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

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
There are no impacts of concern associated with the following Performance Standards: PS 4: Community Health, Safety and Security – all WtE projects comply with PRC regulatory minimum offset requirement of establishing a 300 m buffer zone from residential communities. Security personnel at Canvest facilities are unarmed and no adverse interaction with members of the public is anticipated. PS5: Land Acquisition and Involuntary Resettlement – all WtE facilities currently in operation and those under development are either existing facilities or WtE site locations for which land acquisition was undertaken by the government many years ago dating back to the early 2000s. For those projects under BOT, the land is owned by the government. IFC is not aware of any disputes, outstanding legal challenges or legacy issues related to land acquisition at any of the sites. If additional land for expansion is required during the concession period, the company will ensure compliance with PS5 requirements if applicable; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources – all aspects of concessions including those related to biodiversity and conservation are reviewed through government led impact assessments, and for the concessions/projects under consideration for IFC financing, no negative impacts on conservation or biodiversity within the projects’ area of influence have been identified; PS7: Indigenous People – no indigenous people are known to have been in areas or affected by projects being considered for IFC financing; PS8: Cultural Heritage – the projects being considered for IFC financing are not located in areas of known historical or cultural significance.

This is a Category B project in accordance with IFC’s Policy on Social and Environmental Sustainability because it will create a limited number of specific environmental and social impacts that can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. The WtE facilities operated by Canvest, and those currently in development have a limited footprint, use contemporary technology that meets performance standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), and applicable WBG guidelines for incineration of MSW, to significantly improve on emissions performance of existing WtE facilities that are being upgraded by Canvest. Key E&S issues associated with this investment include: the company’s environmental and social management capacity; monitoring and performance of environmental, health and safety and social management systems; specifications and operating procedures for WtE facilities, including emission control equipment, performance and operational standards, and alignment with internationally recognized practices for the sector.

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.

Canvest has an ISO 14000 and 18000 certified corporate management system which includes oversight of environmental, social, health and safety (ESHS) issues. Among other things, this ensures the operations comply with all applicable laws and regulations. The existing management system includes a series of procedures, work instructions, and reference documents which, when combined with the findings of the project-specific assessments, comprise a program of mitigation and performance improvement measures and actions necessary to effectively manage the E&S risks and impacts of its projects. For new projects, assessments are periodically aggregated and summarized for senior management review. And through management meetings and written documents, project and site managers periodically report on environmental, health and safety performance, as well as accidents and incidents on existing projects.



The company’s management program includes operational policies and procedures that are implemented at the facility level by supervisors who report to management on an as needed basis. Policies and procedures comply with applicable local regulatory requirements for operation of these facilities including those for human resources and labor, occupational health and safety, and environmental compliance. The Vice President, Human Resources has responsibility for overseeing matters related to labor, working conditions and health and safety. The company provides professional training to key personnel to ensure they have relevant skills and adequate training to perform their work. Assisted by qualified personnel, project managers for each project company are responsible for day-to-day implementation of project-level programs and plans. In accordance with the project-specific work plans, project or site managers are responsible for providing environmental and health and safety training to employees, including contractor personnel.



The company monitors environment, health and safety performance for each project according to the procedures established in their existing management system. In addition to standard procedures detailed in the existing management system, project specific procedures are developed to comply with provisions contained in E&S impact assessments and concession agreements with local governments. For example certain identified major environmental, health and safety risks and impacts, measurable targets are established as compliance benchmarks. If monitoring results indicate nonconformance with standards or deviations from established benchmarks, appropriate corrective or preventive actions are initiated. A similar approach is adopted for unplanned events such as accidents where the events are investigated, and corrective or preventive actions initiated to prevent recurrence. Engineering controls and staff training are provided to mitigate risks and issues associated with the company's operation of WtE facilities. The use and storage of hazardo
us chemicals are subject to stringent safety standards as required under PRC laws. The company is required to have emergency prevention, control and response plans which specifies responsibilities, ensures appropriate response equipment and materials are in place, and detail a set of procedures to be followed to minimize the harm of any potential accident.



Performance of the company’s existing environmental and social management system is largely consistent with IFC PS requirements in providing adequate oversight, comprehensive risk assessment, monitoring, reporting and training. For the projects being considered for IFC financing, for better alignment with IFC PS requirements, Canvest will manage its environmental and social performance per IFC PS and applicable sections of relevant World Bank Group EHS guidelines, and implement specific mitigation, monitoring and management measures agreed upon in ESAP action #1 for programmatic integration of ESHS functions for its operations and those of its subcontractors at all its WtE facilities. As agreed in the ESAP action #2, the company will review its scope of emergency response and update procedures as needed, including drills to test the effectiveness. The company will also add a community involvement component that addresses appropriate behavior and safety measures to be implemented in the event of an unplanned release beyond the plant boundaries due to either irregular plant operations or an accident at the facility, or during transportation of material destined for the facility.

Currently the company employs 439 staff, and the number of sub-contracted employees can vary significantly depending on construction activities at any given time. The company has a Human Resources policy that complies with local and PRC regulatory requirements, and is applied consistently to all direct employees across all its business lines and (subsidiary) project companies. As required by law, the policy is included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. This information is provided in the form of an employee handbook at the time of induction. As is common practice in China, although not explicitly stated, employment relationships recognize the principals of non-discrimination and equal opportunity. Although there is no labor union at the company, under PRC law, employees have the right to freedom of association and have the opportunity to collectively represent to the management any issues or grievances that they may have.



The minimum employment age at the company is 18 years. The company ensures that child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. Working hours on site can vary by nature of activity and phase of project, with most labor intensive phases being at the construction phase during which there are continuous operations. Construction activity is largely subcontracted for which unskilled labor is procured locally. Regulatory requirements in PRC do not require the company to provide direct oversight of wages, working or living conditions of subcontracted labor. Wages are paid by subcontractors to labor on a monthly basis and calculated with basis on the hours worked, inclusive of overtime. Terms of employment for sub-contractors are as per PRC laws and the company relies on regulatory agencies for ensuring that sub-contractors comply with applicable labor laws. Moving forward, the company will review its human resources policy to ensure consistency with IFC Performance Standard 2 on labor, payment of wages/overtime, working conditions and worker accommodation (where applicable) for any labor employed by the company, either directly or through sub-contractors, as per ESAP action #3.



Human resources are managed at corporate level with oversight of the company facilities and operations. Training of staff is done on a routine basis in compliance with local workplace regulations. The department of human resources is responsible to ensure that all employees are adequately trained to perform their work safely. Supervisors monitor that standards are met and any reportable incidents are reported and follow up action taken when required. The company’s training, monitoring and reporting framework is consistent with PRC requirements, and is expected to be consistent with IFC requirements after implementation of the Environmental and Social Management System (ESMS) program.



Occupational health and safety
of employees at the company is managed by the Human Resources and Administration. There is a plan for accident prevention and worker safety consistent with local regulatory requirements. All employees in the company have to undergo a training program at induction and subsequently regarding worker health and safety relevant to their job activity. Facilities are audited yearly by regulatory agencies to monitor compliance with labor regulations. The company has been in compliance with regulatory requirements and has recorded no significant lost time incidents or fatalities in its operational history.

Recovering energy from the incineration of MSW is being widely adopted in China as a technology of choice for the management of MSW. Incineration with adequate engineering/ emission controls can provide an environmentally acceptable solution for significant reduction in disposal volumes, and generate energy that can potentially offset usage of coal and other non-renewable energy sources.



In general, WTE plants generate electricity through the following process: MSW vehicles from waste transfer stations enter the plant through a weigh bridge before waste is unloaded into storage silos, where it is stored for a couple of days. During the storage period, there is a significant reduction in the moisture content of the stored waste due to draining of leachate from the waste. Waste with reduced moisture content is continually transferred by grab cranes to hoppers and a feeding trough which pushes MSW onto a moving grate to dry, combust, burnout and cool. Waste stays on the moving grate for about 1.5 to 2 hours.



Leachate from the waste storage silos is collected through a system of under drains for further treatment and reuse. Leachate treatment system consists of a pre-treatment process followed by an Upflow Anaerobic Sludge Blanket (UASB) for reduction of dissolved organics, a membrane bio reactor (MBR) for further reduction in dissolved organics, and for producing reuse quality water, effluent is treated in a tertiary treatment plant using membrane filtration (Nano filtration and Reverse Osmosis). Reject from the leachate treatment system is sent back to the waste storage to be combusted along with MSW in the furnace. No effluent is discharged to the environment from any WtE facility operated by the company.



After complete combustion, residue in the form of waste slag is discharged outside of the furnace. Bottom ash from waste combustion in the incinerator is transported away from the plant after cooling, most commonly for use as additives in the road and construction industry. Fly ash from the FGT system is collected separately and disposed of as hazardous waste by licensed vendors in landfills designated by the local government.



As with any other WtE plant, the principal source of emissions to the atmosphere is in the form of flue gases produced from the incineration of MSW. Flue gases from incineration can contain a range of pollutants, which can exhibit rapid variation in composition and concentration due to the heterogeneous nature of MSW. Reduction of these pollutants is achieved through sophisticated engineering controls during the combustion process as well as through post-combustion flue gas treatment (FGT). The FGT system includes a semi-dry reaction (desulfurization method) tower for removal of acidic substances, followed by active carbon adsorption for reduction in heavy metals and dioxins, and use of bag filters for capture of dust and other reaction products. Flue gas after treatment is vented to the atmosphere through sm
oke stack(s). Emissions are monitored in real time with a continuous emission monitoring system (CEMS) for parameters that are amenable to real time monitoring, for others the company has a monitoring and reporting program that is in compliance with PRC regulatory requirements.



Terms of the concession agreements require Canvest to comply with local regulatory requirements (GB18485-2014) which are largely consistent with emission standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), with exception of a few parameters and monitoring requirements which are slightly less stringent. Monitoring data made available by the company confirms that all operational facilities are in compliance with applicable PRC regulatory requirements (GB18485-2014), EIA approval requirements, and emission performance standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), and applicable IFC/WB guidelines for incineration of MSW. Since all Canvest plants use similar combustion, engineering controls and flue gas treatment systems, it is anticipated that WtE plants currently under upgrading / development by the company will also comply with the above referenced emission standards, and any specific recommendations arising out of ESIA review (as described in ESAP Action # 2 (ii)).



Also as agreed in ESAP action #4, Canvest will install continuous inline sampling and monitoring equipment that can reliably and accurately measure relevant parameters, prior to commercial operations at all WtE facilities. The company will monitor emissions on an ongoing basis to ensure comprehensive compliance at all times with PRC regulatory requirements (GB18485-2014) and applicable IFC/WB Guidelines; should monitoring show significant deviation from the metrics established by the guideline, the company will make immediate necessary changes to remedy the non-compliance.



Generation of nuisance odors is a common problem in MSW transportation, handling and disposal facilities. Appropriate engineering controls at the facility such as negative pressure in MSW storage bunkers, use of chemical agents and other good management practices for transportation of MSW are in use at Canvest to minimize odor issues.



The incineration of MSW involves the generation of climate-relevant emissions. These are mainly emissions of CO2 (carbon dioxide) as well as N2O (nitrous oxide), NOx (oxides of nitrogen) NH3 (ammonia) and organic C, measured as total carbon. CH4 (methane) is not generated in waste incineration during normal operation. It can be assumed that under the oxidative combustion prevailing in waste incineration in MSW incinerators, methane is not present in the waste gas and consequently is not emitted. Although methane emissions may form in the waste bunker, the negative pressure in the waste bunker causes them to be transported with the bunker air to the combustion chamber as primary air, to be convert
ed there. It only arises in particular, exceptional, cases and to a small extent (from waste remaining in the waste bunker), so that in quantitative terms CH4 is not to be regarded as climate-relevant. Based on IPCC guidance on estimation of emissions from waste incineration, it is estimated that Canvest operations will result in GHG emissions in excess of 25,000 tons of CO2 equivalents annually. Consistent with IFC PS3 requirements on GHG emissions, the company will monitor and quantify GHG emissions as well as those avoided, in accordance with internationally recognized methodologies. In addition, the company will evaluate technically and financially feasible and cost-effective options to reduce or offset project-related GHG emissions during the design and operation of the project.

The WtE facilities operated by Canvest and those under development are not located close to communities or settlements which may be affected by the operations of the company. The WtE facilities use contemporary technology that meets performance standards established by the European Union (Directive 2000/76/EC and relevant Annexes/Amendments), and applicable IFC/WB guidelines for incineration of MSW, to significantly improve on emissions performance of existing WtE facilities. The WtE facilities operated by Canvest have not been subject to any public complaints or disputes regarding its environmental or social performance. The company works with the local government at project locations in making available relevant E&S information.

In China, dialogue and communication with relevant stakeholders and disclosure of environmental and social impact assessment occurs through procedures established by PRC regulations. As a result, information dissemination activities have included those undertaken by the local government, which includes stakeholder consultation during project development and operational phases. Extensive public consultation was undertaken for the WtE projects as part of the ESIA development process, and is documented in the ESIA for each project. As part of its environmental and social management program, the company will establish methods for communicating environmental and social aspects on an ongoing basis to external interested parties and maintain procedures for receiving, documenting and responding to concerns from any external interested parties relating to the project, as per ESAP action #1. The company will monitor / review the government’s activities in this regard to ensure that any necessary follow-up with the community is handled properly. Specific procedures will be developed to incorporate community engagement, including clear procedure on disclosure and consultation with potentially affected communities.

For more information see the company’s website at http://www.canvestenvironmental.com or contact:

George Law
Address: Unit 6803B, Level 68, ICC, 1 Austin Road West, Kowloon, Hong Kong
Telephone no.: (852)2302 7066
Fax: (852) 2668 6597
Email: mailto:george.law@canvest.com.hk
Website: http://www.canvestenvironment.com

Relevant environmental and social review documents including environmental and social impact assessments approved by the government will be made available on the company’s website and its corporate office. The ESRS and ESAP will be made available at each of the identified project sites.

Website: http://www.canvestenvironmental.com or contact:
George Law
Address: Unit 6803B, Level 68, ICC, 1 Austin Road West, Kowloon, Hong Kong
Telephone no.: (852) 2668 6596
Fax: (852) 2668 6597
Email: mailto:george.law@canvest.com.hk
Website: http://www.canvestenvironment.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status
Adopt IFC Performance Standards as part of company’s legal requirements.	01/31/2016	Completed
Integrate ESHS functions into its existing management system to provide continued oversight of ESHS for all its operations and those of its subcontractors.	01/31/2017	Completed
Review and update its procedures, training and infrastructure to ensure safe operations and emergency response associated with (a) operation of its facilities, and (b) transportation and handling of hazardous gases/chemicals.	09/30/2016	Completed
Review HR policies, procedures and training program for consistency with good international industry practice in relation to sub-contracted labor.	05/31/2016	Completed
Develop a monitoring program that is consistent with good international industry practice that can reliably and accurately measure relevant parameters (as established through in ESAP Action # 2 (ii)), prior to commissioning of each facility.	12/31/2016	Completed