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
Issues related to PS5: Land Acquisition and Involuntary Resettlement, PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected with this investment for the following reasons: this equity investment does not involve any green field operations as all Wow Nutrition’s targeted subsidiaries under this investment are established facilities, located in industrial and commercial areas. None of Wow Nutrition’s current operations has or will trigger involuntary resettlement and/or economic displacement. There is no presence of Indigenous Peoples within the company’s operational footprint. Traditional communities known as “ribeirinhos” are part of the supply of açaí, which represent less than 1% of the total amount of fruit pulp and concentrate acquired by Wow Nutrition. These communities are not adversely impacted by the project; on the contrary, their livelihoods are in part supported by the procurement of these fruits by one of Wow’s primary suppliers (see below for a more detailed review of the acai supply chain including harvesting practices). In the event that issues anticipated by these PSs arise, Wow Nutrition will promptly inform IFC. Screening and assessment of these issues against PSs requirements will be done through the company’s E&S management system (ESMS). If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

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

This proposed investment is expected to have limited environmental and social impacts which are expected to be site-specific and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. The project is designed to avoid, minimize and manage E&S risks and impacts in compliance with Brazilian legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable sections of the World Bank Group (WBG) General and sector-specific (Food and Beverage Processing) Environmental, Health and Safety (EHS) Guidelines.
Key E&S issues associated with this investment relate to the following: (i) provision of safe and fair working conditions, compliant with Brazilian labor law and Performance Standard 2, for permanent employees, contractors and supply chain labor; (ii) water and energy efficiency and consumption; (iii) solid and liquid waste treatment and disposal; (iv) food safety; (v) sustainability of Wow Nutrition’s supply chain (especially with respect to the extraction of açaí berries by “ribeirinhos”; and (vii) management systems to provide systematic management of all these issues and where appropriate external certification of such.

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 appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFC’s 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 Policies: Wow Nutrition has a number of policies and procedures in place to address human resources, environmental, occupational health and safety (OHS) and food safety performance. The company manages EHS and labor issues of its operations mainly through achieving compliance with Brazilian legal and regulatory requirements. In addition Wow Nutrition has a quality assurance management system certified compliant with ISO 9001 (re-certified in 2015) as well as a food safety system in place based on HACCP (Hazard Assessment and Critical Control Point) to ensure the safety of their products. The implementation of these policies and procedures and the commitment to achieving compliance with Brazilian regulatory framework has been validated during appraisal.



As per the ESAP, Wow Nutrition will develop and approve an overarching policy defining the environmental and social objectives and principles that guide the company. The policy will include reference to requirements based on Brazilian laws and regulations, IFC Performance Standards, applicable sections of the WBG EHS Guidelines, HACCP; and ensure a corporate-level internal audit mechanism for assessing performance level of all operations, including performance targets and key performance indicators (KPIs). The policy will be communicated to employees at all levels and all functions, and as a good practice, it will be published on the company’s website and communicated to key stakeholders, where appropriate.



Identification of Risks and Impacts: Wow Nutrition has specific procedures and staff to address environmental, life and fire safety (L&FS) and OHS risks and impacts and to mitigate them accordingly. L&FS and OHS risks are identified in both processing plants (Caçapava and Manaus) in line with the Brazilian regulatory standards on occupational health and safety, known as Normas Regulamentadoras de Segurança e Saúde no Trabalho – NR. See below under PS2 for more details. With respect to environmental risks and impacts, the Caçapava plant has procedures in place to identify and manage water abstraction, water and electricity consumption, wastewater generation, and solid waste disposal. To ensure the company is in compliance with all applicable environmental and operational permits and licenses, a regulatory department has been created and reports directly to the factory Industrial Director. A copy of all operational and environmental licenses and permits has been provided to IFC during appraisal.



Management Programs: The company management programs are guided by the Brazilian legislation and the international certifications for quality management (ISO 9001) and food safety control (HACCP - Hazard Analysis and Critical Control Point). The plant in Caçapava holds a certification with ISO 9001, and HACCP, while the plant in Manaus is certified with ISO 9001. Certifications are done separately for each processing plant.



Environmental management programs associat
ed with the processing plant in Caçapava encompass water use and energy consumption management, wastewater treatment and monitoring, solid waste management, air emissions monitoring and emergency preparedness and response. A wastewater treatment facility has been installed on site and the company has sought to implement a variety of resource efficiency measures to reduce the use of water and electricity (see below under PS3 for more details). During the appraisal, several control measures were reviewed, such as water samples analysis (which results were found in compliance with the Brazilian legislation and the Standard Methods for the Examination of Water and Wastewater - APHA, AWWA, WEF), boiler inspection report, wastewater effluents (silt) disposal certificate, data related to water catchment, wastewater and electricity consumption control, among others. The plant in Manaus is a simple dry mixing operation; as such the environmental and social risks and impacts are minimal. Ingredients are received and blended, and the product is then shipped to the plant in Caçapava. The whole operation consists of three small mixing rooms and warehousing. No process water is used and effluents are made up of sanitary wastes (from toilets) and from the kitchen area. As such, there is no need for the kinds of management programs seen at the Caçapava plant.



The company has a comprehensive Human Resources management system to comply with the Brazilian Labor Code and a solid OHS management system in line with the Brazilian regulatory standards on occupational health and safety (see below under PS2 for more details). Based on IFC’s review, the company has a corporate environmental, social, health & safety, and quality management system in place regarding its own operations. Given the reliance on contracted operations (that manufacture some of the company’s beverage products), the company will develop procedures and practices that provide them assurance that these elements are being suitably managed with regards to environmental and social matters. For example, the company will enhance its current review and audit functions of these suppliers (that is quality-based) to include matter related to E&S risks and impacts. This is addressed in the ESAP.



Organizational Capacity and Competency: The company has a well-defined organizational structure to implement and manage human resources, environmental, health, safety and security performance. At the corporate level, the Human Resources Director reports directly to the company CEO, while the vice president is ultimately responsible for EHS performance and Supply Chain related issues.



At the operations level, the Caçapava plant has an Environmental, Health & Safety and Quality (EHSQ) Manager that reports directly to the Industrial Director. In addition, the plant has EHS coordinators, supervisors and technicians to ensure EHS procedures are fully implemented. The company has also assigned a Human Resources Ma
nager (operational level) that reports directly to the Human Resources Director at corporate level. A regulatory coordinator has been assigned to oversee operational and EHS regulatory licenses and permits. In Manaus the Operations’ Manager is responsible for environmental, health, safety, security and human resources performance and reports directly to the Industrial Manager and Human Resources Manager.



Training: Wow Nutrition has a structured training program in its operations that includes an induction session covering basic conditions of employment, disciplinary code, and environmental and OHS policies and procedures. The company also provides specific trainings according to workers’ needs, including OHS, first aid, machinery operation, food safety, among others. The training program for 2015, including center of responsibilities and budgetary allocation, has been reviewed during appraisal.



Emergency Preparedness and Response: The processing plant in Caçapava has an emergency preparedness and response system, in line with the Brazilian legislation, comprised of (i) an Emergency Preparedness and Response Plan (known as Plano de Ação de Emergência – PAE), which includes the identification of emergency scenarios and specific emergency response procedures, evacuation procedures, emergency contacts and communication procedures; (ii) trained emergency response teams (currently 58 staff members known as brigadistas) distributed in different sectors and shifts, to ensure at least a minimum emergency response capacity at all times; (iii) stationed emergency equipment and facilities, such as fire extinguishers, eye wash stations, emergency onsite clinic; and (iv) periodic emergency drills. According to information provided to IFC during the appraisal, the company is in full compliance with all Brazilian fire safety regulation, including the fire safety certificate from the state’s fire department for each operation, known as Auto de Vistoria do Corpo de Bombeiros, or AVCB. As per the ESAP, the company will develop an Emergency Preparedness and Response Plan (Plano de Ação de Emergência – PAE) to the processing plant in Manaus.



Monitoring and Reporting: Wow Nutrition has established procedures to monitor and measure the effectiveness of the management programs, as well as compliance with regulatory requirements. Several environmental, labor and health and safety indicators are monitored on a monthly basis (and where required, on a daily basis) by supervisors, the EHSQ Manager and the Industrial Director, related to water use and energy efficiency, wastewater, solid waste disposal, air emissions and occupational accidents. The monitoring results are recorded and if corrective measures are required, those are implemented. The monitoring information is presented to senior management on monthly meetings at the corporate level. The monitoring records were presented and reviewed during the appraisal (see below under PS3 for more details).

Wow Nutrition employs 1,107 direct workers distributed at the corporate and operational levels: 205 people at the corporate level based in São Paulo, 809 people at the plant and distribution center in Caçapava, 23 people at the plant in Manaus and 70 people at the sales office in Fortaleza. Most of the employees are hired locally and regionally. Of the full time staff, approximately 30% are women. The company offers its workers all basic benefits guaranteed by Brazilian law, and all employees are paid above the Brazilian minimum wage in accordance with the salary grid and compensation package agreed in the collective agreements with the labor unions.

Human Resources (HR) Policies and Procedures, Working Conditions and Terms of Employment: The company has a comprehensive set of policies and procedures applicable to all direct employees that reflects the Brazilian labor code known as the Consolidação das Leis de Trabalho or CLT, which outlines the following provisions: (i) recruitment and hiring; (ii) compensation (including wages and benefits); (iii)hours of work; (iv) overtime arrangements; (v) leave; (vi) benefits, including health insurance, pension schemes; (v) conditions of work; (vi) termination procedures and rights; (vii) communication procedures; (viii) training; and (ix) other requirements according to national law. Wow Nutrition is currently reviewing all job positions, remuneration and promotion criteria to be fully aligned with market good practices and to enhance workers retention.

The company has a Code of Conduct since 2014, applicable to all the employees, contractors and suppliers, which includes statements regarding ethical behavior, non-discrimination and equal opportunity. A Compliance Committee has been established to monitor the implementation of the Code of Conduct. Complaints can be addressed to HR or directly to the Compliance Committee members. A monitoring report was reviewed during the appraisal, and was seen to include a description of complaints received and the procedures adopted to solve the situations. Example of complaints included disagreements between employees and direct management. All the reported complaints have been investigated, addressed and closed.

Wow Nutrition abides by all legal prohibitions against under-age employment and forced labor. Minimum age of employment in Wow Nutrition is 18 years old, except for apprentices, which can range from 14-24 years old according to the Federal Decree 5.598/2005. According to reviewed documents during the appraisal, the company has an apprentice program and a partnership with Centro de Integração Empresa Escola (CIEE) and Fundação Roberto Marinho to identify, support and hire apprentices, in order to reach the target established by this Federal Decree.

According to reviewed documents, as of September 2015 Wow Nutrition had not reached the target established by the Federal Law 8.213/91 for the employment of people with disabilities. The company is preparing a work plan to increase the number of people with disabilities amongst its workforce, and therefore, to reach compliance with this federal law by 2017. The work plan will be submitted to the Ministry of Labor for approval in November 2015. As part of this plan Wow Nutrition has established a partnership with Impacta Institute. As per the ESAP, Wow Nutrition will provide evidence to IFC that the work plan (to reach compliance with Federal Law 8.213/91 for the employment of people with disabilities) has been approved by the Ministry of Labor.

During the appraisal IFC verified the companys commitment to implement good labor standards, consistent with the Brazilian legislation and Performance Standard 2, in terms of working conditions, terms of employment and occupational health and safety. In addition, IFC noticed good relationship between management and workers. Nevertheless, Wow Nutrition reported that there are 83 outstanding lawsuits by the Public Prosecutor for labor issues associated with requests for additional payment for overtime, night shift, unhealthy and hazardous activities. These lawsuits have been managed by the companys legal department in accordance with the Brazilian legislation.

Workers Organization: As per the Brazilian Labor Code in Brazil (CLT), as well as determined in the company Code of Conduct, the employees have the right to freedom of association, and there is no restriction to collective bargaining. Under Brazilian legislation all employees are registered with a union, and in the case of Wow Nutrition and its subsidiaries, its employees are represented by different unions from São Paulo, Caçapava, Manaus and Fortaleza. The collective agreements for each subsidiary have been reviewed during appraisal and are judged to be in compliance with the requirements of this Performance Standard. Wow Nutrition and its subsidiaries abide by the collective agreements on salaries and benefits negotiated under the collective bargaining. There is no history of strikes or current indication of tensions beyond those outstanding lawsuits already discussed.

Retrenchment: During 2014 and 2015, as part of an organizational restructuring of the processing plant in Caçapava, the company retrenched approximately 80 employees. This process, as confirmed by the HR department, was conducted according the Brazilian legislation. In the event that the elimination of a number of work positions or the dismissal or layoff of workers is required, Wow Nutrition will follow the requirements of PS2 in addition to Brazilian legislation and requirements under union agreements.

Grievance Mechanism: Workers can address grievances and complaints to the human resources department, to managers and to the Compliance Committee. The workers are informed about the available channels for communicating any concerns at the time of recruitment during induction sessions. Although it is not compulsory according to the Brazilian legislation, a channel that allows anonymous complaints should be available for workers, aligned with IFC PS2. As set forth in the ESAP, Wow Nutrition will enhance its grievance mechanism by developing a procedure that allows for anonymous complaints to be raised and addressed and by defining key indicators to be monitored.

Occupational Health and Safety: The company is committed to ensure a safe and healthy work environment for all its employees, formalized in the Wow Nutrition OHS Golden Rules, OHS programs and standard operational procedures (SOPs). The company maintains an occupational health and safety management system to address the risks of its operations, including identification of key occupational risks, implementation of relevant OHS plans and procedures, and a monitoring system with defined indicators. The company works in line with the Brazilian regulatory standards on mandatory procedures related to occupational health and safety (Normas Regulamentadoras de Segurança e Saúde no Trabalho “ NR).

The processing plant in Caçapava has assigned a team in order to promote the health and protect the integrity of workers in the workplace (Serviços Especializados em Engenharia de Segurança e em Medicina do Trabalho “ SESMT), which is comprised of a health and safety engineer, 4 OHS technicians, an occupational physician, an occupational nurse and 3 nurse technicians. At the processing plant in Manaus, since the operation is small with limited OHS risks, the Operations Manager is responsible for implementing the SOPs. Both operations have a Workplace Risks Prevention Program (Programa de Prevenção e Riscos Ambientais “ PPRA) that identifies occupational risks and determine the appropriate control measures, and a Medical Control Program for Occupational Health (Programa de Controle Médico de Saúde Ocupacional “ PCMSO) which is a plan to monitor occupational health of all employees. These programs, which are updated on a yearly basis, were reviewed during appraisal. The use of personal protective equipment (PPE), such as steel-toe boots, ear plugs, mask, gloves and glasses was observed during IFCs site visit. For those functions involving hazardous activities, a specific authorization (Permissão de Trabalho “ PT) is required, which must be signed by the operational coordinator and an OHS technician. The company has also established a workplace accident prevention committee known as CIPA (Comissão Interna de Prevenção de Acidentes) that promotes various training and awareness efforts on workplace safety.

All OHS accidents are investigated by the OHS team and Workplace Accident Communication Forms (Comunicação de Acidente de Trabalho “ CAT) are sent to the Ministry of Social Security. At the plant in Caçapava, assigned OHS technicians supported by managers, supervisors and coordinators, undertake regular OHS internal audits to verify compliance with SOPs.

All employees have a medical file, and are subject to annual medical tests. From Sep 2014 to August 2015, the operations registered 24 accidents (mainly related to unsafe acts, such as failure to use personal protective equipment) that resulted in 325 lost workdays. In 2014, the lost time injury frequency rate (LTIFR, number of injuries per million work hours) was 14, compared to 24 in 2013 and 17 in 2015 (up to September). Since the beginning of 2015, the company has enhanced its OHS program by hiring an OHS Engineer, reviewing its SOPs and monitoring the OHS performance indicators closely. The plant in Caçapava has a contract with EMERCOR for emergency assistance in the case of emergency situations that cannot be treated at the onsite clinic, and to transport potential patients to the hospital in Caçapava. Each processing plant has a structured training program with an outlined annual training plan and budget for staff. During the appraisal, the plan was reviewed by IFC.

Workers Engaged by Third Parties: The vast majority of Wow Nutritions workforce consists of direct-hire employees. The company outsources some services to third parties, such as cleaning activities, employee restaurant and guard services. The companys contracts with these contractors include legal requirements related to proper labor practices, and Wow Nutrition pays them only on the basis of evidence that they are in compliance with the legislation. All third party workers go through OHS and other appropriate training (such as the Code of Conduct) during the induction session before they start working within the company area. Third party workers have access to the grievance mechanism provided in the Code of Conduct.

Supply Chain: Wow Nutritions beverages are manufactured from fruit pulp, concentrates, and sugar supplied from companies in Brazil and imported tea powder and soy protein, mainly originating from Asia. The diet and light food segment is manufactured from imported products from Asian suppliers. The top ten suppliers are responsible for around 60% of all supplied products (bottle packaging, cans, cardboard packaging box, sugar and concentrated juices and fruit pulps). In relation to the fruit pulp, Wow Nutrition has an extensive supply chain and sources from all over Brazil. The company is very selective in choosing its suppliers, and whenever possible, works with well-established companies, that adopt a solid quality control system in its operations.

Among Wow Nutritions supply chain there is a supplier of açaí pulp, based in Manacapuru, Amazonas. Whereas fruit pulp and concentrate corresponds to about 25% of the total procurement of Wow Nutrition, açaí accounts for less than 1% of this amount. However, IFC carried out a due diligence on this particular element of the companys supply chain since the harvesting of açaí berries is located in the Amazon region, and has been associated with safety risks and/or the participation of children in harvesting.

During the appraisal, IFC found that this supplier has been working in the region since 2007, hiring local workers in compliance with the Brazilian legislation to work at the processing plant and developing a good relationship with the local communities that supply the açaí berries, seeking to establish commercial partnerships that benefit all parties involved. IFC visited some of these communities along the river; however it was not possible to visit any traditional harvesting activity actually taking place due to the timing of the visit. Despite not seeing practices firsthand, IFC did discuss the overall supply chain, including harvesting, at length with the supplier to better understand the nature of the business and also the traditional practices employed to harvest berries.

The company that supplies açaí pulp to Wow Nutrition buys açaí berries from approximately 200 families within traditional populations living along the Solimões river, known as ˜ribeirinhos. Because they live in a challenging environment where the force of nature is ever-present, ribeirinhos learned to live in an environment full of constraints and challenges posed by the river and the rainforest. Most of the dwellings are built of wood, on stilts as they are located next to riverbanks, without running water and sanitation. The river plays a key role in the lives of ribeirinhos and rafts and boats are the only means of transport. Their means of livelihood include subsistence agriculture, fishing, and collection of açaí berries (from the açaí palm, which is native to South America and widely spread across the northern part of Brazil). Ribeirinhos have a vast amount of knowledge of the forest flora, fauna, river and soil. The geographical situation of many of these communities is a major factor limiting access to basic health and education services. The Brazilian legislation, Decree No. 6.040 from February 7th 2007, recognizes the existence of traditional peoples and communities, among which are ribeirinhos, establishing a national policy geared to the specific needs of these people “ the National Policy of Development for Traditional Peoples and Communities (PNPCT).

The main season for harvesting açai berries in Brazil is between January and June. Therefore, in October and November this supplier runs meetings with ribeirinhos in their own communities to discuss and agree on contracts for the season. During the appraisal, IFC verified that this açaí pulp supplier has developed good relationship with ribeirinhos, seeking to establish commercial partnerships directly with ribeirinhos in order to avoid middlemen. However, in some cases the company purchases the berries from intermediaries, due to the isolation of these communities and the difficulty they have to deliver the berries to Manacapuru. The açaí berries have a short lifespan, and the supplier must ensure that the entire process from harvesting to shipping and manufacturing takes place in no more than 36 hours. The supplier also has a good relationship with IDAM (Institute of Sustainable Agricultural and Forestry Development of Amazonas), which supports ribeirinhos with capacity building activities. The supplier has a processing plant that works from January to July, with approximately 25 workers (permanent and temporary). In 2014 the company produced 450 tons of açaí pulp, of which 300 tons were supplied to Wow Nutrition. A new plant is currently being built, which should be operational by 2016, in order to expand its processing activities.

Wow Nutrition has an operational procedure in place to identify, register and monitor suppliers through the following steps: (i) identification and qualification of suppliers based on the analysis of operational licenses and permits and the supplier quality management system; (ii) evaluation of suppliers proposals based on commercial and technical aspects; (iii) establishment of contractual agreements, which include clauses related to quality management, as well as environmental and social compliance with the Brazilian legislation (such as environmental permits and licenses, payment to workers, prohibition of child and forced labor). The contracts also acknowledge Wow Nutritions Code of Conduct and the grievance mechanism provided in the code; and (iv) monitoring of suppliers to ensure the quality of their products.

As noted above, IFC did not observe açaí harvesting taking place (as it was not the season for harvesting). As such, it is not possible to provide an opinion as to the safety risks or labor practices associated with harvesting. Later desk-based research described the traditional practices as involving young men climbing up to 15-20m up the palm trees to cut down the berries; this corroborated the description obtained from Wows supplier. Whereas such information provides some assurances to IFC, the possibility of risks associated with harvesting remains. As per the ESAP, therefore, Wow Nutrition will enhance its procedures regarding oversight of suppliers by developing a specific Code of Conduct for all suppliers and by including environmental and social criteria in its Suppliers Monitoring Program. Specifically, Wow Nutrition will make a particular effort to develop a monitoring program in partnership with the supplier of açaí pulp, that includes (i) mapping the açaí berries suppliers; (ii) identifying potential significant adverse risks and impacts associated with the supply chain; and, if discovered, (iii) implementing procedures to manage these risks.

Co-Packers: Wow Nutrition has a number of contracts with suppliers that are responsible for manufacturing and bottling part of the companys products, named co-packers. The contracts signed with these suppliers also include clauses related to quality management, environmental and social compliance with the Brazilian legislation (such as environmental permits and licenses, payment to workers, prohibition of child and forced labor). The contracts acknowledge Wow Nutritions Code of Conduct and the grievance mechanism provided in the code. Wow Nutrition performs regular audits to monitor co-packers quality management system. As per the ESAP, Wow Nutrition will enhance its procedures for monitoring co-packers by developing a specific Code of Conduct for all suppliers and by including environmental and social criteria in its Suppliers Monitoring Program.

Energy use and Green House Gases: Electricity to all Wow Nutrition subsidiaries is provided by the national grid. In addition, the Caçapava plant is equipped with backup generators that run on diesel in case of power outage. The plant has a boiler for production of hot water/steam that runs on natural gas.



The company has sought to implement a variety of resource efficiency measures to reduce the use of electricity, such as use of natural lighting in the processing areas (replacing opaque roof panels with translucent panels), use of ambient light level detection devices, use of LED lights (in 2015 the company has replaced conventional lights to LED lights in the Diet & Light production. Replacement for LED lights within the beverage production will take place in 2016). Energy consumption is being monitored at Caçapava and Manaus, and the data reviewed during appraisal were comparable with industry benchmarks indicating good international industry practices.



The company outsources all transportation services, i.e. transportation of ingredients from Manaus to Caçapava, and of final products from the Caçapava processing plant to the distribution centers. Third party suppliers are vetted and subject to contractural operating requirements.



Main source of air emissions are the boilers at the Caçapava processing plant. Inspection reports of the boilers were reviewed during appraisal, which confirmed that these are working according to local regulations. As per the ESAP, the company will start measuring its annual GHG emissions to ensure compliance with local regulations and WBG EHS Guidelines, and the results will be reported in the Annual Monitoring Report.



Water Consumption: In order to reduce its water consumption at the processing plant, in 2014 Wow Nutrition commissioned a third party company to identify opportunities associated with water efficiency. Water efficiency initiatives are currently being implemented, such as a water efficiency system named Reaqua (it is planned for 2016 that the wastewater will be recycled used at the gardens and toilets). The production in Caçapava has been undergoing many upgrades in the last 2 years to improve its efficiency and to ensure product quality. The company is implementing a water efficiency program to reduce the water consumption within its production processes (Running Time). With respect to water consumption, the amount of water consumed per liter of juice produced, which reached 2.43 in 2014 and 2.2 in 2015 (Jan-Sept), is favorable to industry benchmarks.



Wastewater Treatment Facility: The Caçapava plant is equipped with a wastewater treatment facility to treat the industrial wastewater using a combined system of equalization tank, flotation and aerobic digestion. The final effluent from this treatment system is discharged to surface waters. Although monitoring results reviewed during appraisal indicated that the effluent levels are in compliance with the local regulations, some of th
ese levels (e.g. BOD and COD) are above the WBG limits (i.e. BOD of 50 mg/l). Wow Nutrition will keep monitoring the wastewater effluent levels to ensure these within the regulatory and WBG limits.The results will be reported in the Annual Monitoring Report.



Waste Management: The solid wastes at the Caçapava plant include packaging wastes, food wastes, pallets, and other assorted solid wastes. These are sorted and are re-used, recycled or disposed of in accordance with local regulations. The hazardous wastes include batteries, metal, sludge from the wastewater treatment facility, discarded materials from the onsite clinic and from the laboratory. Such wastes are properly segregated and disposed by authorized waste contractors in locations authorized by the local Brazilian environmental authorities.

Community Health and Safety: The processing plants in Caçapava and Manaus are located in industrial areas and therefore are not adjacent to any communities. The plant in Caçapava is located in a parallel road to Rodovia Presidente Dutra, which is considered the main corridor between the two major metropolitan areas in Brazil, Rio de Janeiro and Sao Paulo. Wow Nutrition outsources all transportation services, and these suppliers are selected based on the analysis of documentation, experience and training of its drivers. Food safety of the company’s products is covered under HACCP certification requirements and the certificates were reviewed during appraisal.



Emergency Preparedness and Response: Complementing the existing emergency preparedness and response system in place (see above under PS1 – Emergency Preparedness and Response), Wow Nutrition is part of an Integrated Emergency Network (Rede Integrada de Emergência – RINEM) of the Paraíba Valley region. This network, which is coordinated by the Fire Department and have the operational support of the companies in the region, is comprised of tactical teams specialized in responding to emergencies.



Security Personnel: Wow Nutrition outsources its security personnel from private security firms, which are licensed by government authorities to provide security services. The company has unarmed guards at its facilities entrance to control site access in Caçapava and Manaus. These guards are trained to handle security issues in a professional manner. The training certificates were reviewed during the appraisal. There have been no incidents up to date.

Given the fact that Wow Nutrition’s processing plants are located in industrial areas, that the company outsources all its production inputs and does not operate its own transport fleet, there is limited interface with communities. Wow Nutrition supports local institutions in Caçapava with donations of the company’s products. The company has a general customer service and grievance mechanism (Fale Conosco) available at the website, through a toll free number and social networks. The customer service is managed by a third party company and the grievances are monitored with key indicators defined by the company. A consumer’s satisfaction survey is conducted on a monthly basis.

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Policy: Wow Nutrition will develop and approve an overarching policy defining the environmental and social objectives and principles that guide the company. The policy will include reference to requirements based on Brazilian laws and regulations, IFC Performance Standards, applicable WBG EHS Guidelines, HACCP; and ensure a corporate-level internal audit mechanism for assessing performance level of all operations, including performance targets and key performance indicators (KPIs). The policy will be communicated to employees at all levels and all functions, and as a good practice, it will be published on the company’s website and communicated to key stakeholders, where appropriate.	07/31/2016
Emergency Preparedness and Life and Fire Safety: Wow Nutrition will develop an Emergency Preparedness and Response Plan (Plano de Ação de Emergência – PAE) for the processing plant in Manaus.	07/31/2016
Suppliers, Co-packers and Contractors Management Program: Wow Nutrition will enhance its procedures regarding oversight of suppliers by developing a specific Code of Conduct for suppliers, co-packers and contractors by including environmental and social criteria in its Monitoring Program. Specifically, Wow Nutrition will make a particular effort to develop a monitoring program in partnership with the supplier of açaí pulp, that includes (i) mapping the açaí berries suppliers; (ii) identifying potential significant adverse risks and impacts associated with the supply chain; and, if discovered, (iii) implementing procedures to manage these risks.	11/30/2016
Labor Legislation: Wow Nutrition will provide evidence to IFC that the work plan (to reach compliance with Federal Law 8.213/91 for the employment of people with disabilities) has been approved by the Ministry of Labor.	05/30/2016
Worker Grievance Mechanism: Wow Nutrition will enhance its grievance mechanism to workers by developing a procedure that allows for anonymous complaints to be raised and addressed and by defining key indicators to be monitored.	07/31/2016
GHG Emissions: As per the ESAP, the company will start measuring its annual GHG emissions to ensure compliance with local regulations and WBG EHS Guidelines, and the results will be reported in the Annual Monitoring Report.	10/31/2016