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
Based on IFC’s review of the project, PS5: Land Acquisition and Involuntary Resettlement does not apply because all land required for the terminal was purchased by the company at market rates on a willing-buyer, willing-seller basis and no involuntary resettlement is associated with the project. PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply because the project is located within the confines of the Yuzhny port, in a modified habitat not containing significant biodiversity value. PS7: Indigenous Peoples is not applicable as there are no indigenous peoples in the project area, as per the definition used by the World Bank Group; and PS8: Cultural Heritage is not applicable as the project is not located in the area of known historical or cultural significance and does not impact any known cultural heritage.

This is a Category B project in accordance with IFC’s Policy on Social and Environmental Sustainability as adverse environmental and social risks and impacts arising from the project are limited, generally site specific and could be addressed through the implementation of the Good International Industry Practice (GIIP). The terminal and the berth will be constructed within the environs of an established port, will be operated in accordance with recognized E&S and OHS management systems and assuming due application of such systems, will not pose a significant risk to the surrounding environment or communities. Key issues include: (i) management of sediment mobilization and seawater quality due to dredging activities and disposal of approximately 5.0 million cubic meters of dredged material at disposal sites located within Ajalyk Estuary, (ii) management of increased truck traffic due to operations of the terminal, (iii) mitigation of noise associated with construction works, and (iv) occupational health & safety (OHS) management.

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.

Policy: The company recognizes environmental and social management as a corporate priority and is committed to develop and adopt an overarching policy defining the environmental and social objectives and principles to achieve sound environmental and social performance as noted in the ESAP action #1. The company will communicate the policy to employees and contractors.



Identification of Risks and Impacts: The project company hired an E&S consultant to prepare EIAs for the terminal and the berth as required under the Ukrainian EIA legislation. The company obtain approvals of the Ukrainian authorities in May 2016. The company will perform a second round of public consultation for the project EIAs and update the project SEP as defined in ESAP action #5. The EIA for the dredging of the main shipping channel for connecting the berth to the inner channel of the Port of Yuzhny will be prepared under the responsibility of the Yuzhny Sea Ports Authority.



In future, the company will prepare an ESIA for the second phase of the terminal and berth development consistent with IFC Performance Standards and with a special focus on cumulative impacts and management and will update the project construction and operational environmental and social management plans accordingly. This is not, however, part of IFC’s financing of the project under consideration, as mentioned in the project description, and is not considered further in this review summary.



Management Programs: Based on the mitigation measures identified in the EIAs for the terminal and the berth and in order to ensure compliance with Ukrainian legislation and IFC requirements, the company will develop, implement and maintain a construction environmental and social management plan (CESMP) and associated procedures as noted in ESAP action #3. The CESMP will define roles and responsibilities of the company and its contractors, and will be a dynamic operational document which will evolve over the course of the construction and commissioning phase. The CESMP will include a suite of management plans: air emissions and dust management plan; traffic and transportation management plan; noise and vibration management plan; soil and groundwater management plan; waste management plan (for hazardous and non-hazardous waste); oil and chemical spill contingency management plan; emergency preparedness and response plan for construction phase; community health management plan and procurement plan; dredging management plan; cultural heritage chance find procedure; security plan; contractor management and monitoring plan; and environmental monitoring plan.



Prior to operations, the company will develop, implement and maintain the operational environmental and social management plan (OESMP) and a suite of E&S management plans that are consistent with the local legal requirements and the IFC PS requirements as noted in the ESAP action #4.



Internal audits of the implementation of the project E&S management pr
ograms, including contractors’ management plans (and, as needed, their subcontractors) will be carried out and results of the audits will be compared over time to measure E&S performance.



As part of the project design and prior to contractor mobilization, the company will issue a series of regulations and standards on health, safety, security, environmental and social performance which the company expects the general contractor and subcontractors to comply with. The company will develop a contractor management and monitoring plan in order to implement a consistent E&S management and monitoring system during construction as noted in the ESAP action #3. This plan will include at a minimum clear assignment of the company’s and contractors’ E&S responsibilities, company’s commitments in terms of E&S monitoring and contractors’ supervision, and company’s and contractors’ E&S performance and compliance reporting. As noted in ESAP action #3, the contractors will be required to ensure that relevant requirements under the project’s construction permit, the company’s environmental and social performance requirements and the relevant EIA’s commitments are incorporated in their procedures with a clear description of how they will be executed during the works. Prior to the start of the construction, the company will require the contractors to submit their E&S management plans, appropriate to their scopes of work, and achieve compliance with the project CESMP.



Organizational Capacity and Competency: MV Cargo is in the process of leveraging TIS Group Environmental Health and Safety and Social (EHS) resources and hiring new staff to identify project-specific team. TIS Group EHS department has a team of four environmental specialists that regularly conducts environmental audits of the five terminals in the Port of Yuzhny and manages the annual monitoring program of ambient air quality, sea water quality, bottom sediment quality, and radiation. MV Cargo organization will include a dedicated EHS manager and team of qualified EHS professionals in charge of contractors’ supervision, implementation of E&S management plans, and development and coordination of the E&S assessments and studies as noted in ESAP action #2. The project general contractor will be required to provide qualified and dedicated EHS personnel on site and will be responsible for EHS management of their subcontractors consistent with MV Cargo EHS performance requirements.



Emergency Preparedness and Response: The project site is located approximately 2.2 km away from a sunflower oil plant and approximately 3 km far away from a fertilizer plant. As required, these plants have emergency preparedness and response management plans, taking into account TIS Group’s terminals at the Port of Yuzhny, other facilities and neighbouring communities. Emergency drills are held by the fertilizer plant regularly, with participation of all terminal operators of the Port of Yuzhny. TIS Group at the site h
as its own clinic with an ambulance and a fire brigade, which can be deployed to surrounding villages in case of demand. For the project construction and operation, the company will develop site specific emergency preparedness and response management plans as specified in ESAP actions #3 and 4. The plans will include an overview of risks and emergency scenarios, emergency preparedness and response procedures, spill prevention and control measures, roles and responsibilities, notifications and communications (including alarms, warning systems and back-up systems), equipment and resources. The plans will be integrated in the current TIS Group emergency preparedness and response system and will be aligned with IFC requirements. The procedures will include a specific training program for employees and contractors and will be developed in coordination with local authorities, including awareness / notification to the community, as appropriate. Contractors will be required to be aligned with the company’s plan and to develop their own project-specific emergency and response measures procedures as part of their management plans.

The project is estimated to create up to 350 temporary jobs during construction and an additional 280 jobs during operations, to be available mainly for local residents.



Human Resources Policies and Procedures: In the early project phase TIS Group’s human resources (HR) policies and procedures will be used for MV Cargo’s workforce. TIS Group employs around 2400 workers in Ukraine. TIS Group HR policies are composed of an employment policy, regulation on adaptation of personnel, a code of conduct and social policy, and dedicated policies on topics such as occupation health and safety (OHS), and code of conduct, that have been prepared in line with the Ukrainian Labor Law. MV Cargo HR policies and procedures specifically will outline requirements in relation to terms of employment, working hours and overtime, training, leave, retirement, employment welfare, disciplinary actions, health and safety, child labor, forced labor, wages and benefits, the principle of equal opportunity, worker’s organizations, fair treatment and non-discrimination and grievance mechanisms, OHS, and retrenchment. As indicated in ESAP action #7, the HR policies and procedures will be part of the package provided to all employees of the MV Cargo and they will be made accessible at the company’s facilities. Contractors will be required to comply with labor law and company’s HR policies, and the company will monitor their compliance.



Workers’ Organization: The freedom of workers association is guaranteed by the Ukrainian legislation in line with the ILO Convention 87 to which Ukraine is a signatory, therefore it is integrated in the TIS Group policies and will be integrated in MV Cargo HR policies too. TIS Group provides the required conditions for the establishment of a labor union that currently has 400 members.



Grievance Mechanism: TIS Group has established a grievance mechanism for workers. TIS Group has an ‘Open door policy’ meaning that every employee can discuss any personal and work-related problem, proposal, complaint or concern with the Deputy General Director of Human Resources. Besides, the company has a more formal system to communicate complaints to the company’s senior management. In addition, there is a telephone helpline and two boxes for anonymous complaints. Each complaint filed is considered by the HR team and is not left unattended. A grievance mechanism has been designed to direct workers complaints through a process that protects the confidentiality of the worker and ensures that workers can raise their concerns and complaints other than to immediate supervisors. MV Cargo will ensure that a grievance mechanism, be established in line with TIS Group good practices and be applied for the project direct and contracted workers prior of commencement of construction works, as per ESAP action #9.



Protecting the Work Force: MV Cargo will explicitly reject in its HR policy the use of any form of forced or compulsory labor and child labor consis
tently with ILO Conventions 29 and 182 to which Ukraine is a signatory.



Occupational Health and Safety: MV Cargo is leveraging TIS Group OHS resources in the early project phase and in the process of hiring an OHS manager. TIS Group has an OHS unit with a senior OHS manager and 10 OHS coordinators. The unit is responsible for ensuring that the company OHS procedures are implemented in line with Ukrainian legislation, that suitable personal protective equipment is used by all employees, that incidents are investigated properly and that appropriate training is provided to all employees. The MV Cargo OHS unit will develop a project-related OHS management plan and oversee the activities on the project site during construction and operation, and ensure that all contractors meet the national law and adopt the company’s requirements, as per ESAP action #8.



The project contractors and equipment suppliers (portal cranes, wheel loader, mobile cranes, etc.) will be required to adhere to the company OHS management plan and procedures, and to implement health and safety communication and training programs to prepare workers to recognize and respond to workplace hazards. Construction safety specifications are integral part of the tender documentation for the main contractors and require that each contractor submits a site specific OHS management plan for approval prior to the commencement date, and appoints dedicated OHS officers.

Resource Efficiency: The annual power consumption for project equipment (portal and gantry cranes, mobile pic- and place devices), the grain terminal, internal electrical equipment, and pumping stations, current collectors of plumbing facilities, external lighting is estimated to be approximately 10,250 megawatt hours annually. Annual consumption of natural gas is estimated to be approximately 1.98 million cubic meters. Water consumption is estimated to be approximately 3.940 thousand cubic meters annually and will be provided from the public water supply system of Fontanka village.



Greenhouse Gas Emissions: The total greenhouse gas emissions of terminal construction phase (2016-2018) have been estimated at approximately 10,500 tons CO2 equivalent. Annual greenhouse gas emissions of the terminal and berth operation at the end of the first development phase are estimated at approximately 12,000 tons CO2 equivalent, comprising only annual electricity consumption from the national power grid and combustion of natural gas. GHG emissions associated with the combustion of gasoline and diesel in terminal mobile vehicles and disposal of waste generated by terminal will be accounted for by the company during operations.



Adaptation on climate change: The berth is sheltered from direct waves entering into the Ajalyk Estuary from the Black Sea and its zero reference level is - 0.66 meter relative to Baltic system of heights. The company assessed climate change impacts in respect to the increased intensity of rainfall, storm surge, high speed winds and expected sea level rise over the project lifetime and adaptation measures, such as robust dust suppression systems, drainage systems dimensioned to cope with projected intense rain events, upgraded storage facilities to accommodate extreme events, asset and equipment procurements against the future operating environmental requirements, will be incorporated in the berth technical design.



The project construction phase will generate limited, short-term impacts related to soils, air quality, noise and waste management, seawater quality and sediment. The project EIAs include management actions to minimize and mitigate these impacts.



Air Quality: During construction activities emissions of gases and particulates (dust) are expected from earth and demolition works, vehicle traffic and equipment movements and loading / unloading of the inert materials. The EHS management plans will include specific requirements to address these issues, including inspections and enforcing vehicle speed control, keeping construction material wetted down while on storage, covering trucks transporting earth material and controlling dust on access roads through the use of water. Spill control procedures will be implemented. In respect to the operational phase, MV Cargo will ensure that technical specification of air emission control measures that will be included in the final design of berth and terminal are up to good in
ternational industry practice (GIIP), as per ESAP item #4.



Noise: Noise generated during construction will include the use of heavy equipment such as front loaders and trucks. Management and mitigation measures will include adequate maintenance of vehicles and equipment and carrying out monitoring of noise when new activities are introduced. During terminal operations there will be noise generated from the operation of cranes, transport vehicles, and other machineries equipment at the terminal facilities but these levels will be maintained below those established in local regulations and the noise section of the WBG EHS guidelines.



Wastewater and Storm Water Management: The preliminary design of the terminal and berth includes infrastructure and equipment to minimize, segregate and pre-treat storm water runoff and wastewater. The terminal and berth will be equipped with wastewater pre-treatment systems before wastewater is discharged to the berth sewage collection system and then to the sewerage system of the Port of Yuzhny that is connected to the municipal waste water plant. The storm water runoff will be collected from the area of the terminal and the berth by a separate storm water collection system and after pre-treatment in oil water separators will be discharged to the TIS Group storm water collection system at the Port of Yuzhny. The company will prepare, implement and maintain a site specific wastewater management plan for the project construction and operational phases as per ESAP actions #3 and 4.



Liquid waste generated by ships (i.e., bilge waste, ballast water, sewage and used oils) at the terminal will be under the responsibility of the Port of Yuzhny authority and will be managed by third party contractors that have to be licensed to operate in the port.



Wastes: The project is expected to generate moderate quantities of non-hazardous waste and limited amounts of hazardous waste during construction and operation. The company will prepare, implement and maintain site specific waste management plans (WMPs) for the project construction and operational phases as per ESAP actions #3 and 4. The plans will address in detail options for waste minimization, waste recovery and/or waste disposal. The WMPs will cover all types of waste, contain preliminary estimates of the quantity of each type of waste and provide a clear identification of waste management measures, including proposed waste disposal sites and requirements for waste processing contractors in accordance with Ukrainian legislative requirements and GIIP.



Hazardous Materials: Only small amounts of hazardous materials (paints, solvents, lubricants) will be held at project site, and these will be stored and handled in accordance with good international industry practice. Fuel tanks for vehicle refueling will be fitted with appropriate containment features to prevent spills to environment. No hazardous cargoes will be handled at the new terminal.



Dredging related
to the berth: The volume of dredged material at the end of construction is estimated to be approximately 714 thousand cubic meters. According to the EIA for berth, the results of the sediment quality survey to quantify the concentrations of oil, ammonia nitrogen, nitrites and nitrates indicated compliance against Ukrainian legal requirements. Dredged material will be dumped at three dedicated disposal sites approved by the Ukrainian authorities within the Ajalyk Estuary. Actual capacity of the disposal sites was assessed in July 2015 and the assessment confirmed the adequacy of the residual capacity to receive the estimated volume of dredged material. The EIA for berth presented a comparison of characteristics of sediment taken from the disposal sites within estuary and the sediments at the location of berth, providing assurance that characteristics of the sediment types are comparable. As indicated in ESAP action #10, TIS Gidrotekhnika in charge of the berth related dredging works will prepare dredging management and monitoring plan prior to commencement of dredging activities. The plan will adhere to the requirements of Ukrainian legislated requirements and Dredged Materials Management section of the WBG EHS guidelines for Ports Harbours and Terminals. The plan will also define the implementation of mitigation measures to minimize impacts on water quality. The plan will define the implementation details in terms of dredging and dredgers, blasting requirement, disposal methods, and assessment of disposal site options within the Ajalyk Estuary area, mitigation measures to minimize impacts on water quality, benthic habitat and marine ecosystem.The plan will define seasonal constraints if relevant, with specific reference to fish. Required monitoring and control measures will include plume monitoring and water quality monitoring, beach and banks, as well as navigational safety.



Dredging related to the main shipping channel for connecting the berth to the inner channel of the Port Yuzhny (approximately 4.2 million cubic meters of dredged material): According to the agreement signed in March 2016, the Authority and its contractors will design, implement, manage and monitor dredging works according to the approved EIA, obtained permits and ensuring implementation of dredging works in accordance to the all relevant Ukrainian legal requirements.



Reclamation related to berth requires approximately 450,000 m3 of fill material. To date, approximately 300,000 m3 of fill material has already been placed. The fill material was sourced within the TIS terminal complex, having been generated by excavation work associated with the upgrade of the railway network. According to TIS Group EHS representatives, the excavated areas were previously undeveloped and soil analyses performed did not identify any legacy contamination.

The primary risk to community health and safety identified is associated with traffic safety and dust generated by the transport of construction materials and equipment during construction and by an increased volume of truck and rail traffic during the operations phase. The local road infrastructure comprises the roads Odessa – Yuzhny and Odessa – Mykolayiv, both with two lanes traveling in opposite directions and with surface in poor condition. During the high season of grain harvest both roads are jammed with parked trucks waiting to upload at the Port of Yuzhny terminals. According to the terminal design approximately 140 trucks per day will be uploaded in the busiest months of the year. The road conditions affected by shipment of grain by trucks such as traffic safety, road condition, congestions, and availability of parking space for parking are also concerns of the local communities and other project stakeholders raised and recorded during public consultations held in 2011.



MV Cargo included in the terminal design an area for parking trucks between weighing/sampling areas and uploading area with a capacity of approximately 100 35-ton trucks in order to reduce a traffic congestions at local roads in busiest months. In addition, as indicated in ESAP action # 3, the company will develop a traffic and transportation management plan for the project construction phase that will define not only the safety features for traffic inside the terminal, but also a series of measures aimed at minimizing risks and impacts on community safety and health outside the terminal, in coordination with the Port of Yuzhny and Odessa regional authority. The project contractor will also be required to develop its transport management plan. Measures will include: (i) traffic risk assessment and measures to minimize risk of road traffic related incidents; (ii) traffic safety awareness programs along key transport routes to the site, in particular in high risk areas, such as crossings of heavily populated areas and with presence of schools; (iii) dust suppression techniques on temporary construction roads, particularly through the nearby resident area and entrance to the terminal; and (v) vehicle inspections and maintenance requirement. Contractors will ensure that heavy duty vehicles used for transporting material to the project site will not cause overloading on roads, bridges or culverts and conform to requirements of the competent authorities.



Security Personnel Requirements: During the construction phase the project site will be secured by unarmed TIS Group security personal that have clear instructions on the objective of their work and permissible actions. TIS Group performed a security risk assessment to understand risks involved in their operations. During the project operational phase MV Cargo will contract a private security service provider to ensure safe and controlled access to the terminal facilities and berth. All contracted security personnel w
ill not be armed and will be trained in line with the International Code of Conduct for Private Security Service Providers.

Stakeholder Engagement Plan: The company updated the project SEP in August 2016. The SEP has identified and prioritized key project stakeholder groups, provided a strategy and time table for sharing information, and described resources and responsibilities for implementing stakeholder engagement activities.

Information Disclosure: The company disclosed relevant project information which will provide interested stakeholders with information about its operations, recent events, management staff contact details and the project on its web site once it is operational. The project relevant information is disclosed on other relevant sites such as Ukrainian Sea Ports Authority (uspa.gov.ua). The EIAs for the berth and the terminal and the SEP will also be posted at company’s website (http://www.mv-cargo.com), and are disclosed on IFC’s disclosure portal together with this ESRS. The company disclosed non-technical summary of the EIAs for berth and terminal in the local newspapers, on March 30, 2016 and on April 30, 2016 respectively.

Consultation: The first round of public consultations to discuss the site selection process for the berth and environmental impacts of the construction and operation of the new berth facility took place in the town of Kominternovo of Odessa Oblast on February 1, 2011. In accordance with Ukrainian legal requirements, a statement on environmental consequences of the construction of the berth was published on a local newspaper (“Slava Khliboroba”) on June 11, 2011. The company will implement a second round of public consultations to present the outcomes of the EIAs for berth and terminal as per ESAP action # 5.

Grievance Mechanism: The construction and operation of the terminal and the berth will require managing engagement with nearby communities and stakeholders and establishing accessible and simple mechanisms to receive and process potential complaints. The SEP defines a provisional set of steps to inform the surrounding communities about the project construction and operation activities as well as their adverse and positive impacts, management and mitigation measures.

TIS Group designed and is implementing and maintaining a grievance mechanism established at the level of the Port of Yuzhny. However, MV Cargo will establish its own grievance mechanism to cover project construction and operational phases as per ESAP action # 6.

Contact Person: Oksana Grigorieva, Project secretar
Company Name:  MV Cargo Ltd
Address: Alexey Stavnitser str., 60, Vizirka village, Odessa region, 67543, Ukraine
Email:  mailto:mail@mv-cargo.com
Phone: +380482300725

Broad Community Support is not applicable for this project

MV Cargo(37312) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
1. MV Cargo will develop and adopt an overarching policy defining the environmental and social objectives and principles that should guide the project to achieve sound environmental and social performance and incorporating reference to IFC Performance Standards	30-Jan-2017	Completed	Completed	11/30/2017
2. MV Cargo will identify and hire an EHS manager with experience in the application of good international industry practice to strengthen company EHS management system development and implementation (e.g. company EHS policy, operationalization of management plans, internal auditing and reporting framework, EHS committee, contractor’s supervision, and communication on EHS aspects to external interested parties).	30-Sep-2016	Completed	Completed	11/30/2017
3. MV Cargo will develop, implement and maintain a construction environmental and social management plan (CESMP) consistent with the project EIAs, local regulation, IFC PS requirements and which includes: air emissions and dust management plan; traffic and transportation management plan; noise and vibration management plan; soil and groundwater management plan; waste management plan (for hazardous and non-hazardous waste); oil and chemical spill contingency management plan; emergency preparedness and response plan for construction phase; community health management plan and procurement plan; dredging management plan; cultural heritage chance find procedure; security plan; contractor management and monitoring plan; and environmental monitoring plan. As part of the air emission and dust management plan, MV Cargo will provide technical specification of air emission control measures included in the final design of berth and terminal and relevant for the project operational phase. Prior to the start of the construction, MV Cargo will require from a general project contractor to submit its E&S management plan consistent with the project CESMP. The project CESMP and contractors E&S management plans will be sent to lenders for approval prior to commitment date.	30-Oct-2016	Completed	Completed	11/30/2017
4. MV Cargo will develop and implement an operational environmental and social management plan (OESMP) consistent with the project EIAs, local regulation and IFC PS requirements.	02-Jan-2019	Completed	Completed	11/19/2019
5. MV Cargo will implement the second round of public consultations in respect to the EIAs for the terminal and the berth.	30-Jan-2017	Completed	Completed	11/30/2017
6. MV Cargo will develop and implement a grievance mechanism for Affected Communities that will cover both construction and operational phases in accordance with IFC PS 1 requirements.	15-Jan-2017	Completed	Completed	11/30/2017
7. MV Cargo will ensure that all human resources policies and procedures are in accordance with Ukrainian labour law and IFC PS2 requirements. The company will provide access to these policies and procedures to all staff, including contractors. The company will monitor the performance of contractors including their compliance with Ukrainian labor law, IFC PS2 and company HR policies.	30-Jan-2017	Completed	Completed	11/30/2017
8. MV Cargo will develop, implement and maintain an Occupational Health and Safety (OHS) Plan to guide all activities at the project site during, construction phase, and ensure that the project general contractor and its subcontractors meet the relevant requirements.	15-Jan-2017	Completed	Completed	11/30/2017
MV Cargo will develop, implement and maintain an Occupational Health and Safety (OHS) Plan to guide all activities at the project site during operational phase.	02-Jan-2019	Completed	Completed	11/19/2019
9. MV Cargo will develop and implement a workers grievance mechanism in accordance with TIS Group current practices and IFC PS2 requirements.	15-Jan-2017	Completed	Completed	11/30/2017
10. The project contractor will develop, implement and maintain a Dredging Management and Monitoring Plan consistent with the relevant Ukrainian legislated requirements and Dredged Materials Management section of the WBG EHS guidelines for Ports Harbours and Terminals. The plan will be sent to lenders for approval prior to commitment date.	30-Oct-2016	Completed	Completed	11/30/2017