While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The habitat where the project is developed is significantly modified and risks on biodiversity are considered limited to potential residual impacts which potentially occurred during setting up of the port more than a decade ago – PS6 is therefore not considered applicable and the assessment and mitigation of potential residual impacts are addressed under PS1 as part of the environmental and social (E&S) assessment to be undertaken. PS 7 is not considered applicable as no Indigenous Peoples or ethnic minorities are known to be adversely impacted; and there are no expected adverse impacts on cultural heritage within the project’s footprint hence PS 8 is not considered applicable.

The investment has been classified as Category B according to IFC’s Policy on Social and Environmental Sustainability as adverse environmental and social risks and impacts arising from the projects are limited, generally site specific and could be addressed through the implementation of Good International Industry Practice (GIIP). Key issues and impacts identified during appraisal, discussed in more detail in the following paragraphs, include: labor and working conditions including occupational health and safety; waste and dredged material management; traffic and transport safety management; contractor management; and land acquisition and involuntary resettlement including potential residual risks from land leasing activities conducted in 2012 for Phase 1 expansion.

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.

Identification of Risks and Impacts and Management Programs:



An Environmental and Social Impact Assessment was not conducted before commencement of existing MIP operations in 2003 given the lack of national requirements in this regard at that time. In January 2016, the Environmental Impact Assessment (EIA) Procedure of Myanmar formally came into effect, specifying the type and scope of EIA’s required for all investment projects with potential E&S impacts. As indicated in ESAP action #1/PS1, to address potential residual and also anticipated risks, the company will commission qualified international consultant(s) with demonstrated experience in GIIP to: (i) assess key residual E&S risks associated with existing company operations and develop appropriate corrective action plans to address such risks if found; and (ii) undertake an E&S assessment of the Phase 1 expansion including potential cumulative impacts from the expansion and from existing operations. The study will include a site investigation and assessment of the dredged material disposal practices and site.



The output from (i) and (ii) above will include management programs, monitoring programs, and corrective action plans (CAP) to address identified residual risks from existing operations (including potential biodiversity impacts on mangroves which might have existed in project area before port construction), and anticipated risks from planned expansion activities. Implementation of these will form part of overall efforts by the company to develop an appropriately scaled E&S management system (ESMS), to be applied to MIP operations on a day to day basis, as indicated in ESAP action #2/PS1.



Key elements of the ESMS will consist of: (i) the company’s E&S policy statement; (ii) appropriate Key Performance Indicators (KPI), well defined roles and responsibilities, and appropriate incentives; (iii) standard operating procedures (SOP) and related action plans on but not limited to the following aspects: E&S risk assessment and mitigation for future expansion; construction E&S management; life and fire safety, land acquisition and involuntary resettlement including the need to undertake resettlement and/or livelihood restoration planning and implementation, hazardous material (HAZMAT) and waste management; operational and community emergency preparedness and response; general labor and working conditions; worker accommodation; occupational health and safety (OHS); contractor and supplier labor and environmental management; on-site traffic and security management and access control; resource (water/energy/fuel) efficiency; community engagement and grievance management; and pollution and waste management including that of dredging operations; (iv) a monitoring and reporting system whereby KPI summary data and analysis will be regularly reported to senior management; and (v) a mechanism to regularly review ESMS implementation effectiveness.



To the extent possible, the ESMS will be dev
eloped to be consistent with Environmental, Social, Health, and Safety (ESHS) related requirements of the International Maritime Organization (IMO) Comprehensive Manual on Port Reception Facilities. The company will also ensure that, going forward, construction EPC contractual requirements include relevant aforementioned aspects of the ESMS.



During the early stage of implementation of the above, the commissioned international consultant will provide technical support and guidance to MAS, as part of an effort to support the company’s setting up and institutionalization of its ESMS.



Organizational Capacity:



The security department organizes daily staff briefings on security related matters, and the heads of all departments meet once a week to discuss various operational issues including those related to human resources, equipment maintenance, and health and safety. The Head of Security is responsible for: (i) day to day management of on-site security staff and access control, and of vehicles entering and exiting company premises; and (ii) facility safety management including life and fire safety. The Administrative Department oversees the following functions: (i) reception, storage, handling, and use of diesel as fuel for large equipment on site; (ii) waste management and disposal; (iii) energy, fuel, and water consumption; and (iv) human resource related matters including occupational health and safety, and employee accommodation aspects. There are currently no established procedures and reporting or monitoring mechanisms in place in relation to the above functions, and day to day practice is based on verbal communications between staff members. As part of the ESMS and E&S capacity development (ESAP #2/PS1 and #3/PS1), the company will assign an ESHS team under an organizational structure with well-defined roles and responsibilities.



Emergency Preparedness and Response (EPR):



Currently the company does not have a formal EPR system in place which identifies key types of emergency scenarios, analyses risks, develops preparedness and response actions, and trains staff and other stakeholders on EPR implementation. There is a 24/7 emergency response team on site, and fire-detection and fire-fighting equipment such as dry powder extinguishers, sprinkler systems, smoke detectors, is available in some of the buildings within the site. As part of its ESMS development, the company will put together SOPs related to EPR and ensure a functional EPR mechanism and that all relevant stakeholders know what to do in case of emergency scenarios. Refer to ESAP action #4/PS1.

Working Conditions and Worker Relationships:



The company has a direct workforce of about 600 full time workers, and another 200 drivers of container trucks or smaller vehicles. The workforce has an average age of about 30 and is 95% male in terms of gender ratio. Of the total head count, 50 persons work in the administration office and the rest are equipment operators, security staff, drivers, maintenance staff, and technicians working on the ground. Besides the above, the company also mobilizes up to 144 stevedoring workers on a day-wage basis (assuming four docked vessels each operating with two to three cranes), depending on business volume. Each stevedoring team works one shift of 8 hours plus 4 hours of overtime and consists of one supervisor, two operators, and six laborers, who on average all possess more than 10 years of experience in the industry.



To date, no formal employment contracts have been signed with any staff member, and terms of employment are verbally communicated and understood between the employer and the employed. MAS started a process of developing employment contracts in the latter half of 2015 with a goal of having a contract in place for all its employees.



Workers are organized by 12-hour shifts and paid monthly based on recorded working hours. The company states that working hours for most employees are within the 40 hour per week legal limit, plus up to 4 hours of overtime work per day but this varies from day to day depending on business volume. There are no fixed rest days but the actual practice is to have one day off per week plus time off during major religious holidays. Staff members are not enrolled in the national social security scheme or in medical insurance schemes. In case of work related injuries, the company will reimburse an employee directly for medical expenses incurred. As indicated in ESAP action #5/PS2, the company will ensure that all staff members are enrolled in national social security and provided with medical insurance.



Key means of management-worker communications are drop boxes, and day to day direct dialogue between workers and line supervisors. Where a worker feels an issues remains unresolved, s/he can escalate this to the human resource department or to the Deputy General Manager of MAS. The company does not provide any accommodation for its workers (see also relevant paragraph under PS5).



The company states that there has been a near-zero percent turnover in its workforce other than workers leaving the company voluntarily for personal or family reasons. There have not been any major retrenchment since the company commenced operations in 2004 and none is expected in the foreseeable future. As indicated in ESAP action #5/PS2, in the hypothetical case of any major retrenchment in future, the company will develop a retrenchment plan to minimize adverse impacts on employees.



As indicated in ESAP action #5/PS2, MAS will develop a set of detailed HR policies and procedure
s, and employee manuals, which will be consistent with requirements of national labor laws and of IFC PS2, including those on ensuring the rights of workers to form and join workers’ organizations and to bargain collectively should they wish to, as stipulated in The Labour Organization Law (Pyidaungsu Hluttaw Law No. 7 / 2011) and The Labour Organization Rules, Notification No. 1/2012.



Once developed, the HR policies and procedures will be implemented to ensure that all aspects of terms of employments and working conditions (as per national labor and IFC PS2 requirements) are clearly written into an employment contract for all workers (whether full time or day-wagers) and that such clauses (including any updates in future) are clearly communicated to all workers so that rights and responsibilities are clearly understood. As part of the procedures, the company will set up formal grievance mechanisms which are advertised and accessible to all workers including third party workers. The company will also ensure that labor practices of contractors and sub-contractors comply with relevant parts of its HR policies and procedures.



IFC’s review did not find any signs of the use of child or forced labor, and employment practices were consistent with principles of non-discrimination and equal opportunity. As part of the HR procedures, the company will implement worker age screening as an ongoing practice, with a particular focus on screening of contractor and sub-contractor workforces during planned construction activities.



Occupational Health and Safety (OHS):



According to the company, there have been no fatalities in the past two years, and four known cases of lost time accidents, of which three resulted in minor injuries to workers (e.g. a worker spraining his ankle while descending from the top of a container). However there is no system in place to systematically track OHS performance and non-compliances and therefore safety performance of the company, including accident statistics, cannot be assessed. The company implements measures to minimize risks associated with confined space situations, such as a procedure requiring the presence of at least 2 workers, but this is not consistent with the commonly adopted Buddy System (U.S. OSHA) whereby a third worker acting as a Safety Watch person would be positioned nearby to watch all persons working within a confined space and call for help in case of an OHS situation. During IFC’s review, it was observed that there were stevedoring workers standing on top of moving containers as they were unloaded from a docked vessel without harnesses and helmets, and there was another instance whereby a worker was seen standing directly underneath a suspended cargo container and without wearing a helmet. Some workers on site were seen wearing helmets and boots, while others were not. The company states that safety training is provided to full time workers, and attendance by experienced stevedoring workers is o
ptional. The company will ensure that safety training for all workers regardless of seniority or experience will be mandatory – refer to ESAP #6/PS2. During each of the day and night shifts, there are two safety supervisors on site inspecting operations.



The company recognizes that OHS management needs to be strengthened and, as indicated in ESAP action #6/PS2, it will commission a qualified and GIIP-experienced external consultant to undertake an OHS hazard assessment of all aspects of its operations, and develop and implement an OHS corrective action plan (e.g. ensuring that a Buddy System and other key measures are in place).

Resource Efficiency and Greenhouse Gas Emissions:



The port on an annual basis consumes 4.6 million kWh of electricity from the grid and 1.8 million liters of diesel oil used in backup generators and heavy equipment. There is no available information on water consumption but this is expected to be limited given the nature of port operations. The port’s annual greenhouse gas emission is estimated at 15,000 tons CO2 equivalent, attributable to consumption of grid electricity, diesel oil, and to the use of refrigerants (R22) in medium size commercial refrigeration units. As indicated in ESAP action #9/PS3, MAS (with support from external consultants as needed) will undertake an energy and water efficiency review of its operations and a review of the refrigerants used, relevant leakage points and controls, and based on review results, identify technically and financially feasible options to achieve efficiency improvements and R22 phasing out.



Pollution Prevention:



Air emission associated with the direct port operation arises from the consumption of diesel oil used in backup generators and heavy equipment; while waste water consists mainly of stormwater, sewage, and fugitive oils and lubricants from equipment on site. Large equipment such as ship to shore and mobile cranes are regularly inspected and serviced by technicians of vendors who sold the equipment to MAS. Sewage goes into the municipal sewer which is connected to a treatment plant. Dredged materials collected during maintenance dredging by the company’s two barges are transported up river to a dump site, which will be included in the E&S assessment required under PS1. There is an on-site diesel storage depot (85,000 liter maximum capacity) with diesel oil stored in five separate above ground storage tanks – the depot is access controlled and guarded by an assigned staff member. At about 50m away, there is an area where drums of lubricants and heavy machine oils are stored, and these were not access controlled. Moderate spillage of oils on the ground was found and some drums were left unsealed.



Air emissions from vessels docked at MIP emanate primarily from combustion emissions from ships’ propulsion and auxiliary engines and boilers, while likely types of vessel wastewater include sewage, bilge water, and vessel cleaning waste water. MAS states that the management/disposal/collection of vessel waste water is handled directly by Myanmar Port Authority (MPA) and the Yangon City Development Council (YCDC) and the company is not involved in the process.



As indicated in ESAP action #7/PS3 and as part of the EHS assessment under ESAP action #1/PS1, the company will identify a list of all types of solid waste, waste water, and air emissions (and their sources) arising from direct company operations, assess their current collection/storage/treatment/management/disposal methods and audit trails (including where dredged materials are deposited), and ensure that their discharge and emissi
on levels meet applicable World Bank Group (WBG) General EHS Guideline values, by commissioning testing of waste discharge/emission parameters. Based on the assessment carried out under ESAP action #1/PS1, the company will identify and take corrective actions to minimize potential environmental impacts and health and safety impacts on local communities in proximity to the dredged material dump site. A Dredging Management Plan will be developed consistent with the relevant requirements of the WBG EHS Guidelines for Ports, Harbors and Terminals, as indicated in ESAP action #8/PS3.



As part of the above, the company will also undertake the above exercise specifically focusing on all hazardous wastes generated and materials used, which pass through, or are stored on site, and implement a corrective action plan to ensure proper collection/storage/treatment/management/disposal/access control (e.g. ensuring that all such materials have material safety data sheets clearly displayed, and stored in access controlled areas). Related to the above, the company will also put in place and implement procedures to check for hazardous materials/goods/substances in container shipments passing through its port, and apply its company HAZMAT procedures to such shipments.



As indicated in ESAP action #8/PS3, the company, in concert with MPA/YCDC and the shipping lines, and as part of the consultant engagement described under ESAP action #1/PS1, will assess the various types of wastes arising from third party shipping vessels (but also including the two dredging barges owned and operated by MAS) and trucks which use the MIP port, and the current reception/storage/treatment/management/disposal of such wastes including an audit trial of where the wastes go. Based on assessment results, it will devise a corrective action plan (CAP). Working with MPA/YCDC and the shipping lines, the company will exercise duty of care to implementation of the CAP and facilitate proper waste and emission management in relation to docked vessels, by taking appropriate actions and providing appropriate facilities. Potential corrective measures may include switching to low-sulfur fuels where possible, requesting that vessels navigate port access areas at partial power, minimizing the practice of blowing soot from tubes or flues on steam boilers while in port, etc. The CAP will be consistent with principles of MARPOL 73/78 (International Convention for the Prevention of Pollution from Ships, 1973 as modified by the Protocol of 1978).

The existing MIP facility area is walled off and/or separated by a major road from the nearest local communities in Ahlone township which are located about 200m away. Security personnel on site are all employed by MAS and unarmed. According to the company there have been no known security incidents in the past. During its site visit, IFC noted that security was not strictly enforced and it was relatively easy for unauthorized outsiders to enter and stay within the facility; and persons who appeared to be third party laborers were seen in open areas, some resting on the floor in areas between containers. There was also not a clear mechanism in place to direct container trucks within the facility and manage traffic flow.



As indicated in ESAP action #10/PS4 and consistent with International Ship and Port Security (ISPS) code, the company will undertake a Port Facility Security Assessment of port operations followed by development and implementation of a Port Facility Security Plan. On site traffic management will be reviewed as part of the security assessment. As indicated in ESAP action #11/PS4, the company will also put in place procedures/mechanisms to manage potential traffic and road safety risks posed by MIP container trucks as they operate outside of the facility area on public roads (e.g. mandating that two drivers take turns if a truck is expected to travel more than a certain distance; requiring minimum rest hours by a driver particularly for long haul travel; taking steps to prevent drinking and driving or fatigued driving; providing training to drivers on defensive driving, emergency response, community health; etc).

Key stakeholder groups for the project are MAS staff and day wagers; third party shipping agents and truck drivers, MPA employees who have a regular presence and conduct business at the MIP facility areas; and persons affected by involuntary land acquisition and resettlement. During acquisition of land for the existing 102 acre operational area in 2012, the company had some extent of direct interactions and consultations with affected land users in a MPA-managed process. Engagement with staff and contract workers, and with third party persons on site, happen throughout the course of day to day business operations, but it is not formalized. As indicated in ESAP action #2/PS1, the company does not have written procedures on overall stakeholder engagement, including local community engagement, and grievance mechanisms, and will develop and implement these as part of its E&S management system.

Contact Person: Mr. Chris O’Connor and Ms. Ma Cherry Trivedi
Company Name: Organizational Development Advisors acting for and on behalf of MAS
Address: No. 7/2 (B), Strand Road
Ahlone Township, Yangon, Union of Myanmar, 557507
Tel: +959 4210 14 364
Email: mailto:chris@ayuroma.com; mailto:macherry@ayuroma.com

Contact Person: Captain Ko Ko Htoo
Company Name: Myanma Annwa Swan A Shin Group (S) Co. Ltd.
Address: No. 7/2 (B), Strand Road
Ahlone Township, Yangon, Union of Myanmar, 557507
Tel: +65 6708 8988
Email: mailto:ukkh555@gmail.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
The company will commission qualified international consultant(s) with demonstrated experience in Good International Industry Practice (GIIP) to support its efforts in the following areas: (i) undertaking an assessment of all key E&S aspects of company operations (including planned expansion) to identify residual risks and develop appropriate corrective action plans to address such risks; (ii) undertake an E&S impact assessment of the Phase 1 expansion area; (iii) provide technical support and guidance to the company during implementation of the corrective action plans (CAP), and of actions in this document; (iv) support the company as it develops the ESMS, including the provision of introductory, high-level training to the company E&S team (see next action). Indicator 1: International consultant contract signed	02/28/2016
Indicator 2: Final EHS assessment available	05/31/2016
Indicator 3: Implementation final status report available	12/31/2016
The company will develop an appropriately scaled E&S management system (ESMS) which will consist of: i) the company E&S policy statement; ii) Key Performance Indicators (KPI), well defined roles and responsibilities, and appropriate incentives; iii) standard operating procedures (SOP) and related action plans on but not limited to the following aspects: E&S risk assessment and mitigation for future expansion; construction E&S management; life and fire safety, land acquisition and involuntary resettlement including the need to undertake resettlement and/or livelihood restoration planning and implementation, hazardous material (HAZMAT) and waste management; operational and community emergency preparedness and response (EPR); general labor and working conditions; worker accommodation; occupational health and safety (OHS); contractor and supplier labor and environmental management; on-site traffic and security management; resource efficiency; community engagement and grievance management; mitigating potential biodiversity impacts on mangroves which might have existed in project area before port construction; pollution and waste management including that of dredging operations; iv) a monitoring and reporting system whereby KPI summary data and analysis will be regularly reported to responsible E&S staff and senior management; and v) a mechanism to regularly review ESMS implementation effectiveness. To the extent possible, the ESMS will be developed to be consistent with ESHS related requirements of the International Maritime Organization (IMO) Comprehensive Manual on Port Reception Facilities. Indicator: Final ESMS available	07/31/2016
The company will ensure that, going forward, construction EPC contracts include the aforementioned aspects.	07/31/2016
The sponsor will assign a dedicated environmental, social, health, and safety (ESHS) team under an ESHS organizational structure to be fully responsible for implementation of the ESMS, actions in this document, and corrective action plans. The structure will define roles, responsibilities, and reporting relationships clearly. The company will ensure that assigned ESHS team members receive relevant E&S training and that training records and transcripts are available.	05/31/2016
As part of its ESMS development, the company will put together SOPs related to EPR and ensure a functional EPR mechanism and that all relevant stakeholders know what to do in case of emergency scenarios. Indicator 1: EPR SOP available	07/31/2016
Mock EPR drill exercises carried out	10/31/2016
The company will develop a set of detailed human resource policies and procedures, and employee manuals, which will be consistent with the requirements of national labor laws and of IFC PS2, including those on ensuring the rights of workers to form and join workers’ organizations and to bargain collectively should they wish to. The company will ensure that all aspects of employment conditions and clauses are clearly written into an employment contract for all workers (full time; part time; and those employed on a day-wage basis) and that such clauses are clearly communicated to all workers. As part of the procedures, the company will: (i) set up formal grievance mechanisms which are advertised and accessible to all workers including third party workers; (ii) implement worker age screening as an ongoing practice, with a particular focus on screening of contractor and sub-contractor workforces during planned construction activities; (iii) develop a retrenchment policy to minimize adverse impacts on workers in the hypothetical case of major retrenchment; and (iv) ensure that all workers are enrolled in the national social security scheme and are covered by an adequate medical insurance scheme. The company will also ensure that relevant parts of its HR policies and procedures apply to labor practices of contractors and sub-contractors.	06/30/2016
The company will commission a qualified and GIIP-experienced external consultant to support a OHS hazard point assessment of all aspects of its operations, and develop an OHS corrective action plan (e.g. ensuring that a Buddy System and other key measures are in place). This can be the same person/entity as the external consultant under 2/PS1 if the latter possesses the necessary expertise and experience. Indicator 1: Consultant contract signed	02/28/2016
Indicator 2: OHS assessment and CAP available	05/31/2016
Indicator 3: Implementation final status report available	10/31/2016
The company will ensure that safety training for all workers regardless of seniority or experience will be mandatory. Indicator: Training records available as annex in Annual Monitoring Reports submitted to IFC	03/31/2017
As part of the EHS assessment under #1/PS1, the company will identify a list of all types of solid waste, waste water, and air emissions (and their sources) arising from direct company operations, assess their current collection/storage/treatment/management/disposal methods and audit trails (including where dredged materials are deposited), and ensure that their discharge and emission levels meet applicable World Bank Group (WBG) General EHS Guideline values, by commissioning testing of waste discharge/emission parameters. As part of the above, the company will also undertake the above exercise specifically focusing on all hazardous wastes generated and materials used, which pass through, or are stored on site, and implement a corrective action plan to ensure proper collection/storage/treatment/management/disposal/access control (e.g. ensuring that all such materials have material safety data sheets clearly displayed, and stored in access controlled areas). Indicator: Waste and hazardous waste assessment, audit trail, and CAP completed	05/31/2016
Indicator 2: CAP implementation report available	10/31/2016
Related to the above, the company will also put in place and implement procedures to check for hazardous materials/goods/substances in container shipments passing through its port, and apply its company HAZMAT procedures to such shipments.	05/31/2016
The company will exercise duty of care to facilitate proper waste and emission management in relation to docked vessels, by taking appropriate actions and providing appropriate facilities. The company, in concert with MPA/YCDC and the shipping lines, and as part of the consultant engagement described under PS1, will assess the various types of wastes arising from third party shipping vessels (but also including the two dredging barges owned and operated by MAS) and trucks which use the MIP port, and the current reception/storage/treatment/management/disposal of such wastes including an audit trial of where the wastes go. Based on assessment results, it will devise a corrective action plan (CAP). Working with MPA/YCDC and the shipping lines, it will exercise duty of care to facilitate implementation of the CAP. The CAP will be consistent with principles of MARPOL 73/78 (International Convention for the Prevention of Pollution from Ships, 1973 as modified by the Protocol of 1978). Indicator: Waste and hazardous waste assessment, audit trail, and CAP completed	05/31/2016
The company will also develop a dredge management plan (consistent with relevant requirements of the WBG EHS Guidelines for Ports, Harbors and Terminals) and take corrective actions to minimize potential health and safety impacts on local communities in proximity to the dredged material dump site.	09/30/2016
The company (with support from external consultants as needed) will undertake an energy and water efficiency review of its operations and a review of the refrigerants used, relevant leakage points and controls, and based on review results, identify technically and financially feasible options to achieve efficiency improvements and the phasing out of the use of R22 as a refrigerant.	09/30/2016
As part of 2/PS1 and consistent with International Ship and Port Security (ISPS) code, the company will undertake a Port Facility Security Assessment of port operations followed by development and implementation of a Port Facility Security Plan, and by implementation of the company's on-site traffic and security management plan which will be based on assessment results.	07/31/2016
The company will put in place procedures/mechanisms to manage potential traffic and road safety risks posed by MIP container trucks as they operate outside of the facility area on public roads.	09/30/2016
The company, with support from a qualified and GIIP-experienced external consultant, will assess the 2012 land acquisition and resettlement process (applicable to its existing operational site and Phase 1 expansion) against IFC PS5 requirements, with a particular focus on land users without land titles or recognizable legal claims to land. It will develop and implement a CAP to address identified gaps in compensation and livelihood restoration if any. Indicator 1: consultant contract signed	02/28/2016
Indicator 2: Assessment & CAP finalized	06/30/2016
Indicator 3: CAP implementation report available	10/31/2016
The company will ensure that employees and families currently residing within the MIP facility area relocate away and that all housing structures are removed. Due process and consultation should be ensured, and compensation at full replacement costs should be provided to affected employees for lost structures. The company will also exercise duly of care to ensure that affected employees (except those expected to remain with the company only in the short term) move into new housing of reasonable quality and hygienic and safety conditions, and at a reasonable distance to MIP so that the employees can easily commute to work. Appropriate actions will be captured in a simplified Resettlement Action Plan (RAP) to be prepared by the company to guide the resettlement process. Indicator 1: RAP available	05/31/2016
Indicator 2: Relocation completed	09/30/2016
Indicator 3: Structures removed	12/31/2016
Indicator 4: Compensation received by employees	06/30/2016
As part of 2/PS1, the company will develop a set of procedures on land acquisition and involuntary resettlement consistent with IFC PS5 requirements, which will be applied to all ongoing, and future land acquisition related activities should they occur.	05/31/2016