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 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
SACO sources the majority of its cocoa from partner cooperatives, and the remainder from BP’s network of registered farmers and active suppliers (local traders and other cooperatives). The relationship between SACO and the partner cooperatives, BP and the registered farmers as well as the active suppliers is based on yearly procurement contracts. SACO and BP may also provide technical advice to partner cooperatives and the network of registered farmers. As this contractual relationship is short-term, not exclusive and does not involve direct financial assistance (which is not readily available as part of standard sector practices), it is judged that SACO and BP do not have reasonable commercial leverage over the practices of these other than ceasing procurement from these sources. For the purposes of this project, the partner cooperatives, registered BP farmers and active suppliers will be considered as primary suppliers for which PS2 and PS6’s related supply chain requirement applies. Furthermore, for the purposes of this project, only partner cooperatives and registered farmers within BP’s network are eligible for non-cash lending from BC. SACO’s two cocoa processing units in San Pedro and Abidjan are not classified as “associated facilities” within the scope of this project because these would be viable in the absence of this project, and application of the Performance Standards to their operations does therefore not apply.

For the purposes of this project, issues related to PS 3: Resource Efficiency and Pollution Prevention do not apply; however, issues related to PS 3 outside the scope of this project are being addressed under BC’s sustainability framework. Issues related to PS5: Land Acquisition and Involuntary Resettlement are not expected as the company has no plans to acquire land for cocoa cultivation or additional plant/operations within the scope of this project. Issues related to PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: there is no presence of Indigenous Peoples or known cultural artifacts within the footprint of cocoa production areas. In the event that issues anticipated by these PSs arise, BC will promptly inform IFC. Screening and assessment of these issues against PSs requirements will be done through the company’s E&S management system (ESMS).

The project is a “category B” project according to IFC’s Policy on Environmental and Social Sustainability because potential adverse environmental and social risks are limited, reversible and may be readily mitigated.

The key environmental, health and safety issues associated with this project include: i) adequacy of environmental and social assessment and management systems (ESMS); ii) labor relations, human resources policy and practices; iii) employee and student health and safety, including training; iv) life and fire safety, including adequacy of emergency preparedness and response programs; v) water, waste-water, and waste management; vi) building management and opportunities for energy conservation and efficiency; vii) food safety and security.

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: ADvTECH abides by an Environmental Policy that states the importance of
students and staff achieving and demonstrating sound environmental practices,
with particular reference to engagement with the communities where the group is
active, or are seeking to join. Selected environmental programs are implemented
on an ongoing basis throughout the operations, which also form part of the
curriculum at the schools, such as recycling and regular community clean-ups,
as well as participating in affiliated programs like Eco-School and Jacaranda
FM Project Khanya. This Policy is applicable across the Group, and will
similarly apply to all newly acquired or developed businesses in the RoA.
Identification of Risks and Impacts: The Group applies a corporate risk
management approach to its operations, which is reported and monitored at Board
level. Record keeping is thorough, and feedback is given at various levels in
order to continually review issues, and improve service. For new projects,
ADvTECH undertakes a process which includes: demographic studies; an area
analysis; a feasibility study; availability of services; legal aspects; a site
assessment and risk analysis. The project managers utilize an inclusive rating
process to identify fatal laws, and assist with establishing project viability.
The Properties Department manages all aspects of this procedure as well as
overseeing the statutory environmental and social impact assessment (ESIA)
process, and ensures that all relevant permits are obtained.
The Company’s RoA expansion will model its process on the above (and enhance it
to identify E&S risks and impacts to comply with local and IFC’s requirements)
in the form of an Environmental and Social Due Diligence (ESDD) before the
acquisition or establishment of any new business. This procedure is to define
the approach to assessing potential impacts and risks against national EHS
legislation, the requirements of Performance Standard 1 and the World Bank
Group EHS Guidelines (the latter includes the requirement to assess activities
relative to internationally recognized life and fire safety (LFS)). The
outcomes of the ESDD are to be a defined in a time-based EHS action plan to
ensure acquisitions / new developments align with the criteria against which
they are being assessed, within a period of 2 years. (ESAP #1).
Management Programs: During the site visits, it was clear that the facilities
were (without exception) well run, clean and modern, with very strict
administrative and training procedures, that are monitored by ADvTECH. The
company has a history of successful acquisitions, with the concomitant transfer
of systems, policies and procedures. The reputation of the various brands is
due to the effectiveness of applying the existing ADvTECH policies and
practices (including a commitment to good governance, and social management
systems). All facilities owned by the company currently meet local legislative
requirements and utilize detailed operational manuals, which conform to
international best practice for the education sector.

Environmental issues are predominantly dealt with on a site-specific basis and
not via a conventional environmental management system. Due to the objective of
the Group to expand into other markets, it will develop a corporate approach
which consolidates all existing policies and practices into an integrated
environmental, social, and occupational, health and safety (OHS) system with
mitigation measures, monitoring parameters and implementation responsibilities
across the Group. Monitoring parameters and thresholds will be consistent with
those referenced in the World Bank Group’s General EHS Guidelines: section 3.1
for water quality; sections 1.1-1.3 for waste and waste-water, and OHS
corresponding with section 2 of the IFC General EHS Guidelines. While most
aspects of the IFC Performance Standards are currently satisfied for the South
African operations, businesses in other markets may require a more structured
approach. Overall, the resulting E&S management system (ESMS) will be aligned
with the requirements of Performance Standard 1 and other recognized
international standards such as ISO 14001 and OHSAS 18001. Thereafter, this
will become the corporate standard to be employed consistently across all Group
operations, as well as all future businesses in the RoA. The Company also
commits to monitoring socially sensitive matters that could impact reputation
and affect development outcomes. These may include measures to manage E&S
risks, optimize social benefits, conduct public consultation and provide
information to project-affected communities. Implementation will be supported
by the provision of resources (qualified and competent staff, capital and
operating budgets), be integrated throughout operations, and include training,
to accomplish the program and its requirements, as well as measures related to
the evaluation and monitoring of priority risks and impacts, and furthermore be
extended to include contractors working on projects, articulated as ESAP #2.
Organizational Capacity: ADvTECH has a very strong management team with
significant experience in education and recruitment, as well as highly
qualified academic staff (most management and teaching staff have tertiary
qualifications and specializations). The Executive Committee, which meets
monthly, consists of 10 members including the Chief Executive Officer (CEO).
ADvTECH does, however, not have dedicated corporate (Head Office) staff with
Environmental, Health and Safety (EHS) capacity, although each site has a
Health and Safety (H&S) officer. The company presently contracts with an
environmental consulting firm that produces and submits ESIA reports to
government on their behalf, and advises on ad hoc E&S issues.
ADvTECH has agreed to appoint an appropriately qualified employee (“EHS
Manager”) to monitor and report on all matters relating to Environment, Health
& Safety (EHS), labor and community relations during acquisition (in RoA), as
well as managing the integration of the E&S management system across the
Group’s existing operations. This person will also be responsible for
recommending to the Company (for its RoA expansion), the steps or actions
regarding EHS aspects of the businesses acquired or established (arising from
the ESDD), as well as implementing the conditions of the ESAP (ESAP #3).
Monitoring and Review: As mentioned above, each site owned by ADvTECH has a H&S
officer, who ensures compliance to local regulations and reports any incidents
of non-compliance to the Facilities Manager. The group uses an online H&S
system which makes policies, procedures and guideline documents available to
all. The results of the group annual (internal and external) OHS audits, H&S
risks and corrective actions are also reported to a Health and Safety Committee
which meets quarterly at Head Office (and is chaired by the CEO), the Executive
Committee (ExCo) and the Transformation, Social and Ethics Committee (TSEC) of
the Board. The ExCo and TSEC also consider reports on the progress of the
environmental programs implemented within the different divisions. An OHS
Bulletin is circulated regularly to employees that continually raises awareness
and provides information. Incident records from all sites are circulated to all
Facility Managers for learning and discussion, and incorporated into each
sites’ risk profile.

For its RoA expansion the Company will undertake annual EHS assurance audits
against the EHS Policy to confirm the adequacy of the ESMS for all operations,
and based on the findings, will address gaps/deficiencies (taking into account
applicable local requirements and other relevant standards and objectives as
already explained). As per the ESMS, specific EHS key performance indicators
will be monitored and reported upon in an agreed EHS reporting format, as
follows: compliance with legal and regulatory requirements, including the ESMS
progress and certification where applicable, energy and water consumption and
efficiency; GHG emissions; solid and hazardous waste management and disposal,
effluent discharges, compliance with national OHS requirements, including
accident rates (lost-time accidents); customers and community complaints,
supplier performance and community engagement activities (ESAP#4).

Emergency Preparedness and Response: ADvTECH applies strict procedures for
facility fire prevention, emergency response and evacuation, as prescribed by
South African legislation, and which are aligned with ISO 9001 and OHSAS 18001
Management Systems. These measures comply with the IFC’s Performance Standard
1. The Company will ensure that similar emergency and risk procedures are
undertaken in RoA with the same level of meticulousness, supported by suitable
training of employees at each acquired business; and as informed by the results
of the ESDD process

Human Resources and student management: ADvTECH currently employs 5,025
permanent staff members and approximately 600 seasonal employees (e.g. sports
coaches), who provide services to 48,053 students (29% of staff are male; 71%
are female). 65% of ADvTECH students are classified as previously disadvantaged
and more than 57% are female. In 2014 the Group’s grants/bursaries benefitted
over 7 100 individuals.

The company has an Employee handbook and Student handbook applicable to each
brand that articulates the organization’s policies with regard to student,
employee and contractor management. ADvTECH takes into account all local legal
requirements concerning minimum wages, overtime compensation, benefits, sick
leave etc. and ensures that the working week is also as per South African
regulations. The use of child labor is not tolerated. Similarly, ADvTECH does
not engage in or support the use of forced labor. ADvTECH is supportive of
employees’ choice to belong to a union or associating freely with any lawful
worker’s association or collective bargaining association of their choice; a
small number of employees currently belong to a union, but it is below the
threshold to have a collective bargaining agreement. An employee representative
forum is in place that communicates to management on their behalf. ADvTECH does
not discriminate on the base of sex, race, religion or culture. Finally,
ADvTECH does not tolerate any form of corruption including extortion, fraud or
bribery. South African labor standards are very strictly applied, enforced and
reported, and are in compliance with PS2.

All employees have access to the ADvNET site, which is the internal
communications platform, on which policies, practices and continuous refresher
training material are distributed. It is policy that each employee should have
ADvNET as their "home page/screen saver". The ADvTECH People Solution (APS)
system was introduced in 2014, which is an advanced technology-driven HR and
Payroll System. It provides information on the payroll, leave, and employee
development and performance management. This system improves ADvTECH’s legal
compliance and security, and allows staff to check their personal/confidential
information.

Grievances: The company has well documented policies and procedures for raising
grievances, in addition to a hotline for grievances to be logged when the
person would like to remain anonymous.

The company will adapt the existing Employee Handbook as the tool to
communicate and implement relevant policies governing HR, to be applied as the
corporate standard to acquisitions outside of South Africa where the labor
legislation may not be as well established. All acquired and established
businesses in RoA under management control (MC) will then customize the
Handbook to correspond with local regulations, and the Company commits to
monitoring whether the above practices are communicated, performed and followed
by such businesses (ESAP#5). The handbook will also include the grievance
mechanism for all employees and contractors in accordance with Performance
Standard 2.

Occupational Health and Safety: ADvTECH takes Occupational Health and Safety
(OHS) very seriously. The company’s Facilities Manager rigorously trains,
audits and ensures adherence to the Group’s Health and Safety (H&S) policies
across all divisions, which includes aspects of OHS. All job descriptions
include elements of H&S such as emergency preparedness, and some employees also
receive job-specific training. As part of the overall commitment to student and
staff well-being, the Group conducts regular internal and external H&S audits
to comply with their policy and the South African statutory requirements. The
2014 Annual Report confirmed that all four of the ADvTECH brands achieved
external H&S audit scores above the 90% Group target threshold.

Each site has a dedicated person responsible for H&S, as well as H&S volunteer
representatives from the teaching staff, who report to the Facilities Manager,
and who are trained in First Aid, OHS, emergencies, evacuation, Life and Fire
safety, HIV/Aids as well as risk and incident management. Some campuses have
on-site nurses, while the bigger ones have an on-site Doctor who keeps records
of injuries, illnesses etc. The company enters into agreements with the nearest
hospital for ambulance services and treatment; for large events and
particularly sports events, an ambulance and paramedics are always on site duty.

As previously mentioned (ESAP #2)it is envisaged that within a two year period,
the Company will implement a corporate E&S system at all acquired businesses in
the RoA, which will include OHS, LFS, emergency preparedness, and risk
management (to comply with section 3.2-3.7 of the General EHS Guidelines).

Contractor management: Where functions are outsourced to contractors or third
parties, ADvTECH’s service level agreements (SLAs) with these parties will
include actions and measures necessary for them to perform their services in a
manner consistent with the Group’s ESMS, policies and programs. At this stage,
the Group only utilizes contractors on an approved supplier list (screening
includes occupational health and safety experience/accreditation). Bidding
documents for construction phases stipulates that a safety officer must be
present on site at all times, and a mandatory section is included in the
contract committing to the Group’s H&S requirements (this includes training on
hazardous substances management, chemical safety, working at heights etc). The
same principles will be followed by the Company for its RoA expansion, subject
to local conditions.

HIV/Aids program: The Group has an HIV/Aids policy, which is included in the
induction of new employees, to inform them that they have confidential access
to external specialists if they have any HIV- related questions. As with other
social aspects, ADvTECH also educates scholars and students regarding HIV/Aids.
H&S representatives are trained and available to assist in and refer to
specialists regarding HIV/Aids queries.

As the intention is to expand into Africa, within regions with high incidence
rates for HIV/Aids and other communicable diseases, it is expected that the
Company will formulate and implement an HIV/Aids and Communicable Disease
Policy in the RoA, appropriate to the norms and policies of each country, and
aligned with IFC’s Good Practice Note “HIV-AIDS in the Workplace”.

Water consumption: ADvTECH typically implements water conservation measures
across the Group, including the retention of storm-water for irrigation
purposes, rainwater harvesting which minimizes the use of potable municipal
water, and borehole water (some sites use borehole water which is tested and
only used for irrigation purposes).

Waste management: The facilities also each have a waste management plan that
aims to minimize waste generation. The plans include the segregation of waste,
storage, handling and disposal. Separation typically focuses on paper, plastic,
glass and metal, and the infrastructure (separate bins etc.) is supplemented
with ongoing training and environmental programs focused on student and
employee awareness to encourage better waste management. A number of private
(registered) operators collect the recyclables.

Energy and GHG emissions: Security of electricity supply has necessitated the
installation of 12 diesel generators (spread across the Group) of varying
(30-250 KVA) capacities. ADvTECH monitors its carbon emissions, reporting in
its 2014 annual report that normalized emissions reduced from 406 kg CO2 per
student in 2013 to 309 kg CO2 per student in 2014, equating to approximately
14,800 tons of CO2e per annum. This is below IFC’s reporting threshold of
25,000t CO2e per annum, and it is unlikely that, in the medium term, the
company’s planned expansion plans will exceed this threshold.

Energy consumption: Energy use is monitored closely as the Group owns many
buildings; rising costs have been a driver for the implementation of energy
efficiency initiatives and alternative energy sources. The Group has explored
solar panels, heat pumps, and various other technologies via an initiative
called the ‘Power Saving Pilot Project’. Design features which improve energy
efficiency is a major consideration in the design of new buildings and
renovations.

Waste water and sewerage: Waste water arising from existing operations -
kitchens, laundries, showers, basins and other activities - is currently
discharged to the municipal sewer for treatment at municipal waste water
treatment sites. Grease traps from campus kitchens are cleaned weekly if food
is prepared on site. Waste water discharge sites, kitchens and waste areas are
periodically monitored by Environmental Health inspectors from the
municipality.

For each business acquisition or establishment in the RoA, the learnings from
the ESDD process for the above parameters are expected to result in an
Environmental, Health and Safety (EHS) action plan, For all majority-owned
businesses, compliance and consumption data will be reported annually as part
of the Integrated Annual Report which is published on the Group’s website.

Emergency Preparedness and Life and Fire Safety: As indicated in PS1, LFS and
Emergency preparedness plans are usual practice for facilities operated by
ADvTECH, and existing buildings are certified as being in compliance with the
South African Building Standards, and IFC’s LFS PS requirements. This is
applied to both leased and owned buildings (LFS compliance is a condition of
the lease agreement in all cases).It is agreed that, as an integral part of the
ESDD associated with each new acquisition n RoA (ESAP #1), the Company will
perform a review of the Life and Fire status of all facilities of the target
business. The ESDD process will attempt to assess the level of compliance by
the target business with local building fire, and legal/insurance requirements,
as well as with South African LFS standards. Depending on the findings, the
Company may draw up an LFS plan to implement relevant corrective measures on
the facilities. In addition, Greenfield projects shall comply with the WBG LFS
requirements articulated in section 3.3 of the General EHS Guidelines.

Security Personnel: ADvTECH employs reputable (registered) third-party
companies for security. Personnel are accredited with the appropriate security
association, are suitably trained, equipped, and regularly rotated. They are
unarmed and rigorously follow a Standard Operating Procedure prescribed by the
Group. Additional security measures also include access control gates and
booms; electric fences, security lighting; CCTV which is monitored 24/7;
emergency lighting; intercoms; and access to armed response in the case of an
emergency. Security personnel assist with identification of risks, incidents,
and facilitate efficient implementation of emergency procedures and drills.

Food safety: All food prepared for the different campuses and facilities
(café’s, canteens and boarding establishments) are governed by detailed Service
Level Agreements that the company has developed. Providers must comply with
South African Food Safety regulations, and are subject to ADvTECH’s stipulated
dietary criteria.

Accommodation and facilities structural integrity: The Properties Manager
ensures that all buildings comply with the South African National Building
Regulations, as well as a particular set of standards which have been developed
by the Group. As per the legislation, buildings are approved and certified by
the local planning authorities, building inspector, and the fire department.
Boarding accommodation and associated facilities are in line with international
norms and far exceed the South African government “Guidelines for the provision
of boarding facilities in public ordinary schools”.

Vehicle/Driver safety: ADvTECH has meticulous protocols that must be followed
when employing and monitoring drivers of their own, or hired, vehicles
transporting pupils/students. The company ensures appropriate training of
drivers (all will be trained in advanced driving techniques and hijack reaction
during 2016), maintenance of vehicles (vehicles undergo daily checks) and
performance monitoring is undertaken (Skytrax, a GPS tracking system, is being
installed on all vehicles to measure speed and driving behavior).

For its RoA expansion, the Company will assess the specific need, and develop
an implementation plan, for all businesses acquired or developed in RoA, for
the following: i) security measures, which may include the development and
implementation of a Security Management Plan (SMP), the need for security and
emergency training etc; ii) food safety measures, which may include the
development and implementation of a Food Safety Management System aligned with
HACCP, and iii) a safe driver and transport safety vehicle policy and procedure
(ESAP #6).

ADvTECH prioritizes collaboration with their stakeholders wherever they operate, which include investors, students and their parents, alumni, staff, suppliers, business partners, government and policymakers, NGOs and communities, in addition to accredited membership of relevant industry bodies. Special focus committees - Human Resources, HIV/AIDS, Employment Equity, Skills Development, Investors in People, Occupational Health and Safety (HESIO) – along with the support of the on-site Student relations managers, partner with various organizations to ensure a positive impact is made in communities where ADvTECH is active. The company does not have a formal stakeholder grievance procedure, which will be developed and applied across the Group, as ESAP #7. The Company will ensure that affected local communities in RoA, if identified, are engaged via a communication process and grievance procedure.

Contact Person: Company Secretary
Company Name: Advtech Limited
Address: Inanda Greens, 54 Wierda Road West, Wierda Valley, Sandton
Email: mailto:groupsec@advtech.co.za
Phone: 011 676 8000
Facsimile: 011 783 2640

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
ADvTECH will develop and implement an Environmental and Social Due Diligence (ESDD) procedure for application prior to the acquisition or establishment of any new business in South Africa (SA) or Rest of Africa (RoA). This procedure is to define the approach to assessing potential impacts and risks against national EHS legislation, the requirements of Performance Standard 1 and the World Bank Group EHS Guidelines (the latter includes the requirements to assessing activities relative to life and fire safety requirements). The outcomes of the ESDD are to be a defined in a time-based EHS action plan to ensure acquisitions / new developments align with the criteria against which they are being assessed within a period of 2 years.	06/30/2017
ADvTECH will develop a corporate approach to E&S which consolidates all existing policies and practices into an integrated environmental, social, and occupational, health and safety (OHS) system with mitigation measures, monitoring parameters and implementation responsibilities. This integrated Environmental and Social Management System (ESMS) will be aligned with the requirements of the Performance Standard 1, the World Bank Group EHS Guidelines, ISO 14001 and OHSAS 18001 and will become the corporate standard to be applied to all new businesses acquired by ADvTECH in RoA.	09/30/2017
ADvTECH will appoint a qualified person to manage all matters relating to Environment, Health & Safety (EHS), labor and community relations during acquisition and operation of acquired businesses in SA or RoA, where the Company will exercise management control. The EHS Manager will monitor compliance with statutory requirements and pursue the incorporation, over time, of the relevant IFC’s Performance Standards.	12/30/2016
Ensure that all acquisitions / new developments comply with the company existing approach to human resources in South Africa.	06/01/2016
Prepare an integrated EHS report format based on critical EHS key performance indicators (e.g., compliance with legal and regulatory requirements, including the ESMS progress and certification where applicable, energy and water consumption and efficiency; GHG emissions; solid and hazardous waste management and disposal, effluent discharges, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, supplier performance and community engagement activities) for submission to IFC and the company Board.	12/30/2017
ADvTECH will, at an appropriate time, assess the specific need in any acquired businesses in RoA (where there is MC) for the development and implementation of the following: i) a Security Management Plan (SMP), as well as the need for security and emergency training; ii) a Food Safety Management System aligned with HACCP for any kitchens operated by the company, and iii) a safe driver and transport safety vehicle policy and procedure, in order to be in compliance with the requirements of IFC’s Performance Standard 4.	12/30/2017
The ADvTECH will develop and implement a formal stakeholder grievance policy and procedure, which will be applied across all divisions, and be applied to all businesses acquired or developed in RoA.	12/30/2016