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
The project is not expected to have significant adverse effect on Indigenous Peoples, therefore, PS7 – Indigenous Peoples is not applicable to this project. PS5 – Land Acquisition and Involuntary Resettlement and PS8 – Cultural Heritage have also not been identified as relevant to the project. If these Performance Standards become applicable, KTDA Power shall update its policies and procedures to manage these aspects.

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability. The environmental and social risks and impacts associated with this project are limited, site-specific and can be readily addressed through generally accepted mitigation measures as described in this document and the attached Environmental and Social Action Plan (ESAP).

The potential environmental and social risks and impacts associated with this project relate to: (i) adequate assessment of social and environmental risks and impacts during the construction phase as well as plant operations in accordance with local requirements and IFC Performance Standards; (ii) occupational health and safety as well as labor and working conditions of employees, including contractor employees; (iii) management of social, environmental and safety performance by the engineering, procurement and construction contractors; (iv) biodiversity management and water quality management; (v) land acquisition; (vi) engagement with project stakeholders and management of community health and safety and emergency response; and (vii) management of wastes and emissions.

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.

IFC’s assessment considered KTDA Power’s approach to management of its environmental, social and occupational, health and safety performance; compliance with Kenyan environmental permitting requirements; and public engagement and disclosure of information about its operations.



Environmental and Social Assessment and Identification of Risks and Impacts: In line with The Environmental Impact Assessment and Audit Regulations 2003 of the Environmental Management and Coordination Act (EMCA) 1999, environmental impact assessment (EIA) studies were conducted for six of the seven SHP projects between 2009 and 2014 – Lower Nyamindi, Iraru, South Mara, Nyambunde, Kipsonoi and Kiringa. The reports were submitted to the National Environmental Management Authority (NEMA) and environmental approvals (and renewals) have been granted for these projects. The EIAs identified the potential direct and indirect environmental and social impacts of the project from construction to operations and decommissioning, as well as the impacts of associated facilities such as transmission lines. The EIAs included the associated management plans – Environmental Management Plan (EMPs) – to manage these impacts. In line with the requirements of the EIA regulations, public consultation and participation was included in the process. The EIAs however did not cover the biodiversity impacts in the rivers and ecological flow assessments; these aspects are further discussed under Performance Standard 6. The EIA was conducted in line with the requirements of Kenyan Laws but did not cover the IFC Performance Standards; thus gaps related to the Performance Standards are discussed in subsequent paragraphs and addressed in the project ESAP. The EIA for the Nyamasege SHP is yet to be completed; as indicated in the ESAP, this EIA shall be completed in line with the Performance Standards and local EIA requirements in Kenya.



The EIAs included management plans for each project and each EPC contractor is required to comply with local E&S requirements and develop and implement a project Environmental Health and Safety (EHS) Plan for the construction phase; the plan is to be reviewed and approved by KTDA Power. EHS Plans have been developed for projects currently under construction – South Mara, Iraru and Lower Nyamindi. KTDA Power shall also ensure that all other EPC contractors develop appropriate EHS plans which meet the requirements of the Performance Standards for all projects.



The SHP projects required land acquisition for the project sites (intake, canal, penstock and powerhouse) and the transmission lines; a total of 38 hectares has been acquired for the first six sites. The social assessments conducted for the projects documented the livelihoods of the local communities, particularly the farming activities. The designs of the projects considered options to minimize the need for extensive land acquisition; where applicable, the project footprint has been altered to avoid lan
d that was not available for acquisition. Where applicable, compensation was paid to land owners that would be temporarily affected by the project; In addition, beyond the value of the land, compensation was also paid to permanently affected land owners for the crops on their plots of land. The land acquisition and compensation process involved extensive consultation with the land owners (mostly KTDA farmers) and the local administrative authorities and requisite national agencies. Compensation and land rates have been agreed and paid for the parcels of land and crops, and resettlement agreements have been reached for the cases where cash payments were not appropriate due to cultural sensitivities. There are a few parcels of land which have not been acquired and are pending the resolution of land titles issues within the affected families. As indicated in the ESAP for this project, KTDA Power shall provide a final land acquisition and compensation report summarizing the details of the land parcels and compensation paid to all land owners for all project sites.



For the remaining site (Nyamasege) as well as future projects, KTDA Power shall develop a Land Acquisition and Resettlement Framework for managing future land acquisition.



Management Programs: During the construction phase, the EPC contractors will be responsible for the E&S management programs. As indicated in the ESAP for this project, KTDA Power shall ensure that all EPC contractors develop adequate procedures and plans for the management of identified risks and impacts. For the operational phase of the project, KTDA Power will develop management programs and associated plans and procedures to address the risks and impacts identified, including procedures related to OHS, air emissions and solid management; these will be included in the ESMS referenced above. The programs and plans shall be implemented for each SHP by the relevant RPC.



KTDA Power has not yet developed an Environmental and Social Management System (ESMS) and the associated operational procedures. Whilst KTDA has an ESMS, this does not cover the activities of KTDA Power. In line with the requirements of this Performance Standard, KTDA Power will be required to develop an ESMS consistent with the requirements of this Performance Standard and ISO 14001, to cover the development, construction and operations of future projects. KTDA Power shall ensure that in relation to the operations, each RPC adopts this ESMS to ensure that all SHP projects are implemented in accordance with Kenyan regulatory requirements and the IFC Performance Standards; this requirement is included in the ESAP.



Organizational Capacity: For KTDA Power, EHS matters are handled by the project design and construction unit. In addition, there’s a Social Specialist at KTDA who provides support to KTDA Power on social matters. For each construction project, the KTDA-appointed Project Engineer will have the overall responsibility of ensuring
compliance with EHS requirements. The Project Engineer is responsible for ensuring that all EPC contractors and sub-contractors comply with the project’s EHS requirements. For the projects under construction, each EPC contractor has an EHS Officer and a Community Liaison Officer (CLO). KTDA Power shall ensure that all other EPC contractors have adequate organizational capacity to manage EHS matters.



For the operations phase of these projects and subsequent projects, adequate EHS capacity will be put in place. At the corporate level, KTDA Power shall appoint an EHS Manager to oversee the implementation of the ESMS and management of OHS matters; and EHS Officers shall also be appointed for each RPC. KTDA Power will be required to formally confirm the appointment of the persons responsible for EHS issues before operations start. This has been defined in the project ESAP.



Emergency Preparedness and Response: For the projects under construction, each EPC contractor has an Emergence Response Plan (ERP) incorporated into the project EHS Plan; the emergency scenarios covered include – fires, explosions, medical emergencies, spills, structural collapse and security breaches. KTDA Power shall ensure that all other contractors develop appropriate ERPs. For the operational phases of the SHP projects, KTDA Power will be required to develop an ERP and incorporate this into the ESMS for each project.



Monitoring and Review: During construction and operations all parameters that require monitoring in line with local regulations and WBG EHS guidelines will be monitored as to be defined by the ESMS (and as defined in the project EMPs). During the construction phase, in line with local requirements, monitoring data and reports will be provided to NEMA as required. KTDA and its associated factories conduct annual environmental audits and annual reports are submitted to NEMA. Similarly, during operations, environmental compliance audits will be conducted annually by KTDA Power/RPCs and reports provided to NEMA. KTDA Power will define key performance indicators (KPIs) in order to monitor EHS parameters such as Lost Time Incidence Frequency Rate (LTIFR); accident free days; carbon emissions, water quality and air emissions. In addition, the EHS Manager/Officer to be appointed will define an integrated EHS report to cover key EHS KPIs and present it to senior management for review. These EHS KPIs shall include: compliance with legal and regulatory requirements; EHS management system progress report; air emissions, solid and liquid waste management, compliance with national OHS requirements, community complaints, and community engagement activities as applicable. This has been included in the ESAP.

Stakeholder Engagement: Stakeholder engagement was included as part of the project EIA process for the first six projects; the EIAs followed the public consultation process as defined by the local regulations in Kenya. The identified stakeholders included
national regulatory authorities, regional administrative authorities, and affected communities. The EIAs included consultation sessions with these stakeholders to discuss the proposed projects and identify and address concerns raised by these stakeholders; the issues raised by the stakeholders include – impacts of the project on water and land use; environmental pollution; employment opportunities for communities; potential health impacts; protection of the workforce; potential benefits from the project (power for the communities) and obtaining necessary approvals from relevant authorities. These issues was factored into the project design and the EMPs. In addition, socio-economic assessments were conducted for all locations to establish a baseline of indicators for affected communities. It is noted that the projects are located in KTDA farmer communities and as such, there is significant support for the project due to the cost savings expected at the KTDA factories following the implementation of the SHP projects. KTDA Power will be required to develop a Stakeholder Engagement Procedure which meets the requirements of Performance Standard 1 for subsequent projects. Additional aspects of community engagement are covered in subsequent paragraphs in this environmental and social review summary.



External Communications and Grievance Mechanism: EPC contractors shall be responsible for managing any grievances during the construction phase. KTDA Power shall ensure that each EPC contractors EHS Plan includes a grievance procedure. For the operations phase, as covered in the ESAP for this project, KTDA Power shall develop an ESMS which includes a grievance mechanism which shall be applied to all projects. Each project has a Community Chairperson elected by the community to liaise with KTDA Power and the EPC contractors; grievances would typically conveyed through the Community Chairperson.

IFC’s review considered KTDA Power’s operations with regards to fair, safe and healthy working conditions and is based on an assessment of the practices in place, and a review of the documents, and information made available during due diligence process.



When fully operational, the seven SHP will employ approximately 60 staff. During construction, the number of employees is expected to peak at 300 for each project. It is expected that a substantial number of employees will be recruited from the local community for each project. No workers’ accommodation is planned for the projects in construction phase. For future projects, where applicable, the EPC contractors for the other projects shall develop workers’ accommodation which meet internationally recognized standards such as those specified in the IFC/EBRD guidance document on workers’ accommodation.



Human Resources Policy and Management: During the construction phase, contractor employees will be subject to the HR policies of the individual contractors. All contractors are required to comply with local regulatory requirements. KTDA Power shall ensure that each contractor’s policy complies with the requirements of Kenyan Labor Laws and this Performance Standard particularly in relation to fundamental principles of the rights at work.



All KTDA subsidiaries are covered by the KTDA Group HR Policy. Where applicable, each subsidiary may amend sections of the HR Policy to reflect the unique requirements of the sector in which it operates. The KTDA Group Policy covers aspects such as terms of employment, working hours, recruitment, performance management, salaries and benefits as well as training. The terms and conditions of employment stated in the HR Policy meet, at a minimum, the wage scales and benefit entitlements established by the Kenyan Ministry of Labor, the National Employment Act, Labor Relations Act and Regulation of Wages Act, which themselves are consistent with, at a minimum, the Core Labor Standards established by the International Labor Organization. All staff are entitled to medical cover for themselves and their dependents and all permanent staff are covered by the Group life insurance scheme. In line with local law, Employment Act 2007, KTDA does not employ minors; the minimum age for recruitment is 18. In addition, the company does not employ any form of forced labor.



Worker’s Organization: There are no restrictions to forming or joining unions at KTDA. Non-management employees of KTDA are members of Kenya Plantation and Agricultural Workers Union (KPAWU) Union. There is a collective bargaining agreement between the KPAWU and KTDA; the terms of the agreement are reviewed on a regular basis. As with all other KTDA operations, during the operation phases of the SHP projects, KTDA Power shall allow freedom of association in line with the requirements of this Performance Standard.

Non-Discrimination and Equal Opportunity: As provided for in the Employment Act 2007
, KTDA does not discriminate against any persons in any aspects of its operations. The HR Policy includes recruitment procedures, disciplinary procedures, grievance procedures and training and development procedures which are applicable to all employees.



Occupational Health and Safety (OHS): KTDA has a Health and Safety Policy. KTDA’s health and safety policy and practices are formulated to fulfill the requirements of Kenyan Health and Safety Legislation, in particular the Occupational Safety and Health Act (OSHA), 2007. All KTDA/KTDA Power contractors are required to comply with local regulatory requirements on OHS (Occupational Health and Safety Act 2007).



The potential OHS risks related to the construction phase of this project are typical of construction projects; these include – working at height, use of heavy equipment, use of explosives, exposure to electricity cables, exposure to dust and noise and traffic management on site. As highlighted in the EMPs for the SHP projects and associated EHS Plans, these risks can be managed through the implementation of adequate OHS procedures and provision of adequate PPE and training to employees. The EHS Plans cover hazard identification, risk assessments and the procedures for managing these risks. For the construction phase of the KTDA Power projects, KTDA Power shall ensure that adequate PPE and training are provided to contractor employees and the EMPs and EHS Plans are implemented accordingly. KTDA Power shall also ensure that all EPC contractors record and report incidents and accidents. One injury was reported to the local authorities in June 2015 by JWHC at one of the first three SHPs (not included in this project).



The typical OHS risks during operations include working with machinery, noise, and lifting of heavy materials. As highlighted in the EMPs for the projects, these risks can also be managed through the implementation of adequate OHS procedures and provision of adequate PPE and training to employees. KTDA Power has not yet established OHS procedures. The requirement to develop and implement these procedures is included in the ESAP for this project; KTDA Power will be required to develop and implement OHS procedures that meet the requirements of OHSAS 18001 and Performance Standard 2. During operations, KTDA Power shall provide appropriate PPE for all employees and provide the required training to ensure that employees work in a safe manner.



Third Party Workers: As set forth in the ESAP, KTDA Power will develop and implement a procedure to ensure contractors’ labor and working conditions, including those related to OHS, and need for a grievance mechanism, comply with the requirements of this Performance Standard and Kenyan Labor Laws.

IFC’s review considered KTDA Power’s management of its operations, resource use and waste disposal procedures and the impacts on the surrounding human and natural environment. The review focused on available information and estimates provided by KTDA Power.



This is a renewable energy project which is expected to have a net positive impact by replacing fossil fuel in power generation. These SHPs have been developed as part of KTDA’s strategy to move away from fossil fuel consumption and also reduce consumption of biomass for generating electricity at the tea factories, thereby reducing carbon emissions and reducing production costs; KTDA Power estimates that the seven projects will result in a reduction of 63,334 tons of carbon emissions per year.



Construction activities will include excavation, minimal blasting, drilling, and crushing of aggregates, brickwork and erection of structures. Potential pollution issues during the project’s construction phase will be those typically associated with construction sites including – the discharge of contaminated soils, diesel and oil spills, dust and noise emissions, water pollution etc. During operations, the issues include management of waste oil and other fluids, water pollution, and noise emissions; these impacts need to be adequately managed. Potential impacts during the construction phase can be largely mitigated through effective implementation of the EMPs and EHS Plans associated with these projects; additional measures have been included in the ESAP for this project as indicated in the paragraphs below. Furthermore, KTDA Power shall develop and implement air emissions, noise and water quality monitoring programs compliant with the WBG General EHS Guidelines; this is also included in the ESAP for this project. The data from the monitoring program shall be reported on annual basis to IFC.



Pollution Prevention: Air emissions from the project will primarily be dust/particulates from the construction phase and fugitive emissions from equipment during construction and operations. As covered in the project EMPs, dust suppression measures will be implemented during the construction of the plant to minimize impacts. Noise pollution is expected from the project during construction especially during excavation, blasting and drilling. As detailed in the EMPs and EHS Plans, KTDA Power shall ensure that appropriate measures are taken to minimize noise emission from the sites and construction activities will be limited to daytime (8am to 5pm). Noise pollution during operations will be mostly limited to the power houses; all employees will be provided with adequate ear protection to minimize noise impacts.



Effluent Management and Water Pollution: Effluent from the construction phase will be limited to the sewage and kitchen wastes which will be discharged to septic tanks; the tanks will be emptied by local county authorities as required. Impacts associated with turbidity due to suspended solids a
nd sediment loads as result of construction works involving earth removal and blasting in the project sites, may affect the water quality of the rivers. Measures to minimize water pollution from soil erosion are also included in the EMPs for the projects.



Solid Wastes: KTDA shall ensure that the EHS Plans for the construction projects cover the management of wastes. Construction wastes such as domestic waste, inert waste (rubble, spoil) recyclables (plastics, paper, metals) and small quantities of oil and oil-contaminated material are to be sorted on site and collected by local county authorities for disposal. During operations, solid wastes will also be collected by the local county authorities. KTDA Power will be required to develop a Waste Management Procedure (WMP), as part of the operating procedures for the project sites; this is included in the ESAP for this project.

IFC’s review considered the potential impacts of KTDA Power operations on the local community in the various locations. The assessment is based on the documents provided for review by KTDA Power and the observations made during the site visit.



Community Health and Safety: The projects sites are typically located within 100m of farm plots and/or households. The projects have been designed to meet recognized industry standards so as to minimize potential impacts on the community. The socio-economic assessment for the projects revealed no significant trend in diseases and the projects are not expected to lead to an increase in any disease; influx of migrant workers will be limited as most of the employees are expected to be recruited from the local communities and foreign workers will be limited to a handful per site. Medical facilities will be available on each construction site and HIV/AIDS awareness campaigns will be included in the training sessions for all employees.



Impacts on community safety during construction shall be addressed through the mitigation measures identified in the EMPs. Adequate provisions shall be made to inform community members about hazardous activities; the CLO and Community Chairperson are responsible for informing community members in each location about the potentially dangerous operations and the safety measures to be adopted by community members. The EHS Plans for the first three SHP sites include traffic management plans to manage potential impacts on the community. KTDA Power shall ensure that all other EHS Plans include appropriate measures for the protection of the community.



Security Personnel: During construction and operation, site security will be managed by private security firms which will provide trained unarmed security personnel; where required, additional support will be provided by local police. KTDA Power shall ensure that the security contractors comply with local regulatory requirements as well as the requirements of this Performance Standard; as indicated in the ESAP, KTDA shall develop standard terms of reference for security personnel that will be used during the construction and operations for each site.

IFC’s review covered the protection and conservation of biodiversity within the project sites; the assessment is based on the documents provided for review by KTDA Power.



Biodiversity issues relate to impacts of the SHPs on existing flora and fauna in the different locations. Hydropower projects can have significant impacts on the river flow, thereby leading to reduced biodiversity; hydro projects can also impact aquatic system connectivity and migration of species. The EIAs for the six projects considered the potential impacts on terrestrial flora and fauna; a diverse amount of plant and animal species were identified in the project areas with the dominant plant being tea as the projects are located in the tea-producing areas. In general, the project sites are considered modified habitats which have been modified through agricultural use and other human activities. There were no endangered terrestrial species identified during the EIA and no area was identified as a critical habitat.



The EIAs did not include biodiversity assessments for the rivers and ecological flow assessments. As indicated in the ESAP for this project, biodiversity monitoring will be required for the first six projects during the construction phase as well as during operations. For the Nyamasge project, the EIA shall include a detailed biodiversity assessment for the river as well as ecological flow assessment. The EIA shall also cover the potential cumulative impacts of the Nyabunde and Nyamasege SHPs on the River Gucha.



As previously mentioned, the EIA did not include ecological flow assessments; the projects were based on ecological flows of 10-15% of the minimum monthly flow of the rivers. It is noted that water use permits for these projects have been issued by the Water Resource Management Authority (WRMA), an indication that the selected flows meet local requirements.



Ecosystems Services: The rivers where the SHPs will be located provide domestic water and irrigation water for local communities; the projects are not expected to have any impacts on any provisioning or regulating services provided by the rivers. The other users were taken into consideration in the design of the projects as well as in the permitting process conducted by WMRA. The design of the projects were based on low water demand and adequate ecological flows shall be allowed in order not to significantly alter the natural flows of the river to minimize impacts on downstream users.

KTDA Power’s SHPs project provide a unique scenario for community engagement as a significant majority of the affected community members are KTDA farmers who are the ultimate beneficiaries of the SHP projects. As owners of the factories, initial consultation meetings were held at factory level with the KTDA farmers to secure the buy-in and approval required to commence the SHP projects. The overwhelming support of the farmers led to the development of these projects.

Stakeholder engagement was included as part of the project EIA process for the first six projects; the EIAs followed the public consultation process as defined by the local regulations in Kenya. The identified stakeholders included national regulatory authorities, regional administrative authorities, and affected communities. The EIAs included consultation sessions with these stakeholders to discuss the proposed projects and identify and address concerns raised by these stakeholders. In addition, socio-economic assessments were conducted for all locations to establish a baseline of indicators for affected communities. As noted previously, the projects are located in KTDA farmer communities and as such, there is significant support for the project due to the cost savings expected at the KTDA factories following the implementation of the SHP projects.

Each project has a Community Chairperson elected by the community to liaise with KTDA Power and the EPC contractors; grievances are typically conveyed through the Community Chairperson.
EPC contractors shall be responsible for managing any grievances during the construction phase. KTDA Power shall ensure that each EPC contractors EHS Plan includes a grievance procedure. For the operations phase, as covered in the ESAP for this project, KTDA Power shall develop an ESMS which includes a grievance mechanism which shall be applied to all projects.

Community projects have been identified at the various projects sites through consultations with the communities and these projects will be implemented as applicable by the EPC contractors and/or KTDA Foundation, KTDA’s vehicle for coordinating and delivering Corporate Social Responsibility projects across the Group.

This ESRS document and the associated ESAP will be available at KTDA Power Limited:

Contact Person: Mr. Lucas Maina
Address: Kenya Tea Development Agency House
Nairobi
Kenya
Email :mailto:info@ktdateas.com
Tele phone No.:+254-020-3227000,2221441-2

Broad Community Support is not applicable for this project

KTDA Small Hydro(36402) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Environmental & Social Management System (ESMS): Design and implement an Environmental and Social Management System consistent with ISO 14001, and IFC Performance Standard 1. The ESMS shall cover project development, construction and operations (to be adopted by the RPCs for operations). The system shall define roles and responsibilities, and other necessary elements (manual of procedures) to enable all operations to comply with Kenyan laws and regulations, IFC Performance Standards and the applicable World Bank Group Environmental, Health and Safety Guidelines. The systems shall include but not be limited to: • Emergency Preparedness and Response Plans; • External Communications Procedure and Grievance Mechanism; • Waste Management Procedure; • Key Performance Indicators to monitor EHS performance; and • Stakeholder Engagement Procedure	14-Dec-2015	Completed	Completed	8/31/2017
Organizational Capacity Appoint a suitably qualified EHS Manager to implement the ESMS defined above, as well as EHS Officers for each RPC.	14-Dec-2015	Completed	Completed	8/31/2017
Terms of Reference for EIAs Develop generic terms of reference for environmental and social impacts assessments (ESIAs) of future projects (including Nyamasege SHP) that meet the requirements of the Performance Standards. These terms of reference shall cover, amongst other aspects, the Performance Standards, Kenyan EIA requirements, biodiversity assessments and ecological flow assessments and social issues.	14-Dec-2015	Completed	Completed	8/31/2017
Environmental Health and Safety Standards for Construction Phase Develop standard specifications and/or procedures for environmental and social risks and impacts related to construction to be included in invitations to tender for construction works and implemented by EPC contractors, including the development of EHS Plans which meet the requirements of the Performance Standards.	14-Dec-2015	Completed	Completed	8/31/2017
Provide a final land acquisition and compensation report summarizing the details of the land parcels and compensation paid to all land owners for all project sites.	14-Dec-2015	Completed	Completed	8/31/2017
Develop a Land Acquisition and Resettlement Framework	14-Dec-2015	Completed	Completed	8/31/2017
Occupational Health and Safety Develop and implement Occupational Health and Safety (OHS) policies and procedures for the operational phase (to implemented by the RPCs) demonstrating compliance with WBG’s EHS Guidelines, Performance Standard 2 and OHSAS 18001. The policies and procedures should include: • Identification of managers/persons responsible for OHS performance; • Training Programs; and • Workplace Monitoring.	01-Jan-2019	In progress	Due date revised as agreed with IFC Client
Third Party Workers Develop and implement a procedure to ensure contractor’s labor and working conditions comply with Performance Standard 2: Labor and Wording Conditions.	14-Dec-2015	Completed	Completed	8/31/2017
Monitoring Program Develop and implement an emissions monitoring program for monitoring emission parameters at all sites during operations.	01-Jan-2019	In progress	Due date revised as agreed with IFC Client
Develop generic terms of reference for security contractors which meet the requirements of Performance Standard 4.	14-Dec-2015	Completed	Completed	8/31/2017
Develop and implement aquatic biodiversity monitoring programs for Lower Nyamindi, South Mara, Iraru, Kipsonoi, Nyambunde and Kiringa and develop terms of reference for the biodiversity assessment for Nyamasge. The monitoring program and the terms of reference for the Nyamasege assessment shall be submitted to IFC for review and approval.	30-Sep-2018	In progress	Due date revised as agreed with IFC Client