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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement

The potential power generation investments to be supported by IFC’s equity participation in UNIT include Unit Zakho (a 1,260 MW CCGT project in Iraq); other potential power generation projects still to be identified. Unit Zakho (IFC’s other project appraised in 2014) identified PS1 – 5 as applicable. For other potential power generation projects to be identified, PS 1 -3 are applicable, and applicability of other PSs (PS 4 – 8) will be identified through assessment of environmental and social risks of those identified projects when they are going to be developed in the future.

Based on IFC’s review of UNIT’s representative set of existing power plants in their portfolio, the pending completion of land acquisition and involuntary resettlement at UNIT’s existing hydropower plants was identified as a potential E&S risk that needs continuing and thorough management by UNIT. Brief background information as well as an agreed supplemental action is described under PS5 section of this ESRS. In addition, brief description about dam safety review of UNIT’s existing hydropower plants and security personnel management by UNIT is provided under PS4 section of this ESRS.

No major PS6 (Biodiversity Conservation) or PS8 (Cultural Heritage) impacts have been identified in connection with UNIT’s projects either under construction or in the pipeline. However all new projects will be screened against these PSs, as per description under PS1 and associated ESAP item. PS6 and 8 legacy issues associated with portfolio projects are described in the project description section. PS7 (Indigenous Peoples) is not considered applicable to this investment given the target countries involved.

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

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. This is a category A project according to IFC’s Policy on Environmental and Social Sustainability because the company plans to invest or develop gas-fired large scale CCGT projects in the Middle East and renewable energy projects in South Eastern Europe, which have potentially significant E&S risks and impacts.

Environmental and Social Assessment and Management System:



Existing power generation assets in the UNIT portfolio have E&S management system (including policies and procedures, assigned E&S officers, monitoring and reporting scheme) generally in line with IFC Performance Standards.



UNIT’s operation to develop power generation projects and to manage their performance is conducted by a small group of project development professionals. At UNIT corporate level, senior management officers responsible for compliance and operations management are also assigned to cover E&S performance monitoring, but this is not clearly documented in UNIT’s Project Development Procedure. At each project company, a board member representing UNIT receives and reviews regular operational performance reports which include E&S aspects, and where significant E&S issues are identified, those are brought to UNIT senior management’s attention. As per ESAP Action No. 1, UNIT will include E&S impact identification and management elements into UNIT’s Project Development Procedure.



Policy:



The corporate level environmental policy of UNIT was published in 2008. With this policy, UNIT guarantees compliance with local laws and regulations, clear identification of direct and indirect risks and impacts and reduction of these impacts and risks. To achieve these objectives, the company is committed (i) to continuously improve its environmental performance and integrate applicable best practice into their business operations, (ii) to reduce their consumption of resources and improve efficiency in the use of those resources, (iii) to manage waste generated from their business operations according to the principles of reduction, reuse and recycling, (iv) to ensure environmental criteria are taken into account into the procurement of goods and services, and (v) to ensure that environmental considerations form part of their business planning and decision-making processes. Implementation of the policy objectives is the responsibility of all group employees, contractors, suppliers and vendors. As per ESAP Action No. 2, UNIT will strengthen their existing corporate environmental policy to include requirements of PS 1 (i.e. defining health and safety, and social principles and objectives of the company).



Identification of Risks and Impacts:



UNIT retains external consultancy companies for (i) identification of risks and impacts of its individual projects mostly in the form of environmental impact assessment (EIA) or environmental and social impact assessment (ESIA), (ii) monitoring of E&S performance during construction and operational phases of the projects and (iii) conducting E&S audits for compliance with local laws and regulations at the project level.



All operational and under construction projects have obtained governmental approval through EIA procedure except Boyabat HEPP, which was exempted from environmental assessment as the project was introduced before the
relevant EIA regulation was published. Nevertheless, an environmental assessment report (“Boyabat Dam and Hydroelectric Power Plant, Environmental Assessment Report, 1998) was prepared by a local consultancy company so as to evaluate the environmental and social impacts of dam site and powerhouse of Boyabat HEPP and submitted to regulatory authorities for their information (before UNIT was involved in the project). Various feasibility studies were prepared for Boyabat HEPP project, including the first set of feasibility studies prepared in 1958, followed by updated technical and financial feasibility studies conducted by DSI (State Hydraulic Works) in 1979. DSI further updated the feasibility studies in 1986, and the project was subsequently transformed into a BOT project by the Ministry of Energy and Natural Resources (MENR). The final design documents were submitted to EIGM (General Directorate of Energy Affairs) of the MENR in 2008 to proceed with the construction activities. In addition to DSI who was involved in the technical design of the project (including seismic risk and dam safety review), additional review was conducted by the owners’ engineer (Su Yapi – Yapi Teknik, and Hidrodizayn plus Lahmeyer) and the lenders’ engineer (Poyry plus Dolsar).



The above mentioned Environmental Assessment Report of 1998 for Boyabat Dam and Hydroelectric Power Plant was prepared in line with the World Bank Operational Directive 4.01 and IFC’s Guidance for Preparation of Environmental Assessment, available at that time in 1990s.



The biomass cogeneration plant in Croatia and the wind power plant in Bulgaria were also exempt from local EIA procedures. However, for the biomass cogeneration plant in Croatia, UNIT conducted an environmental impact assessment, covering air, wastewater, and solid waste. As per ESAP Action No. 3, UNIT will review the latest E&S performance reports of these two companies to confirm that the E&S risks are managed in line with IFC Performance Standards or describing additional mitigation measures if needed.



For the Uni-Mar CCGT plant, UNIT retained Istanbul Technical University (Faculty of Civil Engineering) to carry out an environmental impact assessment (“Uni-MAR Enerji Yatirimlari A.S., Environmental Impact Assessment, Final Report, August 1994”). This EIA was approved by the Ministry of Environment on August 11, 1994. Uni-Mar is considering an option to increase the generation capacity of the plant as the period of BOT phase finishes in 2019. Uni-Mar will prepare and submit an EIA report if the capacity increase is above the limits defined in the local EIA regulation.



For Yeni Elektrik CCGT plant, UNIT retained a local consultant to carry out an environmental impact assessment (“900 MWe (1,580 MWt) Yeni Natural Gas Combined Cycle Power Plant Project, EIA Report, June 2010”). This EIA was approved by the Ministry of Environment and Urbanization on July 16, 2010. A separate EIA for the associated transmission li
ne was prepared by TEIAS (Turkish Electricity Transmissions Company) and this was also approved on December 22, 2011.



Furthermore, UNIT will establish an EHS due diligence procedure for all new assets against national requirements, IFC Performance Standards and the IFC/World Bank Group Environmental Health and Safety Guideline requirements, as per the ESAP Action No. 4.



Management Programs:



UNIT has obtained certification for ISO 9001 quality management system at its operations at the corporate level. The projects that UNIT owns or has shares in are certified against ISO 9001, ISO 14001 and OHSAS 18001 as described below:



Uni-Mar’s ESMS has been certified with ISO 14001:2004 (valid until 2015) and OHSAS 18001:2007 (valid until 2017) by NSF International Strategic Registrations. During the appraisal visit, it was observed that the ESMS is fully in place for the operations of Uni-Mar. Uni-Mar had an external audit by National Power Enerji for its Environmental and Occupational Health & Safety (OHS) management systems certified with ISO 14001 and OHSAS 18001 in 2013, no major or minor non-conformities were identified.



In Yeni Elektrik, studies for establishment of the ESMS have been started in 2013 and necessary applications for certification with ISO 9001, ISO 14001, and OHSAS 18001 are being made. Full certification is expected in late 2014 or early 2015. According to the findings of the appraisal, many plans and procedures are developed to ensure implementation of an appropriate ESMS except that more concentration on environmental issues is required in risk identification matrix.



Boyabat HEPP’s ESMS has been recently certified with ISO 9001:2008, ISO 14001:2004, OHSAS 18001:2007 and ISO 50001:2011 in April 2014 by TUV International Certification. A detailed risk assessment study has been done in October 2014 by an external consultant (AON Danismanlik Hizmetleri A.S.) for Boyabat HEPP operations. The study conducted an assessment of the power plant in terms of technical, occupational health and safety, fire safety and environmental risks. No major risks were identified by the study. The study provided recommendations mainly to further improve performance by continuing the current practice adopted at the plant.



Operations of Bagistas II are also recently certified with ISO 9001:2008, ISO 14001:2004, OHSAS 18001:2007 and ISO 50001:2001 in August 2014 by TUV International Certification. The certificates are valid until 2017.

At the time of the appraisal, there was no information received regarding the management system at Prolez WPP. UNIT will ensure that the operations of Prolez are undertaken in compliance with IFC’s PSs requirements as well as IFC/WBG EHS Guidelines as per ESAP Action No. 3 described above. Similarly, UNIT will ensure that the ESMS for the operations of Babina Greda be established as soon as the operation is started and ensure that the system is in compliance with the requirements of IFC’s PSs and WBG
EHS Guidelines as per ESAP Action No. 5.



Additionally, UNIT’s corporate level ESMS will be strengthened significantly as part of this investment so that a more systematic approach can be integrated into UNIT’s operations to ensure full compliance with the requirements of IFC’s PSs and WBG EHS Guidelines through above mentioned ESAP Actions No. 1, No. 2 and No.4.



Organizational Capacity and Competency:



There are no dedicated corporate level environmental, health and safety (EHS) officers at UNIT. At each plant there are either dedicated personnel with sufficient experience and education for managing environment and OHS issues or an external consultancy mobilized for this purpose, depending on the type and scale of the operations in place. Relevant issues are raised to the Technical Director and senior management at the project level. All EHS issues are forwarded to the Internal Audit and Risk Management department and raised in the board meetings or steering committee meetings if anything significant occurs.



As per ESAP item No. 6, UNIT will appoint or contract a dedicated (i) Quality, Environmental, Health and Safety Coordinator at corporate level, with relevant expertise and experience in managing E&S issues of company assets and (ii) Social Development Specialist for managing the social impacts and stakeholder engagement of the projects UNIT invests in and the overall corporate level social performance / stakeholder engagement / disclosure of information (e.g. corporate website, sustainability reports) of the portfolio projects.



UNIT will strengthen the coordination of environmental, health and safety training programs between at each of the invested projects and at corporate level and ensure that the contents and frequency are relevant to the type and scale of the project and in compliance with IFC’s PS requirements as per the attached ESAP Action No. 7.



Emergency Preparedness and Response:



Based on the appraisal information provided by UNIT, most of the company’s projects have emergency preparedness and response plans in various forms depending on the type and scale of the project risks. For example, at Boyabat HEPP, an Emergency Procedure was developed to cover the dam and HEPP project site and the central office in Istanbul. This procedure is supported by the list of emergency teams and equipment, and the evacuation plan prepared for the HEPP. The procedure includes the emergency situations such as fire, natural disaster (i.e. earthquake and flood), chemical spill and sabotage. The procedure defines the responsibilities of the emergency chief, control team, fire-fighting team, site security team, first aid team and rescue team. The procedure includes communication systems, emergency response methods, training needs and reporting requirements. The procedure also describes how internal and external communication will be provided during the emergency cases.



Similarly at Bagistas II HEPP, an Emergency Response Pl
an was developed in January 2014 by the plant management officers covering emergency cases such as fire, natural disasters and sabotage. In addition, as part of the OHS Risk Analysis conducted by Aksiyon Consultancy, an additional Emergency Response Plan was developed covering emergency situations including fire, occupational accidents and incidents, earthquake, sabotage, food poisoning, flood, chemical spills, working at height, collapse and demolition, machinery and equipment failure, explosion and flame, storm, and lighting and thunderbolt. Integration of these two plans is being conducted at Bagistas II HEPP.



UNIT will ensure that all the emergency preparedness and response plans are in place at UNIT invested projects in accordance with the requirements of IFC’s PSs as per ESAP Action No. 8.



Monitoring and Review:



Periodic and unplanned external and internal monitoring activities are conducted at each of UNIT’s plant operations. The findings are forwarded to senior management, mostly in the annual management review meetings. The consolidated results collected by the Internal Auditing and Risk Management department at the corporate level are discussed at board or steering committee meetings. UNIT will establish a corporate level E&S monitoring and review procedure covering definition of the flow of information from project level to corporate level, identification of key performance indicators (KPIs) to be followed up, targets and objectives set and review frequency of information etc in accordance with the requirements of IFC’s PSs as per ESAP Action No. 9.

As described under the Project Description, UNIT’s portfolio includes 3 major power plants (Boyabat HEPP, Yeni/Gebze CCGT, Uni-Mar CCGT) under operation plus 3 smaller power plants either under operation or commissioning. Boyabat HEPP has 39 staff (management, general admin, operation and maintenance team) and 18 security personnel. Yeni/Gebze CCGT has 37 operating staff (at O&M company – UNES) and additional outsourced staff providing logistics and support services. Uni-Mar has 38 staff (management, finance, administration including security) and 49 operating staff (at O&M company – National Power Enerji AS).



Human Resources Policies and Procedures:



UNIT’s operation to develop power generation projects and to manage investment performance is conducted by a small group of professional development professionals (currently 9 officers). Their tasks are supported by other UNIT Group employees and external consultants. UNIT has its own HR department which ensures that the company is in compliance with national Turkish labor requirements and standards. The HR department of UNIT also ensures that UNIT’s majority controlled investments comply with country laws and IFC Performance Standard 2. UNIT’s employees can raise concerns through the HR department. There are no workers’ organization at UNIT level, but UNIT does not prohibit employees to form one or to conduct collective bargaining. For UNIT’s majority controlled investments in countries where national law restricts workers’ organizations, UNIT will ensure that workers will not be restricted from developing alternative mechanisms to express their grievances and protect their rights regarding working conditions and terms of employment. Due to the characteristics of the power generation projects in the countries UNIT is considering, the risk of forced or child labor is low. As per ESAP Action No. 10, UNIT will review, and revise, if determined necessary, the existing HR policies and procedures, to confirm that IFC PS2 elements are adequately addressed not only for UNIT workers, but also workers of UNIT investee projects where the company is the majority stakeholder or has sufficient influence on project management. At Boyabat HEPP, UNIT informed IFC that there are pending court cases about third party workers during construction phase. UNIT is monitoring the status and will keep IFC informed through their Annual Monitoring Reports.



Occupational Health and Safety:



Based on the appraisal information provided by UNIT, no major OHS incidents have been reported during the last three years by UNIT investee companies. As per ESAP Action No. 11, UNIT will establish a consolidated occupational health and safety performance tracking system among UNIT investee companies to track OHS performance and identify areas for further improvement.

Resource Efficiency and GHG Emissions:



UNIT’s portfolio consists of high energy efficient gas-fired CCGT projects and renewable energy projects (large and small hydropower plants, a small wind farm, and small biomass-fired Circulating Fluidized Bed, or CFB plant). UNIT’s latest CCGT project (Yeni Elektrik 850 MW CCGT plant in Turkey) is designed to achieve 57.9 % net efficiency at Lower Heating Value basis, one of the highest efficiency rates of its category equipped with Air-Cooled Condensers cooling system. UNIT’s investment strategy is to focus on these kinds of power generation projects with high energy efficiency and thus better GHG emissions performance, or renewable energy projects with avoided GHG emissions. As per ESAP Action No. 12, UNIT will establish a corporate level GHG emissions estimation system to evaluate corporate average GHG emissions performance over time and to identify opportunities to further improve such performance.



Water:



Where water supply is scarce in the proposed CCGT project sites, UNIT applies an Air-Cooled Condensers cooling system which minimizes water consumption (e.g. at its Unit Zakho project in Iraq and Yeni Elektrik project in Turkey). As a private sector IPP project developer, UNIT supports project companies’ continual investment to maintain energy and water utilization efficiency of the existing units.



Pollution Prevention:



UNIT senior management explained to IFC that UNIT has a strategy to develop power generation projects in compliance with not only host country requirements but also good international industry practice, such as IFC/World Bank Group environmental, health and safety guidelines, including air emissions, liquid effluents, and noise control. For example, NOx emissions of UNIT’s recent CCGT projects (Yeni Elektrik CCGT plant under operation, and Unit Zakho CCGT project under development) are specified to fully comply with IFC / WBG NOx emission guideline limits for gas turbines (51 mg/Nm3 at 15% O2). All new investments developed from the time of IFC’s equity participation will be reviewed to confirm compliance with IFC Performance Standards and relevant EHS Guidelines, including pollution prevention and abatement measures.

Security Personnel:



Due to the security situation of the project site in Iraq, the Unit Zakho CCGT project will use armed security force during construction and operation of the project. To ensure that security personnel operate in accordance with the International Code of Conduct for Private Security Providers, the Unit Zakho project company is preparing and will be implementing a security force management plan (including necessary training programs). This was included in the Unit Zakho’s ESAP Action No. 8.



Security personnel arrangement by UNIT or its invested project companies differs according to the security situation of the project site. For example, at Yeni Elektrik CCGT, security personnel are employed directly by Yeni Elektrik and they do not have firearms. Whereas at Bagistas II HEPP, security personnel are provided by a contractor and they carry firearms. UNIT informed IFC that no major incidents occurred related to security personnel or use of firearms. For new projects, UNIT will follow the similar commitment as required for Unit Zakho project.



Dam Safety:



Dam safety design of UNIT’s two hydropower plants was reviewed at multiple stages of project development. For the Boyabat HEPP project, for example, the dam safety design review was conducted initially through feasibility studies conducted by DSI and their mobilized international experts, and once the project was decided to be developed as a private sector project, the Boyabat Elektrik contracted Engineering, Procurement and Construction (EPC) company to conduct detailed design of the plant including dam safety. As a private sector project, Boyabat Elektrik retained owners engineer (Su Yapi – Yapi Teknik, and Hidrodizayn plus Lahmeyer) to review and monitor the EPC company’s design and construction progress. And finally, lenders to the Boyabat HEPP project retained an independent engineer (Poyry plus Dolsar) and their review included dam safety design. For the Boyabat HEPP, operational phase dam safety monitoring is being conducted by Boyabat Elektrik and their monthly monitoring results are submitted to the General Directorate of State Hydraulic Work (DSI) which is responsible for analyzing results of dam safety monitoring and mitigation of any potential risks. While the analysis of results is conducted by DSI, the Boyabat HEPP staff have relevant experience and are capable of identifying potential risks and planning mitigation measures. As mentioned under PS1, Emergency Procedures / Emergency Response Plans are in place at both Boyabat HEPP and Bagistas II HEPP.



Other potential risks that UNIT is aware of: UNIT informed IFC that a NATO pipeline of about 380 m was inundated by the development of a reservoir at Bagistas II HEPP. The pipeline is managed by the Ministry of National Defense. UNIT conducted various site studies which concluded that the pipeline was within a concrete envelope and no community or environmental impacts were predicted due to
the reservoir formation.

Stakeholder engagement for each power project is conducted by the project development team (under development and construction) and by the project company or its contracted O&M team (under operation). Based on the appraisal information, no major issues related to stakeholder engagement for UNIT’s pipeline of power projects have been identified to date.

As described under PS1 section of this ESRS, consultation activities were held by the Turkish authorities and Boyabat Elektrik with respect to the land expropriation process and relocation of affected families for Boyabat HEPP. Stakeholder engagement activities led by Boyabat Elektrik expropriation manager are ongoing to settle the pending land acquisition court cases and the remaining relocation of affected families.

For the UNIT Zakho CCGT project which is under development by UNIT and their partner sponsor, the project company (UNIT & Polteks Limited) is conducting stakeholder engagement and disclosure of E&S information in line with IFC requirements. The project company prepared a Stakeholder Engagement Plan, including a grievance mechanism, before starting the ESIA process. Details can be found in the IFC ESRS for that project (#34482).

UNIT recognizes that the level of social impact assessment and stakeholder engagement practice needs to be strengthened to promote power generation projects in a more sustainable and systematic way. UNIT will establish a corporate level procedure for stakeholder engagement including identification and mapping of key stakeholders, procedures for disclosure of project information and associated consultation, and development of appropriately scaled grievance mechanism with respect to IFC PS1 requirements, as per the ESAP Action No. 13.

For additional information please contact:

Name: Mehmet Okten
Corporate Finance Manager
Company: UNIT Investment NVAddress: Nispetiye Caddesi, Akmerkez, Etiler, Istanbul, Turkey
Email: mailto:Mehmet.okten@unit.com.tr
Telephone: (+90) 212 319 1912
Website: http://www.unit.com.tr

For new investment in power generation assets, UNIT will require the project company to disclose the relevant E&S documents at local places accessible by project affected communities as appropriate.

For the existing investment, the following E&S documents were submitted to IFC for review. UNIT will make these documents available to the public upon request. IFC’s ESRS will also have the following E&S documents as attachments to the ESRS:

Boyabat Dam and Hydroelectric Power Plant, Environmental Assessment Report, 1998 (both the Executive Summary and the Main Report);
Yeni Elektrik Uretim A.S., 900 MWe (1,580 MWt) Yeni Natural Gas Combined Cycle Power Plant Project, EIA Report, June 2010;
UNI-MAR Enerji Yatirimlari A.S., Marmara Ereglisi Natural Gas Combined Cycle, B.O.T. Power Plant, Environmental Impact Assessment, Final Report, August 1994; and
Study Report on the Environmental Impact of Activity for Iprard Program Grant Funds – Measure 303, 9.99 MW Biomass Cogeneration Plant, Municipality of Babina Greda (no date).

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
No. 1 (PS1): UNIT will include E&S impact identification and management elements into UNIT’s Project Development Procedure in line with IFC Performance Standards. UNIT will provide a revised Project Development Procedure to IFC.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 2 (PS1): UNIT will strengthen their existing corporate environmental policy to include requirements of IFC Performance Standards. UNIT will provide a revised corporate E&S policy statement (signed by UNIT’s management) to IFC.	02/29/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 3 (PS1): UNIT will review the latest E&S performance reports of Prolez Wind Power Plant in Bulgaria and Univiridas/Babina Greda biomass-fired CFB power plant to confirm that the E&S risks are managed in line with IFC Performance Standards or describing additional mitigation measures if needed. UNIT will provide the review reports to IFC.	02/29/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 4 (PS1): UNIT will establish an EHS due diligence procedure for all new assets against national requirements, IFC Performance Standards and the IFC/World Bank Group Environmental Health and Safety Guideline requirements. UNIT will provide a copy of the EHS due diligence procedure to IFC.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 5 (PS1): UNIT will ensure that the ESMS for the operations of Babina Greda be established as soon as the operation is started and ensure that the system is in compliance with the requirements of IFC’s PSs and WBG EHS Guidelines. UNIT will provide documentation about the established ESMS to IFC.	04/30/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 6 (PS1): UNIT will appoint or contract (i) a dedicated Quality, Environmental, Health and Safety Coordinator at corporate level, with relevant expertise and experience in managing E&S issues of company assets and (ii) a Social Development Specialist for managing the social impacts / risks and stakeholder engagement of the projects UNIT invests in and the overall corporate level social performance / stakeholder engagement / disclosure of information (e.g. corporate website, sustainability reports) of the portfolio projects. UNIT will provide CVs of the appointed or contracted officers with required qualifications to IFC.	04/30/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 7 (PS1): UNIT will strengthen the coordination of environmental, health and safety training programs between at each of the invested projects and at corporate level and ensure that the contents and frequency are relevant to the type and scale of the project and in compliance with IFC’s PS requirements. UNIT will provide documentation describing the strengthened coordination to IFC.	02/29/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 8 (PS1): UNIT will ensure that all the emergency preparedness and response plans are in place at UNIT invested projects in accordance with the requirements of IFC’s PSs. UNIT will provide a list of all the emergency preparedness and response plans to IFC.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 9 (PS1): UNIT will establish a corporate level E&S monitoring and review procedure covering definition of the flow of information from project level to corporate level, identification of key performance indicators (KPIs) to be followed up, targets and objectives set and review frequency of information etc. in accordance with the requirements of IFC’s PSs. UNIT will provide the established procedure to IFC.	06/30/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 10 (PS2): UNIT will review, and revise, if determined necessary, the existing HR policies and procedures, to confirm that IFC PS2 elements are adequately addressed not only for UNIT workers, but also workers of UNIT invested projects with majority stakeholder. UNIT will provide the reviewed HR policies and procedures to IFC.	02/29/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 11 (PS2): UNIT will establish a consolidated occupational health and safety performance tracking system among UNIT invested companies to identify areas for further improvement. UNIT will provide the established tracking system to IFC.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 12 (PS3): UNIT will establish a corporate level GHG emissions estimation system to evaluate corporate average GHG emissions performance over time and to identify opportunities to further improve such performance. UNIT will submit the established system to IFC.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 13 (PS1): UNIT will establish a corporate level procedure for stakeholder engagement including identification and mapping of key stakeholders, procedures for disclosure of project information and associated consultation, and development of appropriately scaled grievance mechanism with respect to IFC PS1 requirements. UNIT will provide the established procedure to IFC.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 14 (PS5): UNIT will commission Supplemental Resettlement Action Plans for each of the two hydroelectric sites to: summarize the nature (i.e. physical vs economic displacement) and magnitude of historic and ongoing displacement; provide maps showing the locations of the original and new villages; summarize the expropriation steps undertaken by EMRA; summarize the types and amounts of compensation / resettlement assistance provided to affected parties; summarize outstanding compensation and relocation actions required at each site and undertake a limited stakeholder engagement/sampling exercise involving representatives of the main affected communities to determine whether, in general, compensation and support has been sufficient to allow affected families to re-establish their homes and livelihoods. Based on this information, the SRAPs will identify and prioritize in kind supplemental measures which need to be implemented to mitigate any major residual or ongoing social impacts caused by the resettlement process, prioritizing the most vulnerable households and those who have yet to receive compensation or replacement housing. The SRAP will also formalize a grievance mechanism for affected parties to raise resettlement related complaints to the relevant authorities and/or project companies.	03/31/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
No. 15 (PS5): UNIT will develop and apply to its new projects a new Land Acquisition and Involuntary Resettlement Procedure consistent with IFC PS 5 requirements, including a land acquisition and resettlement-related grievance procedure.	02/29/2016 12:00:00 AM	In Progress	Due date revised as agreed with IFC client