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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
No land acquisition is expected as part of this project. The construction of the Aurora plant is taking place within a lot previously owned by the Company which was acquired on a willing seller - willing buyer basis. Therefore, PS 5 “Land Acquisition and Involuntary Resettlement” is not considered applicable.

Although Ecuador hosts important Ecoregions that has been threatened by the deforestation process, including the Napo Moist Forests, Cordillera Real Montane Forests and Andean Montane Forests, dairy production is a secondary activity within the farms and it is not a driver for deforestation process. The ecological survey conducted as part of the ESIA showed that there were no flora or fauna species of particular importance on the project site and the results revealed that the vegetation has had anthropogenic alterations. In addition, Toni’s supply chain activities are not taking place on the deforestation frontier and the supply chain expansion strategy is to increase the source of milk from the coastal area, which is a consolidated area of agriculture. In addition, Toni has been implementing a policy to increase the productivity of milk production by hectare used. If at any time, Toni considers expanding its supply providers beyond the current identified areas, it will, prior to initiating such operations, inform IFC and develop a screening process, satisfactory to IFC, to identify possible impacts from supply chain activities in environmental sensitive areas and propose applicable mitigation measures. This will be managed under its PS1 compliant Environmental and Social Management System. Therefore, PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable.

Toni will use the collected information in the ESIA ecological survey to recreate the biological conditions in a 5 ha set-aside area within the 17 ha of Toni’s property where the Aurora plant is being built. When acquired, the 17 ha lot was already significantly intervened and completely void of any flora and/or fauna, however, Toni has decided to reclaim 5 ha of its own land for which it has installed a nursery to grow native species needed for the population of this area.

The Aurora plant and a near housing development are separate by an open channel that, as agreed with the local environmental authorities, Toni will convert into a mangrove.


Furthermore, the project’s area of influence is located in areas absent of communities that would be considered as ‘Indigenous’ as defined by the World Bank Group, thus PS 7 - Indigenous People is not considered applicable. Archaeological and historic sites were not found within the project site’s boundaries, thus PS8 - Cultural Heritage will not apply.

Key environmental and social impacts associated to this type of operation include environmental and social management, air emissions, liquid effluents, workplace noise and chemicals exposure, handling of hazardous materials, supply chain, and community related impacts.

The proposed investment qualifies as a Category B project as defined by IFC’s Environmental and Social Sustainability Policy (2012) because of potentially limited environmental and social impacts that may result from the expansion and operation of the existing facilities, all of which can be avoided or mitigated by adhering to generally recognized good practices and design criteria. The company has objectives and plans that seek to address environmental and social risks and impacts in accordance with Ecuadorian laws and relevant IFC Performance Standards (PS), including the applicable elements of the World Bank Group (WBG) General Environmental, Health, and Safety (EHS) Guidelines; the EHS Guidelines for Dairy Processing; and 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.

Environmental and Social Assessment

Prior to the construction of the Aurora plant, Toni conducted an environmental and social impact assessment (ESIA) consistent with local regulation requirements, including an environmental and social baseline and impact assessment, as well as mitigation measures along with an environmental management plan. As part of the licensing process, the Ecuadorian environmental authorities required Toni to conduct public consultation prior completing the ESIA. The company conducted public hearings as required by the local Ecuadorian laws. The public hearings received overall community approval; however, they mainly rose job expectations. The public consultation process conducted satisfies IFC requirements.



After the completion of the ESIA, instead of building the dairy manufacturing facility presented in the ESIA, Toni decided to update the project by building an integrated complex having both the dairy and ice-cream operations on the same site. Thus, Toni is being required to review, upgrade and submit to IFC a copy of the updated ESIA, as indicated in the ESAP, reflecting the potential additional impacts and needed mitigations to ascertain the plant will operate in accordance with the IFC social and environmental requirements. Once obtained, Toni will provide a copy of the Ecuadorian environmental operational license to IFC as indicated in the ESAP.



Management Program

Toni has in place a certified EHS Management system (ISO 14000, ISO 9001, BMP and HACCP) that includes a policy establishing management commitment, assessment of environmental impacts, continuous performance review, training, monitoring, and reporting. The system includes occupational health and safety (OHS) risk prevention; and health management, solid waste and liquid effluent management, and resource use management programs. Toni is further enhancing its OHS program to include hearing protection and ergonomic programs. The food safety management system (HACCP) includes hazard analysis, identification of critical control points, establishment of critical limits for each critical control point, monitoring requirements, definition of corrective actions, and recordkeeping logs, among other aspects. Toni’s OHS management program is consistent with the OHSAS 18001 standard requirements.



The EHS management system in place extends to the contractors; for the construction of the Aurora plant, it developed and required the contractor to comply with specific EHS requirements and established monitoring procedures to oversee the EHS performance of the contractors. It also assigned dedicated EHS personnel to conducts periodic EHS audits to oversee EHS training, use of PPEs, accident/incident rates, and air emissions, noise, liquid effluents controls, among others.



Organization

Toni, PESA and Topsi have personnel dedicated to oversee the EHS aspect of the operations. However, now that the company is building the Aurora plant and it is ext
ending its EHS and social management practices to the milk collection centers, distribution centers, and transportation and logistics, Toni Corp will increase the number of EHS qualified personnel. In addition, it will appoint qualified personnel to handle community related aspects. Details of the new organizational structure will be submitted to IFC as indicated in the ESAP.



Training

Toni, Topsi, and PESA provide basic EHS training for all workers as part of their induction program. In addition, it also provides other specific trainings, on a need basis, such as training for working in confined spaces, working at heights, working with electrical devices and for the boilers operators. These programs as others as needed will be extended to the Aurora plant and business supporting activities.



Monitoring and Reporting

Toni, Topsi, and PESA monitor relevant E&S aspects such as wastewater quality, water consumption, energy consumption, boiler fuel consumption, waste generation, and accident rates. It also conducts periodic environmental as well as OHS audits and inspections. These programs will be extended to the Aurora plant and its business supporting activities such as distribution, transportation, and milk collection. Toni, Topsi, and PESA report relevant mandatory E&S indicators to the competent authorities (e.g. solid wastes, hazardous wastes, wastewater, and accident rates) and also reports internally, to Senior Management, selective E&S performance indicators, such as production loss, energy efficiency, wastes, accidents rates auditing results and corrective actions completeness.



Engagement, Communications and Grievance Mechanisms

Toni has yet to determine and inform to IFC, as indicated in the ESAP, who will manage the external communications and overall engagement with project stakeholders for the Aurora plant. It is expected that the external communications will involve keeping the stakeholders informed of the company’s growth strategy and operations; engagement with stakeholders and communities will take place in an open and transparent manner. The Aurora plant operations are located in an industrial area that borders the Colonia San Nicolas community that contains approximately 200 families and also a new housing development that is separated from the Aurora plant by a channel. This channel will be transformed into a mangrove as agreed with the local authorities.



Toni has yet to develop a grievance mechanism (GM) for communities, for collecting or addressing concerns or complaints from local or directly affected communities. The company will develop and implement a GM scaled to the risks and adverse impacts of its operations to receive, record and when appropriate facilitate resolution of affected communities’ concerns and grievances about Toni’s environmental and social performance in alignment with PS 1 requirements. A copy of the GM will be submitted to IFC as indicated in the ESAP. The mechanism will include:
(a) methods of communication about the mechanism to communities (i.e. existence of the grievance mechanism); (b) means to present the grievances, process of resolution, etc.; (c) process of receiving and registering grievances/ complaints; (d) assessment and categorization of grievances; (e) prioritization and hierarchy of grievances and response time; (f) guidelines for resolution and response of grievance; (g) responsible personnel in charge of resolution; (h) documenting grievance/resolution; and (i) periodic monitoring of grievances.

Human Resource Policy and Management

Toni’s Human Resources (HR) policy and procedures, which were upgraded as part of a prior investment with IFC, include aspects related to equal opportunity employment, recruitment, employees’ conduct, employment regulations, salaries, disciplinary code, employees’ grievances, and performance management. Toni’s s HR manager is responsible for ensuring Toni’s compliance with Ecuadorian laws and regulations affecting all employees including contractors. Toni’s HR policy is aligned with IFC PS2 requirements stating that Toni will not use forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise and will only hire employees who meet local minimum age requirements. This policy and its procedures are communicated to all employees. Toni’s HR practices are also applied to Topsy, PESA, Dipor, and Codenase.



Currently Toni Corp combined operations (Toni, Topsi, PESA, Dipor, and Cosedone) have approximately 3500 employees of which 80% are operative and 20% are administrative. Toni and Topsi combined have 799 direct employees (22 %), Dipor and Cosedone have approximately 2,227 employees (62%), PESA has 584 employees (16 %.) Once operational, the Aurora plant anticipates having 799 permanent workers (80% male and 20% female.) For the construction phase, the Aurora plant has 128 contractor workers.



Worker’s Organizations

Even though Toni employees have right to freedom association, currently its labor force is not unionized. All PESA employees and 35% of Dipor employees are organized in workers company’s committees. Toni and Topsi employees are organized in self – guided employee committees (22 %.) There is an overall positive labor climate at all operations.



Non-Discrimination and Equal Opportunity

The HR policy also includes provisions relating to non-discrimination and equal opportunity, wages and benefits and occupational health and safety. Toni is an equal opportunity employer that extends equal employment opportunity to all applicants and its selection decisions are merit based.



Retrenchment

During 2014 and until January of 2015, Toni retrenched approximately 230 employees. This process, as confirmed, was conducted in according to the labor Ecuadorian requirements. It is not anticipated that additional retrenchment will take place as part of the project.



Protecting the Work Force

The minimum hiring age of its direct workers and following national laws, is 18 years old. All Aurora plant contractor’s employees are also older than 18 years old. Some of Toni’s suppliers have children younger than 18 years old working with their parents after school but in work that would not be considered harmful child labor. However, as indicated in the ESAP, Toni will develop and establish a systematic procedure to confirm that there will not be presence of harmful child labor in its supply chain. The procedure will map out its supply chain, monitor, reconfirm t
here is no child labor and as needed, it will establish prevention/mitigation measures. Typically, in Ecuador the main concerns of child labor rely on the banana plantations, flowers production, bricks production and gold mining.



The working periods at all plants are divided in two shifts of twelve hours, four days of work with two days off. Under this arrangement the Company pays overtime after 8 hours of work as established by the Ecuadorian labor law. It is anticipated that this same working shift will be adopted at the Aurora plant.



As part of Toni’s first investment with IFC, the company developed and established an internal workers grievance mechanism including the proper channels of communication, conflict resolution mechanism, record tracking, and feedback response.



Eighty percent of the labor force used in the construction of the Aurora plant come from Guayaquil and nearby areas and the remaining 20% comes from Quito. As indicated in the ESAP, Toni will provide details to IFC related to the house accommodations conditions of the 20% personnel that comes from afar and as needed it will include improvement actions to comply with the IFC requirements related to workers accommodations.



Occupational Health and Safety (OHS)

Toni has an established system to manage the risks of its operations, such as noise reduction measures, fall prevention measures at milk unload areas, chemicals spill prevention and double containment, etc., seeking compliance with Ecuadorian and IFC OHS requirements. It has developed and implemented OHS risk prevention plans identifying work related risks, workers exposure to hazardous agents and the need for protection. The operations have an OHS committee and conducts daily safety talks. In addition, it also conducts workplace monitoring and periodic audits as well as statistical assessment of the accidents and injuries to identify applicable preventive/protective measures to reduce accidents rates; reporting of key performance indicators; and when needed establishes corrective actions to comply with local and IFC environmental and labor requirements.



Toni Corp accident/incident statistics indicate that even though there have not been fatalities, the company is enhancing its programs to reduce the number of accidents such as falls, ergonomic affections, etc. It is anticipated that for the operation phase of the Aurora plant, given the updated and automated operation along with the training and OHS systems to be established, the number of potential accidents will be further reduced. It is worth noting that the OHS program established for the construction of the Aurora plant is effective since there have not been any significant accidents during construction activities to date.



Toni Corp has an occupational medical doctor in charge of the assessment of the overall and occupational health of its employees, it conducts periodic check-ups and along with the health and safety manager determine the
best workplace conditions for the workers of all its operations as needed. As part of this project and as indicated in the ESAP, Toni Corp will complete an assessment of the ergonomic conditions of all its operations and the hearing of its workers to further reduce these impacts; and as appropriate it will implement corrective measures.



Toni will extend the above mentioned programs to the Aurora plant. While operating, and as the plant is been designed, Toni will focus its attention to the prevention of risks related to work at heights, work with live power lines and equipment, fire, exposure to chemicals, etc.; and make compulsory the use of PPE (i.e., ear protection when workers noise exposure is above 85 dB (A), safety helmets, safety goggles, mechanical protection gloves, safety shoes, welding masks, full-body harness, etc.) All personnel exposed will be informed of the hazards and activities associated with use of chemicals (e.g., paints, solvents, glues, etc.). Working areas greater than 2 m high will be protected by handrails, guarding and/or appropriate fall protection equipment; hoists, slings, chains and other lifting devices will be inspected prior to use and verified to be in adequate condition. Only properly trained and qualified personnel will be authorized to work with and handle electrical equipment.



Additional safety measures will include equipment periodic maintenance and installation of enclosures and buffers to ensure noise levels below 85 dB (A); availability of portable gas detectors to identify potential leaks and prevent accidents, and of fixed O2 detectors in closed zones. It is anticipated that the Aurora plant will have designated walkways, stairs, ladders, roads or other access ways when entering or exiting work locations. They will have appropriate warning signs, barricades or barriers for all potentially hazardous conditions (e.g., open pits, missing handrail, chemical spill, traffic movement, etc.) Powered vehicles, including forklifts and personnel lifts will be always operated by trained and authorized personnel only. All accidents/incidents as well as the identification of unsafe conditions and acts will be reported to the division manager or supervisor immediately. All incidents will be investigated to determine the underlying causes and contributing factors of the incident and corrective actions will be implemented to prevent the recurrence of similar incidents. The results of investigations will be shared with all site workers, and other facilities that have potential for a similar incident.



Toni will also ensure that all workers maintain good housekeeping across the facilities at all times. Exits, aisles and stairs will be kept free from obstruction, as well as access to fire extinguishers, hoses, valves and hydrants. Tools, electrical cords, and hoses will be stored properly when not in use. No one will be allowed to work if their ability or alertness is impaired due to fatigue, illness, a
lcohol or drugs.



When operating, the plant will have emergency response procedures in place and the company will conduct emergency response training for all employees as well as contractors and visitors. Its emergency response team will consist of a team leader, firefighters and auxiliary firefighting team available 24 hours per day, and a fire truck driver. It will conduct quarterly emergency drills and it will have access to hospital with ambulance. The plant will install a firefighting prevention/response system including 2 water tanks with capacity of 30 m3each; one jockey pump, and electric and diesel firefighting pumps; firefighting hydrants; monitors; deluge valves covering the entire production area. It will also have emergency prevention equipment in the ammonia storage and refrigerating systems, such as leak detectors (indoor areas), preventive ammonia leak detectors maintenance, secondary contention, proper warning signs and emergency response equipment. In addition, the new plant construction has been designed in accordance with NFPA 1 and 101 standards for fire protection, and NFPA 70 (ref. Electrical Code). It will also have its corresponding emergency response and preparedness plan covering all emergency scenarios and risks, copy of which will be submitted to IFC as indicated in the ESAP.



PESA also has overall good OHS systems. All personal is required to use PPE; the plant exhibits excellent housekeeping, all areas are properly marked, and the plan has safety rails installed. The plant also has a comprehensive fire prevention system which is checked in weekly basis. All grinders are enclosed thus significantly reducing noise and all equipment movable parts are also enclosed. The company has an emergency response plan and personnel properly trained to response 24 hour per day.



Supply Chain

Toni sources its milk from 180 milk producers located in the Ecuadorian northern and southern coastal areas and central and austral sierra areas. It currently buys a total of 180,000 lt/d of milk and with the Aurora plant in operation it anticipates buying 400,000 lt/d of milk. Currently, it acquires 50% of the milk, by purchasing directly, from approximately 150 producers; 40% from purchases from six intermediaries; and the remaining 10% from its own four milk collection centers (“centros de acopio”) which in turn are supplied by approximately 30 small producers. Forty five of all milk suppliers provide exclusively to Toni and the remaining 55% also sell to other buyers.



Among the several aspects considered by Toni to satisfy its additional milk demand it will establish a program to help milk producers to increase their current average milk production from approximately 3,000 liters / hectare / year and one cow / ha to 8,000 liters - 10,000 liters / hectare / year and 4 - 5 cows/ha. With the support of Simpleca, Toni has begun promoting an environmentally friendly production alternative that links trees - pasture -
animal, to generate an ecosystem that benefits both, environment and human beings, through the overall improvement of milking techniques and grass irrigation methods among others. Currently it is actively working of 10 farmers who have committed to improve their practices. In addition, it will look to obtain the certification of good manufacturing practices for its 4 milk collection centers.

Resource Conservation, Energy Efficiency

The Aurora plant building is being designed to optimize energy efficiency and better resource use, following the Leadership in Energy and Environmental Design (LEED) rating system and its approach to green design. For the current operation, Toni’s energy efficiency performance can be considered satisfactory when compared with those parameters included in the WBG’s Dairy Processing EHS guidelines. A similar situation is found for the water consumption. Nonetheless, the Company will explore the opportunities to further enhance energy efficiency and resource conservation in the new Aurora plant processing operations by conducting a resource efficiency assessment shortly after the date that the plant is commissioned and using that assessment to define specific measures and goals to drive efficiency in energy and water use.



PESA, as a great energy consumer, has its own power substation. It total annual energy consumption is approximately 1,900.000 kw-h. However, it has started an energy optimization initiative with the support of the Ministry of Renewable Energy. Already between 2024 and 2015 it has reduced consumption from 2.5 kw-h to 2.2kw-h. It also conducted an energy audit; results identified the greatest energy consumers as being the extruders, injectors, chillers, and compressors. As part of the energy optimization, therefore, it is replacing the 4 compressors it currently uses with models that have greater capacity and higher efficiency. It has also begun regulating the startup of the higher energy consuming equipment; startups will avoid peak hours by better timing periods of peak production. It will also replace the current chiller with a new one which will reduce energy consumption by 3.79%.



Air emissions

The main sources of air emissions at Toni’s current operations are the small boilers (0.82MW all together) that burn bunker oil to produce steam. Toni monitors Boilers’ air emissions that are consistent with WBG EHS guidelines.



The main source of air emissions at the Aurora plant will be three efficient low NOx diesel boilers to be installed, each with a capacity of 800 BHP, 600BHP, and 300 BHP. Toni will monitors the boilers’ air emissions to ensure they are consistent with the WBG EHS guidelines. PESA has a 120 psi vapor pressure boiler that uses bunker as fuel oil.



Wastewater

The liquid effluents generated at Toni and Topsi include industrial, sanitary, and storm waters. At its current plant, Toni treats the industrial wastewaters using a combined system of equalization tank, flotation and aerobic digestion. The treated wastewater is discharged to the municipality sewage system. Toni’s sanitary wastes are released to the sewage system. Topsi and PESA also have wastewater treatment for their industrial wastes. PESA discharges its treated effluents to the municipal sewage system and Topsy to the Daule River. The treated effluents of the current operations are consisten
t with the WBG General EHS Guidelines.



For the Aurora plant, the company will install a new wastewater treatment plant (WWTP) that is designed to treat effluents in compliance with both local regulations and the WBG General EHS Guidelines and will ensure that any potential odors emitted from the WWTP will be properly controlled. Once treated 85 % of the effluents will be discharged to the nearby Daule River and the remaining 15% will be used for irrigation within the plant premises. The WWTP design specifications will be submitted to IFC prior to its being constructed as indicated in the ESAP. The sanitary wastewaters will be also treated prior being discharged to the Daule River and will also be consistent with the local regulation requirements and the WBG General EHS Guidelines. In addition, as indicated in the ESAP, Toni will control the wastewater discharges and install WWTPs at each of the four milk collection centers consistent with the local regulation requirements and the WBG General EHS Guidelines.



PESA uses water for the chiller, boiler and drinking purposes. The water used in the process has an enclosed system. It has a wastewater treatment to treat the liquid effluents generated which after treatment are discharged to the municipal sewage system. PESA has an initiative to reuse the treated effluent in the services area.



Solid wastes

The solid wastes at the Aurora plant will include process organic wastes, sludge from the WWTP, boiler ashes, paper and paperboard, plastic material and metal scarps. The hazardous wastes will include empty chemical containers and used lubricant oil. All the wastes will be properly segregated and disposed by authorized companies in locations authorized by the local Ecuadorian environmental authorities.



PESA solid and hazardous wastes are properly segregated and stored. Ninety nine percent of its industrial rejects are recycled back into the process. They discharge just 0.15%. This waste stream is disposed in accordance to the local environmental authorities as per the specific requirements to ensure qualified personnel and authorized final disposal for its wastes.



Hazardous Materials

The Aurora plant will use ammonia as refrigerant replacing the R22 and R507 refrigerants currently used at Toni. Even though ammonia will be more benign with the environment, as a toxic and flammable compound is requiring from Toni implementing rigorous measures to prevent ammonia leaks and establish detection systems to identify any minor leak as well as emergency response measures to address any potential leak.



Toni’s processing operations, at the Aurora plant, will not use large amounts of chemicals and the main hazardous materials will include cleaning products such as caustic soda, phosphoric acid, and liquefied petroleum gas (LPG) for the forklifts and diesel to fuel the boilers. The acid and soda will be packed in drums that will be kept in a dedicated properly locked and signed area. T
he acid and soda storage areas will have secondary contention and will have emergency showers nearby. For the sale points, Toni will acquire 8,000 high energy efficient 134A and CO2 refrigerants refrigerators which will be placed in small shops where Toni’s products will continue to be sold.



Toni has developed an environmental management system to ensure the impacts during the construction phase (such as noise, emissions, particulate matter and truck traffic) are properly controlled and do not cause nuisance to the nearby communities. In addition, Toni developed an external grievance mechanism for potentially affected communities raising their questions, complaints and concerns during the construction phase



Toni began conducting an EHS assessment at its four milk collecting centers to identify and fix all possible non-compliances. As per local requirements, it has been required to establish an environmental management plan (EMP) for each center, which will be also developed in accordance to the IFC EHS requirements. A copy of these EMPs will be submitted to IFC as indicated in the ESAP. In addition, it also began establishing a system, which will be formalized as per the ESAP, to help the small milk producers enhance their environmental practices such as proper handling of pesticides, appropriate disposal of pesticide packaging, preservation of river banks (from erosion), etc.



PESA’s hazardous materials, which include uses polystyrene, polyethylene, and polypropylene, among others, are properly stored and handle.



Greenhouse Gas (GHG) Emissions

Toni’s and PESA’s emissions are mainly related to the use of energy from the grid, steam production in the boilers, LPG consumption in the forklifts and diesel for the spare generators. It is anticipated that the combined GHG emissions will be 15,000 tons of CO2 eq/year.

Emergency Preparedness and Response

Currently, Toni has an emergency response and preparedness plan including emergency scenarios and risks, communication procedures, trained emergency brigade and periodically conducts emergency drills. As indicated, it will develop one for the Aurora plant and will ensure the plant has, as in the current operation, signed emergency means of egress, fire alarm systems, smoke detectors, sprinklers, hydrants, and portable fire extinguishers. The plant will follow NFPA 1 and 101 standards for fire protection, and NFPA 70 (ref. Electrical Code). The emergency response plan for the Aurora plant, which will include incident and crisis response will be develop and submitted to IFC as indicated in the ESAP.



As indicated above, Toni will have rigorous systems in place to prevent the likelihood of ammonia leaks and potential ammonia related accidents. As previously indicated, Toni will prepare/update the ESIA to assess the impacts of the project which includes the milk as well as ice cream production operations. This document will also carefully assess any possible ammonia impacts to nearby communities and as appropriate include needed mitigations.



PESA also has emergency response and preparedness plan including emergency scenarios and risks, communication procedures, trained emergency brigade and periodically conducts emergency drills.



Currently, two of Dipor’s twenty distribution centers have emergency response plans in place. As indicated in the ESAP, Toni Corp will develop and submit to IFC satisfactory emergency response plans for 18 distribution centers as well as for the four milk collection centers.



Logistics and Transportation

Logistics and transportation of products and goods to and from Toni facilities is a critical component of its operations. It obtains the milk from milk production farms, which is transported to the manufacturing plant or to the collection centers. In addition, from the manufacturing plant, the products are transported to the distribution centers and then to the sale points throughout the country. Toni owns, operates and maintains its own fleet of 11 tankers used to transport the milk from the farms and collection centers to the processing plant. It also uses 6 contracted tankers. The intermediaries deliver the milk directly to Toni’s plant. Even though, Toni has in place some transportation safety measures, as part of this project it will develop and implement a Safety Transportation Plan to ensure that drivers are trained to properly operate, care and maintain the equipment, and to ensure the safety of equipment and communities. Copy of which will be submitted to IFC as indicated in the ESAP.



Product Stewardship

Toni is a food manufacture company and, as such, food safety is a critical aspect related to the safety of its clients and communities. Toni has in place a certified and comprehensive food safety management system, based on HACCP and ISO 9001 framework,
to prevent and address the chemical, physical and biological hazard to enhance food safety.



Security Personnel

Toni Corp operations employ and will continue employing private security personnel from specialized firms in the sector and does not rely on Ecuadorian public armed forces for any services or support. Security personnel are screened for criminal backgrounds and are provided with training in the use of force. Toni implements security policies and procedures commensurate to the operations’ risks and provides security personnel codes of conduct and training to ensure appropriate conduct with neighboring communities. Copy of the security procedures for all Toni Corp operations will be submitted to IFC as indicated in the ESAP.

Toni has a Consumer Services Center (SAC) system in place that can be accessed through the internet:
http://www.tonisa.com/contactos.aspx , by phone via a toll free line at 1800 tonisa or 1 800 866472. These contact options are widely announced through the Company’s consumer products. Most complaints received are related to product quality. All claims are registered and a product replacement is offered. The defective products are analyzed and a monthly report of products claims is shared with managers and directors, who decide if any corrective action is needed.

As part of the E&S licensing process, Toni disclosed the EIA report locally and conducted a public hearing for all interested stakeholders. As already spelled out under PS1, Toni will develop an external grievance mechanism for affected communities to raise their questions, complaints and questions about the construction and operational phase of the new site development. This system will be designed to receive, document, handle and provide a feedback for all complaints from nearby affected communities.

Toni will disclose this document in Spanish language in the communities where plants are located. Shortly after publication in IFC’s website, the document will be displayed at the following locations:
Planta Aurora vía Perimetral Km. 17.5
Planta Toni vía a Daule Km. 7.5
Planta Topsy vía a Daule Km. 10.5
Planta PESA vía a Daule Km. 8.5
“Canchita Deportiva” de la Cooperativa San Nicolás mz. 52, solar 12 – La Aurora-



Please contact the following for enquiries or concerns about the environmental and social impacts of this project:
Plant
Contact
Planta Toni vía a Daule Km. 7.5
Nombre: Edward Mcintosh
Cargo: Representante Legal
Nombre de la Compañía: Industrias Lácteas Toni S.A.
Dirección: Vía Daule 7.5 km

Teléfono: 593-04-3701300
Facsimile: 593-04-3701316

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
2	1. Review, upgrade and submit to IFC a copy of the updated ESIA for the Aurora plant	08/31/2015	Completed
3	2. Provide a copy of the Ecuadorian environmental operational license for the integrated dairy/ice cream operations at the Aurora plant	03/31/2016	Completed
4	3. Provide details of the new EHS organizational structure to manage the EHS aspects of the Aurora plant, Dipor, Codenase, and milk collection centers indicating reporting lines	09/30/2015	Completed
5	4. Provide copy of the CV and job description of the community relations responsible personnel for the Aurora plant	08/31/2015	Completed
6	5. Develop, implement and provide a copy of a Community Grievance Mechanism aligned with the requirements of the PS1 for the Aurora plant and supporting operations	09/30/2015	Completed
7	6. Prepare and submit copy of the demobilization plan for the current Toni and Topsi operations indicating EHS impacts and mitigations for own and contractors	01/31/2016	Completed
8	7. Develop establish and provide a copy of the procedure to systematically confirm that there will not be presence of harmful child labor in Toni Corp operations’ supply chain.	08/31/2015	Completed
9	8. Provide details related to the house accommodations conditions of the 20% Aurora plant construction personnel that comes from afar and, as needed, mitigation/improvement actions to comply with IFC PS2 related to workers accommodations	08/31/2015	Completed
10	9. Complete an assessment and submit findings and proposed mitigations of the ergonomic conditions of all its operations and as appropriate needed corrective measures	12/30/2015	Completed
11	10. Complete an assessment and submit findings and proposed mitigations of the hearing conditions of its workers; and as appropriate needed corrective measures (a) Toni	12/30/2015	Completed
12	10. Complete an assessment and submit findings and proposed mitigations of the hearing conditions of its workers; and as appropriate needed corrective measures (b)Topsi (C)PESA	03/31/2016	Completed
13	11. Provide a copy of the emergency response and preparedness plan covering all emergency scenarios and risks for the Aurora plant	03/30/2016	Completed
14	12. Provide the wastewater treatment plant (WWTP) specifications for the Aurora plant detailing the control methods to ensure that the treated concentrations and no odor generation are in accordance to the WB EHS dairy manufacturing guidelines	09/30/2015	Completed
15	13. Provide details of the WWTPs for each of the four milk collection centers detailing the control methods to ensure treated concentrations are in accordance to the WB EHS dairy manufacturing guidelines	09/30/2015	Completed
16	14(a)Provide copies of the monitoring results of the performance of the WWTP of the Aurora Plant	12/30/2015	Completed
17	(b)Provide copies of the monitoring results of the performance of the WWTP of the Aurora Plant	05/31/2016	Completed
18	(c)Provide copies of the monitoring results of the performance of the WWTP of the Aurora Plant	07/31/2016	Completed
19	15. Provide copy of the monitoring results of the performance of the WWTP of each of the four milk collection centers	12/30/2015	Completed
20	16. Provide copy of the environmental management plans for the four milk collection centers	12/30/2015	Completed
21	17. Provide copy of the procedures to be established to help the small milk producers enhancing their environmental practices	09/30/2015	Completed
22	18. Develop and submit to IFC satisfactory copies of emergency response plans for 18 distribution centers	01/30/2016	Completed
23	19. Develop and submit to IFC satisfactory copies of emergency response plans for the four milk collection centers	09/30/2015	Completed
24	20. Develop, implement, and submit a copy of the Safety Transportation Plan	09/30/2015	Completed
25	21. Develop, implement and provide to IFC a copy of a security procedures for Toni Corp operations aligned with the requirements of the IFC PS4.	09/30/2015	Completed