identified annually and prioritized – assistance is provided to local schools, fire departments, mosques, and for the disabled. Employees’ children receive scholarships to attend school and university.


External Communications and Grievance Mechanisms

Nuqul has established a robust community and customer complaint and feedback mechanism across its operations, for both employees and external parties. All of its product packages contain a local telephone number (and email address for contacting the company to provide feedback on the product, service, or to suggest improvements in any aspect of its operations). The same contact information is available at the gate of every Nuqul facility, and security guards have been trained to direct any party who arrives at the gate with a complaint to be transferred to staff dedicated to this function. Nuqul has designated a customer/ community service representative in each of its business units to receive comments, complaints and suggestions. The GSM requires that every comment received must be logged in through the EHS dashboard, and tracked until it is resolved and closed out to the satisfaction of the individual providing the feedback.

While PM5 is planned to be located within an industrial zone, the environmental and social impact assessment (ESIA) and resulting environmental and social management plan (ESMP) will determine the need for local stakeholder engagement. Moreover, Nuqul will carry forward the existing community and customer complaint and feedback mechanism that has been already established at the existing facilities.

Dr. Tareq Abu Ghazaleh
Head of Business Excellence & Governance
Address: 84, Moh''d Ali Bdeir St. - Abddon
P.O. Box 154 Amman 11118 Jordan
E-mail: mailto:tabughazaleh@nuqulgroup.com
Tel: +962 6 4652688 (Ext. 2243)
Fax: +962 6 4645669

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Company will hire an experienced third party to carry out an Environmental and Social Impact Assesment (ESIA) for PM5 in alignment with IFC Performance Standard 1 and WBG EHS Guidelines requirements.	04/15/2016
Develop an Environmental, Social and Health and Safety Management System (ESMS) tailored to PM5 project in Abu Dhabi in line with PS1. This management system shall include the relevant policy, ESHS Management Plans and Procedures in line with IFC's PSs.	07/15/2016
As part of its existing ESMS, Nuqul will develop and implement an appropriate Environmental Management and Monitoring Plan (EMMP) as a basis to enhance workplace and environemntal condition at existing facilities. Specific areas of focus will include heat stress of the workplace at tissue paper facilities in Jordan, wastewater quality at the Jordan facilities and workplace air quality at the Egypt facilities. Based on the findings thereof the company will implement measures to ensure applicable workplace and environmental conditions align with that specified in the WBG General EHS Guidelines and WBG EHS Guidelines for Pulp and Paper Mills.	05/31/2016
Nuqul Group will ensure that an on-site environemntal and social (E&S) focal point is present prior to the start of construction and an E&S focal point is available off-site during the operations phase.	04/15/2016
Develop and implement an Emergency Preparedness and Response Plan (ERP) for the PM5 project which includes procedures and training requirements in coordination with local government agencies and other relevant third parties.	07/15/2016
Nuqul Group will develop a Human Resources (HR) Policy and Procedures for PM5 in line with IFC's PS2 and with UAE labor laws and will ensure that the HR Policy and Procedures as developed by the EPC contractor/ O&M provider are consistent with commitments made in the Group Human Resources related documents (including training and workers grievance mechanism).	04/15/2016
Nuqul Group will ensure that a site-specific Occupational Health and Safety (OHS) Procedure is developed and implemented for the construction phase of the PM5 project. These procedures are to be aligned with good international industry practice and the requirements of the OHSAS 18001. Nuqul Group will also incorporate these requirments in contractual agreements with such third party employers.	04/15/2016
Nuqul Group will ensure that a site-specific Occupational Health and Safety (OHS) Procedure is developed and implemented for the operations phase of the PM5 project. These procedures are to be aligned with good international industry practice and the requirements of the OHSAS 18001. Nuqul Group will also incorporate these requirments in contractual agreements with such third party employers.	07/15/2016
The company will undertake an air quality study by a suitably qualified individual/firm to assess project compliance against the WBG General EHS Guidelines and WBG EHS Guideliens for Pulp and Paper Mills. Based on the findings thereof, agree with IFC on a time based corrective action plan to achieve performance levels aligned with the Guidelines if applicable.	05/31/2016