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
IFC’s appraisal did not identify issues relevant to PS5, PS7, or PS8. No land acquisition is involved, there are no known indigenous populations, or cultural heritage sites in the project area.

This is a category B project according to IFC’s Environmental and Social Sustainability Policy because the Project will generate limited and site-specific E&S impacts that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Key environmental and social (E&S) issues for the company are related to level of implementation of the environmental and social management system (ESMS) at corporate level and effective corporate and plant specific management programs addressing workplace conditions including air quality and noise, risks of fire and explosions, safe management of hazardous materials (such as hexane, caustic soda, hydrochloric acid, sulfuric acid, liquid nitrogen, etc.), solid, liquid and hazardous wastes. Additionally, Vicentin must manage issues associated with supply chain; community engagement and emergency preparedness and response. Information about how these potential impacts will be mitigated is summarized in the following paragraphs. Further information is provided in the attached Environmental and Social Action Plan (ESAP).

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

Vicentin has developed an overarching ESHS policy statement that describes the company’s corporate commitments to continuous improvement of its ESHS performance, and that the project will be in compliance with all applicable laws and regulations of Argentina. It further describes its obligations under international law, such as guarantee of good labor and working conditions without child labor in direct operations, prevention of pollution and minimizing the environmental impacts of its operation, prevent damage to health to employees, and improving the relationships with stakeholders. The overarching policy is not fully aligned with the 2012 IFC Performance Standards and as set forth in the ESAP, it shall be updated to include reference to the intent of Vicentin to support its commitments to: a) reduce risks associated with operations (e.g., explosions, fire and/or spills of hazardous substances), b) a sustainable sourcing policy in compliance with PS2/PS6 objectives, and c) manage external interactions through an active stakeholder engagement program and a mechanism to receive, analyze and address stakeholder grievances. Once updated, the policy will be communicated to contractors and suppliers.



Identification of Risks and Impacts

An identification and classification of HSE risks is carried out for environmental, and occupational health and safety. Vicentin has documented procedures to address risks associated with internal operations, and actions are designed to prioritize avoidance rather than risk minimization or mitigation. Internal risk identification is reviewed annually and when introducing a new technology or expansion. Concerns raised in the risk identification process are assessed to develop plans for compliance either through mitigation measures such as contracting external staff for EHS management, engineering controls, or use of Personal Protection Equipment (PPE). However, the risk management system requires better identification of risks and impacts of its operations to labor conditions, and supply chain operations. And, it lacks a formal method to understand fully and address risks and impacts to surrounding communities. Additional measures to be implemented by Vicentin are included in the ESAP.



Management Programs

Vicentín implemented a Corporate Management Programme during 2014. It includes objectives to mitigate E&S risks and impacts and annual reviews for continual improvement. Action plans to manage risks are prepared by supervisors from various departments, in consultation with workers and external expertise when needed, defining targets, timelines, resources, and responsibilities. Gaps identified during appraisal in the management program include the need to formalize management procedures for contractors, supply chain management, and for community engagement including on-going reporting to communities; and formalize a community grievance mechanism.



During February 2015, IFC performed an E&S assessm
ent of the Company to obtain an update of implementation progress of the past two years since repayment of IFC’s previous loans. The main findings of the 2015 assessment indicate that Vicentin has made progress in the following areas: a) developed E&S policies; b) Improved corporate life and fire safrety systems; c) In the past two years obtained corporate OHSAS 18001 certification together with ISO 14001, ISO 9001. Five out of 10 plants have the three certifications.



Organization Capacity and Competency

At corporate level, Vicentin has implemented an EHS Committee, which includes senior level managerial staff, to manage E&S issues. E&S roles have been clearly defined and assigned. This Committee includes a team of competent professional engineering staff from several divisions of the company that have time and duties allocated to the EHS role, including a consolidated monitoring framework and quarterly progress report to the company’s senior management. A Corporate EHS Manager, a Coordinator, and two EHS Regional Managers have been appointed for the operations at Avellaneda/Reconquista (North) and San Lorenzo (South). Each region has an Environmental Management Unit, a Health and Safety Management Unit, and a Quality and Food Safety Management Unit. EHS staff is routinely trained, including in root-cause analysis and specialized ESMS training to support their involvement in rolling out the ESMS. In addition, Vicentin has hired a Corporate Social Responsibility consultancy company for developing and implementing a community engagement action plan. Going forward, as set forth in ESAP, Vicentin will appoint dedicated staff to manage E&S issues in supply chain procurement of soy under its direct responsibility.



Emergency Preparedness and Response

All industrial facilities have developed and implemented emergency preparedness and response plans, in accordance with local OHS legal standards and OHSAS 18001 requirements, which cover risks due to fire and explosion as well numerous other hazards. The company is implementing a corporate emergency preparedness procedure. However Vicentin’s emergency preparedness and response planning accounts only for within-the-site response and does not include provision for external emergency management, external communication channels, or training plans, or continuous improvement of these, nor does emergency planning include nearby communities that may be affected by company operations. As set forth in the ESAP, Vicentin will update its corporate and specific emergency preparedness and response procedures to address these gaps.



Training programs shall be reviewed regularly and if necessary updated to adjust to changing scenarios arising from new acquisitions or expansions, technological changes to operations, and dynamics of surrounding communities.



Monitoring and Review

Vicentin undertakes monitoring and reporting on E&S performance of direct and supply chain operations to senior management
and to the Provincial Governments of Santa Fe and Rosario. Procedures require the involvement of the EHS Committee, and monitoring activities take place with the participation of employees. Results of monitoring are used by Vicentin in the development of improvement plans, including instances when mitigation actions do not progress at the rate expected against goals. Reports are reviewed by senior management to evaluate the effectiveness of the ESMS in supporting the general E&S performance of Vicentin. Some indicators such as water use, solid waste and energy consumption are measured at San Lorenzo in the South, but not included in the monitoring plans at the North operations. As set forth in the ESAP, at all operations, Vicentin will enhance their process for periodic monitoring and reporting to senior management of activities that have been identified to have potentially significant E&S risks and impacts during its normal operations and upset conditions. This will ensure continuing EHS performance review and realignment of Vicentin’s sustainability priorities through adoption of Key Performance Indicators (KPIs) to mainstream Environmental, Occupational Health and Safety and social parameters, including a) Safety – Lost Time Incident Frequency Rate (LTIFR - Number of lost time incidents per million hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Greenhouse gases (kg CO2 emitted / tons produced); Water Usage (m3/ton processed) and Energy Efficiency (kWh/ton processed) - Energy consumed/produced; Wastewater monitoring effluents and air emissions parameters; c) E&S Staff retention and number of training days provided to new and existing employees.



Training

Training employees in corporate EHS values, policies, and procedures is an integral part of Vicentin operations. It includes mandatory EHS induction for all staff and contractor’s before starting to work at its facilities. As set forth in the ESAP, Vicentin will further develop E&S training programs to institutionalize the PS1 compliant ESMS, and training programs including information about internal and external grievance mechanisms.

Human Resources Policies

Vicentín is a non-discriminatory and equal opportunity employer. The Corporate Human Resources department is professional, and has carried out a number of improvements to advance HR management and working conditions, including defining work ethics, training needs, provision of medical services and, in general, making efforts to ensure a safe and respectful working environment. All HR principles are equally applicable to Vicentin’s contractors. The minimum employment age at Vicentin is 18 and child labor and forced labor are forbidden within their direct operations and those of suppliers and/or contractors. Written contracts provided to permanent staff define terms of employment consistent with national labor law, including hours of work, wages and benefits, leave for illness, maternity, vacation or holiday, etc. And, no retrenchment is expected as result of project operations. Freedom of association to join a trade union of the employee’s choice is guaranteed at all Vicentin operations, following Argentina’s national labor law. The Company has procedures in place on how to effectively engage workers representatives.



Grievance Mechanism

The appraisal did not identify a formal worker Grievance Mechanism (GM), since grievances are addressed by supervisors without the benefit of an officially approved procedure applicable at the corporate level. As set forth in the ESAP, Vicentin shall implement a corporate Employee Grievance Mechanism involving an appropriate level of management and subject to a timetable for completion of consideration of grievances, using an understandable and transparent process that allows also for anonymous complaints, and provides feedback to those concerned.



Occupational Health and Safety

In compliance with Provincial legislation, Health and Safety Committees have been implemented at each Vicentin facility. Each committee is composed of workers and company supervisors/managers. Committees meet monthly to address health, safety, contractors, payroll, etc. All workers undergo mandatory pre-occupational medical examination. Also, the national labour legislation requires annual mandatory medical examinations performed by the insurance companies (Aseguradora de Riesgos del Trabajo – ART). This procedure is established to ensure that employees are fit for duty and capable of performing essential job functions.



In the past two years, Vicentin has developed an Occupational Health and Safety (OHS) Unit, equipped with professionals that have reporting lines and responsibilities in the EHS Committee. The company conducts workplace job hazard analysis which is used to prioritize preventive actions needed to eliminate or reduce the sources of accidents. This includes use of engineering controls with subsequent employee training focused on understanding workplace hazards and actions employees can take (such as using appropriate personal protective equipment–PPE, to minimize hazards.



Vicentin
has significantly upgraded the Life and Fire Safety (L&FS) fire equipment and the L&FS plan includes periodic fire drills with participation of the fire department as external auditor, and a system to ensure that corrective measures are implemented. Vicentin has obtained Corporate OHSAS 18001 in five out of 10 plants and will continue obtaining OHSAS 18001 Certification for its OHS management system at all plants.

Resource Efficiency

Vicentin pays attention to resource efficiency through continuous improvement of their processes, selection of equipment and energy source, provide reduction targets, and awareness programs with employees to reduce consumption. The Company is active in water conservation, through recycling and re-use of condensate during the crushing process. Water use, sourced from steam condensed, is 240 l/ton of soy. And, Vicentin water use does not affect use of the resource by communities. Careful attention is given during routine plant maintenance to prevent and control leaks and spills.



All industrial plants have co-generation of electricity and thermal energy for process needs. As result of an eco-efficiency project that is being conducted by Vicentín, two of the Ricardone boilers can operate with biomass (sunflower husk), while the other three boilers are fed with up to 5 tons per day of glycerin waste tanks (fatty acids and biodiesel). Fuel oil is used at times due to gas restriction availability in the country during winter. In the North, around 75% of the generated steam returns to the boilers as condensate. Firewood is used as fuel, as well as the wood waste from sawmills. Electricity consumption is in line with industry norms.



Greenhouse Gases

Cogeneration and energy efficiencies described above reduce the GHG emissions during operations. Annual greenhouse emissions from all operations are estimated at around 380.000 tpa CO2 equivalent.



Air Emissions and Ambient Air Quality

Vicentin operates a series of substantial boilers, some for cogeneration and others for process heating needs that warrant emissions monitoring. The Company is required to develop an air emissions protocol and show reliable monitoring, reporting all parameters required by IFC for each of the boilers. As set forth in the ESAP, Vicentin shall conduct boiler stack emissions monitoring at all its operations; will assess the compliance of point source emissions with local regulations and applicable WBG EHS Guidelines (General EHS Guidelines or Thermal Power Guidelines according to boiler size). If stack emissions exceed guideline values or regulatory limits, Vicentin will design and implement an approach and implementation schedule to address exceedances or demonstrate that actual emissions are not detrimental to human health and the environment.



Wastewater Treatment

Vicentin has five effluent treatment plants in both South and North operations. Sanitary wastewater in all cases is sent to the municipal sewage system. In most reports, effluent quality data are partially reported, but in operations in both South and North the available monitoring shows non-compliance with local regulation and WBG EHS Guideline values. As set forth in the ESAP, at each operating effluent treatment plant in the North and South, Vicentin will undertake comprehensive monitoring to fully understand effluent characteristics; implement cleaner production practices t
o address effluent volume and contaminant reduction through resource efficiency measures; conduct effluent quality re-evaluation, and compare results against local regulatory standards and applicable WBG EHS Guidelines with the expectation of meeting PS3 objectives. If effluent quality is not sufficiently enhanced by these measures, then Vicentin shall design and implement further remedial measures according to a remediation schedule agreed with IFC.



Waste Management

Solid waste at Vicentin is in general managed in line with best practices (reuse, recycling, treatment, disposal, and monitoring) to reduce environmental impact. Solid waste collection is separated into domestic wastes, paper and cardboard, plastic, metal and glass. Domestic wastes are send to final disposal, while paper, cardboard, plastic, metal and glass are recycled. Records of solid waste by categories are kept, as well as receipts of final disposal

from government authorized waste management and recycling contractors. Workers handling waste are trained on proper waste handling, and the appropriate use of PPE.



Hazardous Materials

The hazardous materials present at Vicentin consist of hexane, caustic soda, hydrochloric acid, sulfuric acid. All these are kept under controlled locked storage equipped with fire control equipment, and PPE and a safety protocol is provided to workers handling these materials. Vicentin monitors regularly hexane concentration in the air. Other materials include oil, light tubes, and packing materials. All these are handled separately and labeled in accordance with acceptable practices.

Community Health and Safety

Communities are not immediate neighbors of Vicentin plants in the South, and are usually located some 4 – 6 km away from the limits of Company operations. Any risk of fire and fire safety is expected to be minimal. However, potential impacts could be caused by plant-induced truck traffic carrying raw material and in some cases hazardous chemicals (e.g. hexane, hydrochloric acid, etc.). In the North operations, communities are in the vicinity of Vicentin and may be directly impacted by the Company operations in case of fire, explosion, noise, etc. As set forth in the ESAP, to prevent impacts on communities, Vicentin will develop clear safety guidelines to be enforced at each industrial plant. The Company will implement safety guidelines to be enforced on all contracted transport to avoid accidents to members of the public, as well as ensure safety of transport of raw materials and hazardous chemicals. The Company will also develop guidelines to ensure active participation of local government agencies and Local Fire Departments to respond to emergencies due to direct operations. All Company community safety guidelines will be listed in Vicentin’s website.



Security Personnel

The appraisal found that there is no formal Code of Conduct for the security personnel at Vicentin facilities, nor was documentation available showing how the company’s practices comply with PS-4 requirements on vetting personnel, providing human rights training, ensuring communities/workers are aware of grievance channels in the event of problems. As set forth in the ESAP, the Company will manage security forces in accordance with IFC PS4 requirements as described in paragraph 12 – 14, and will provide a means for communities to channel complaints about the Company’s security arrangements or personnel. Vicentin will develop a Code of Conduct and Security Management System procedures for security personnel, provide human rights training, and prepare a corporate level procedure to address and manage each identified risk in alignment with the Voluntary Principles (VPs) on Security Forces and Human Rights of the United Nations.

Supply Chain

Soybean procured in Argentina originates mainly from the region called "Zona Nucleo", which has soy production systems characterized by large farming enterprises (Estancias), no forests (no risk of deforestation), fully mechanized (no risk of child labor), and using the best available agricultural technologies. These large suppliers are fundamental to the soybean crushing business. Soybean crushing operations also procure grains in the Rosario Grain Stock Market (Bolsa de Rosario), a spot market that allows for a fair identification of origins. Certain crushing companies have implemented “Acopios”, a facility built at origins where soybean is procured and stored, and origination can be known. Soybean procurement origins comprise also the Chaco region at large where significant deforestation takes place (Chaco region includes: Central and West of Formosa, West of Chaco (Province), East Salta, and North East of Santiago del Estero Province/Department of Moreno).



Enforcing E&S policies in the soybean supply chain in Argentina is somehow challenging. Soybean is procured under a sellers’ market since the crushing capacity in the country exceeds supply of soybean. Global market conditions have a role to play in the certifications of soy adopted in Argentina. The Roundtable for Responsible Soy (RTRS) initiated implementing certification in Argentina, nonetheless the “Biomass, Biofuels, Sustainability Voluntary Scheme” (2BSvs) certification is widely accepted by suppliers, as it allows exports of certified soy oil and biodiesel to the EU. Another certification body is CARBIO (Cámara Argentina de Biocombustibles), which only certifies biodiesel from soybean oil for the EU. CARBIO is required by the EU to provide assurances that soybeans were produced following internationally acceptable labor conditions and not sourced from ecologically sensitive areas. Refiners in the EU receive tax rebates on biodiesel produced from certified soy. Adding to fragmentation of the certification scenario, the RFS2 Standard from the USA Environmental Protection Agency (EPA) is being used to guarantee sustainability of the supply chain for export of biodiesel to the USA.



As part of the supply chain component of the ESMS, the Company will develop and implement a sustainability sourcing policy (“Supply Chain Policy”). This shall require sustainable purchasing procedures and increased volumes of certified soy. This policy will prohibit sourcing of soybeans known to be produced breaching national environmental and social legislation (for example illegal land clearing, harmful child / forced labor) and/or violation of IFC Performance Standards. As set forth in the ESAP, the company will present to IFC a copy of Vicentin’s Supply Chain Policy and management procedure for review. As evidence of its commitment to sustainable sourcing, the Company will provide documentary evidence to IFC of the Supply Chain Policy training plan for its field staff and supplie
rs.



To operationalize the Supply Chain Policy, Vicentin will develop and monitor a supplier database to facilitate collection and management of supplier E&S information in soy. Primary supply chain E&S risk metrics shall include: harmful/forced child labor, labor standards and OHS issues among supply chain workers, and potential biodiversity loss. As set forth in the ESAP, traceable suppliers will be classified in categories (e.g. Certified, Traceable Not Certified, Traceable within a Region, Non-Traceable), based on E&S risk, their level of compliance with IFC PSs, and Vicentin’s knowledge on their sourcing. To demonstrate task completion, Vicentin will provide to IFC documentary evidence of creation and population of the Supplier Database and a summary of initiatives to improve the sustainability of suppliers.

The appraisal found that Vicentin has not yet developed a comprehensive stakeholder engagement plan for its operations. Elements such as stakeholder mapping, and impact zoning to identify potential affected communities are not defined. External communications and a formalized community grievance mechanism are required to ensure a publicly available channel with external stakeholders. As set forth in the ESAP, Vicentin will perform stakeholder mapping/analysis, and implement stakeholder engagement procedures including an external communication system, and operationalize a Corporate Community Grievance Mechanism.

1.Region San Lorenzo: Ruta A012 km 64, San Lorenzo, Santa Fe, Argentina
tel 03476- 423930/424148
Contactos:
Ing. Pedro Vicentin: mailto:pedro.vicentin@vicentin.com.ar
Ing. Carolina Zurcher: mailto:carolina.zurcher@vicentin.com.ar

2.Region Avellaneda: Planta algodon hidrofilo Av. Circunvalacion S/N Avellaneda, Santa Fe Argentina
CP(3561)
tel 03482-480300/480101
Contactos:
Ing. Lino Degiusti: mailto:lino.degiusti@vicentin.com.ar
Ing. Gustavo Feuillade: mailto:gustavo.feuillade@vicentin.com.ar

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
ESMS Policy: The ESHS overarching Policy statement will be revised to fully align with the 2012 IFC Performance Standards, and it shall be updated to include reference to the intent of Vicentin to support its commitments to: a) reduce risks associated with operations (e.g., explosions, fire and/or spills of hazardous substances), b) a sustainable sourcing policy in compliance with PS2/PS6 objectives, and c) Manage external interactions through an active stakeholder engagement program and a mechanism to receive, analyze and address stakeholder grievances. Once updated, the policy will be communicated to contractors and suppliers.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
ESMS Identification of Risks and Impacts: Vicentin will present to IFC the upgraded risk management process to improve identification of risks and impacts of its operations to working conditions, surrounding communities, and supply chain.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
ESMS Organization Capacity and Competency: Vicentin will appoint dedicated staff in the North and South to manage E&S issues in supply chain procurement of soy under its direct responsibility.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
ESMS Emergency Preparedness and Response: Present to IFC the updated corporate and specific emergency preparedness and response procedures that will address continual improvement on emergency management, external communication channels, and include nearby communities that may be affected by Company operations. The company will implement an internal emergency training plan in line with results arising from the risk assessment and required monitoring. Training programs should be updated frequently to adjust to changing scenarios arising from new acquisitions or expansions, technological changes to operations, and dynamics of surrounding communities.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
ESMS Stakeholder Engagement: Vicentin will perform stakeholder mapping/analysis, and implement stakeholder engagement procedures including an external communication system, and operationalize a Corporate Community Grievance Mechanism.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
ESMS Community Grievance Mechanism: Vicentin will develop, operationalize and ensure training for all staff of a Corporate Community Grievance Mechanism (GM). The GM shall be designed to receive, accept, analyze and respond to complaints from affected communities, and the general public regarding its operations and transport operations. The implemented mechanism shall include public external communication to public for dissemination of the grievance mechanism and how individuals may register grievances publicly or anonymously with Vicentin, brought to the attention of Vicentin senior management, and resolved. Any event will be recorded in the AMR.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
ESMS Training: Vicentin will further develop E&S training programs to institutionalize the PS1 compliant ESMS, and training programs including information about internal and external grievance mechanisms. Additionally, provide a summary of dates and the specific content of training seminars to demonstrate thorough distribution of information.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
PS 1 ESMS Compliant: Vicentin is required to demonstrate a PS1 compliant Environmental and Social Management System (ESMS). To close gaps and demonstrate compliance of the ESMS, Vicentin will provide to IFC, for review and clearance, its Procedures Manual.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Compliance with the PS1 ESMS element requirements will be verified by IFC through site supervision visit.	09/30/2015 12:00:00 AM	Completed	Completed	09/23/2015 12:00:00 AM
ESMS Reporting and Review: At all operations, Vicentin will enhance their process for periodic monitoring and reporting to senior management of activities that have been identified to have potentially significant E&S risks and impacts during its normal operations and upset conditions. This will ensure continuing EHS performance review and realignment of Vicentin’s sustainability priorities through adoption of Key Performance Indicators (KPIs) to mainstream Environmental, Occupational Health and Safety and social parameters, including a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (M3/ton processed) and Efficiency; Energy Usage (kWh/ton processed) - Energy consumed/produced; Wastewater monitoring effluents and air emissions parameters; c) E&S Staff retention and number of training days provided to new and existing employees.	3/31/2016	In Progress	In Progress
Employee Grievance Mechanism: Vicentin shall implement a formalized employee Corporate Grievance Mechanism (GM) involving an appropriate level of management and subject to a timetable for completion of consideration of grievances, using an understandable and transparent process that allows also for anonymous complaints, and provides feedback to those concerned. The GM should have a system to document, route, track, and report on the resolution. And, employee training at induction and periodic refresher sessions shall inform the workers of the grievance mechanism and its function and how individual grievances have been resolved. The GM shall be easily accessible to all employees.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Boiler stack emissions: Conduct Boiler Stack Emissions Monitoring and collect stack emissions samples: Vicentin is required to develop an air emissions protocol and show reliable monitoring, reporting all parameters required by IFC for each of the boilers. Vicentin shall conduct boiler stack emissions monitoring at all its operations; will assess the degree of compliance with regulatory and WBG General EHS guidelines air emissions limits (the most stringent will be adopted). If stack emissions are beyond the allowable limits stipulated, Vicentin will design and implement an approach and implementation schedule to address exceeds or demonstrate that actual emissions are not detrimental to public health.	3/31/2016	In Progress	In Progress
Effluent quality compliance at all effluent treatment plants: At each operating effluent treatment plant in the North and South, Vicentin will undertake comprehensive monitoring to fully understand effluent characteristics; implement cleaner production practices to address effluent volume and contaminant reduction through resource efficiency measures; conduct effluent quality re-evaluation and compare results against local regulatory standards and applicable WBG EHS Guidelines showing that the current discharges meet PS3 objectives; design and implementation of remedial measures and proposed remediation schedule if needed shall be presented to IFC for review.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Community Health and Safety: To prevent impacts on communities, Vicentin will develop clear safety guidelines to be enforced at each industrial plant. The Company will implement safety guidelines to be enforced on all contracted transport to avoid accidents to members of the public, as well as ensure safety of transport of raw materials and hazardous chemicals. The Company will also develop guidelines to ensure active participation of local government agencies and Local Fire Departments and Emergency Care to respond to emergencies due to direct operations. All Company community safety guidelines will be listed in Vicentin’s website.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Security Management Plan and Operating Procedures: a) Operating procedures will include how security forces will be managed in accordance with IFC PS4 requirements as described in paragraph 12-14. b) Hiring of security personnel will include (i) screening potential workers for past criminal offenses or human rights abuses, (ii) training, company security policy and code of conduct. c) A corporate level procedure will be prepared to address and manage each identified risk in alignment with the Voluntary Principles (VPs) on Security Forces and Human Rights of the United Nations. d) As part of its stakeholder engagement policy, Vicentin will communicate and train on security arrangements to workers and affected communities. e) An incident response system involving security forces will be implemented to ensure that all incidents are registered and responded to using correct disciplinary actions where required.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Supply Chain Risk Monitoring to Ensure Sustainable Procurement Within the Management System Framework Described in Task 1: a) Vicentin will develop and implement a sustainability sourcing policy (“Supply Chain Policy”). This shall ensure sustainable purchasing procedures and increased volumes of certified soy. This policy will prohibit sourcing of soybeans known to be produced breaching national environmental and social legislation (for example illegal land clearing, harmful child / forced labor) and/or violation of IFC Performance Standards. The Company will present to IFC a copy of Vicentin’s Supply Chain Policy and management procedure for review. The Supply Chain Policy shall be included in all contractual agreements with suppliers.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Supply Chain Risk Monitoring: As evidence of its commitment to sustainable sourcing, Vicentin will implement field staff training programs for mainstreaming the Supply Chain Policy.	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Supply Chain Risk Monitoring: c) To operationalize the Supply Chain Policy, Vicentin will develop and monitor a supplier database to facilitate collection and management of supplier E&S information in soy procurement. Primary supply chain E&S risk metrics shall include: harmful/forced child labor, labor standards and OHS issues among supply chain workers, and potential biodiversity loss. The suppliers’ database will be structured to facilitate monitoring of traceable suppliers. Suppliers will be classified in categories (e.g. Certified, Traceable Not Certified, Traceable within a Region, Non-Traceable), based on E&S risk, depending on their level of compliance with IFC PSs, and Vicentin’s knowledge on their sourcing. To demonstrate task completion, Vicentin will provide to IFC documentary evidence of creation and population of the Supplier Database and a summary of initiatives to improve the sustainability of suppliers. This shall include informing farmers with whom Vicentin has soy purchase contracts or partnerships that the Company expects them to comply with Argentine legislation, IFC Performance Standards, and that the Company will avoid procurement of soybean from unlawfully cleared land in the Chaco region at large (Central and West of Formosa, West of Chaco (Province), East Salta and North East of Santiago del Estero Province (Department of Moreno).	12/15/2015 12:00:00 AM	In Progress	Due date revised as agreed with IFC client