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
Future on-going assessment of potential additional Performance Standard requirements will be part of PTBB’s responsibilities through PS1 and, where identified, IFC must be promptly informed and appropriate mitigation agreed to manage new issues. The applicability of PS1, 2, 3 and 4 has been determined through the appraisal process. The remaining PSs were deemed not applicable for the following reasons:

- PS5. The 700 ha Indotaisei industrial park was acquired by Indotaisei around 1992 from private shareholders on a willing seller-willing buyer basis. Details on land dealings by the shareholders who acquired the land some time earlier are unknown. The 16 ha vacant PTBB plant site on the north-east corner of the industrial park was acquired as leasehold land from Indotaisei in 2010. The site has no known land ownership disputes over it. The six separate leases over the land variously expire from 2022 onwards but renewal of these leases for further terms (usually 20 or 30 years) is standard practice.

- PS6. Clearance and development of the Indotaisei industrial park commenced in the early to mid 1990s. Prior to industrial use the mostly moderately sloping land was primarily used for mixed cropping and grazing. Land use on the PTBB plant site consisted of mixed cropping, scrub, grassland and several small wetlands or farm dams prior to 2006 when the site was cleared. This highly modified habitat type is common in the area and across Java, and does not have high conservation value.

- PS7. The PTBB plant site is situated within the 700 ha Indotaisei industrial park that has been partially developed. The site was cleared and partially levelled prior to PTBB’s acquisition. The park is located in a rapidly developing area, with no evidence of indigenous peoples living in the area in a manner that would trigger the requirements of PS7.

- PS8. There are no known cultural heritage sites or property on the PTBB site or on the broader Indotaisei industrial park.

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

The project has been classified as category B according to IFC’s 2012 Environmental and Social Review Procedure. Category B projects are defined as those which have business activities with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures.

Key environmental and social issues associated with the proposed investment are: B. Braun’s corporate capacity, monitoring and performance regarding environmental, health and safety and social management, and how this will be transferred to PTBB’s Indonesian operations, focusing on product quality; efficiency of raw material, water and energy use in the manufacturing process; pollution control and waste management; labor and working conditions; and the management of contractors and suppliers.

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.

The environmental assessment (UKL-UPL Environmental Management Efforts and Environment Monitoring Efforts) for the plant is at final draft stage, being prepared by an independent consultant. At the time of this disclosure, PTBB was liaising with relevant authorities to finalise the EIA process to receive approval to proceed, which is required prior to the start of manufacturing. The target for government approval is the end of December 2015. The broader impacts from the development of the industrial park were addressed in an EIA prepared for Indotaisei by an independent consultant in 1993.



At the corporate level, B. Braun has established overarching requirements for the EHS management programs of all operating companies around the world. B. Braun maintains the high quality of its products to safeguard patient health by utilising the same good manufacturing practices (GMP), raw materials and highly developed quality management systems at every manufacturing facility it operates, regardless of the global location. Quality management is modelled on international standards and ensures that all regulatory requirements are met. Strict health and safety practices are implemented to prevent parenteral contamination and product mislabelling, with multiple safety checks implemented throughout the manufacturing process, in accordance with international best practice and national license conditions. Staff are thoroughly trained in standard operating procedures. Manufacturing plants are regularly monitored and certified by national authorities and independent bodies. Regular reviews of the quality management systems are conducted using internal and external audits, as well as continuous employee training. All of these B. Braun corporate requirements will be applied to PTBB’s manufacturing activities.



An Integrated Management System has been established by PTBB (September 2015). This system incorporates leadership processes (strategy and leadership, measurement, analysis and improvement), business processes (supply chain management, production process), and supporting process (personnel, resource management, environmental, health and safety management). Some of B. Braun’s worldwide production plants are OHSAS 18001 (occupational health and safety management system) certified, with similar certification planned for the PTBB plant within two years of operation. The EHS Manager will develop the EHS management program framework and implementation strategy before the plant enters production.



PT Pharma is required to hold the following licenses for the plant and LVP manufacture in Indonesia: Master Plant Development, GMP Certificate and Product Registration issued by the national Agency of Drug and Food Control (BPOM); and Principal Permit and Manufacturing License issued by Ministry of Health. PT Pharma obtained Master Plant Development approval in January 2015, and has applied for the Principal Permit licenses for the manufacture of parenterals in Indone
sia which it expects to obtain in December 2015. In addition, licenses required for the sale of the manufactured LVPs in Indonesia and in countries where the products are exported to are: Product Registration (primarily for export products) and Certificate of Pharmaceutical Product (CPP) issued by BPOM; and Product Registration from the national food and drug administration in the export destination country, or WHO respectively.



PolicyB. Braun views quality and compliance as two essential elements of its business, critical in providing very high standard medical products and services. B. Braun establishes an EHS Policy for each operating plant, and hence PTBB will develop an EHS Policy for the Indonesian plant, modelled on the Malaysian policy. The Malaysian EHS Policy has the objectives of: i) a safe and healthy workplace; ii) ensuring that all employees have adequate information, training and supervision to carry out their duties in a safe manner; iii) investigating occupational accidents, dangerous incidents and environmental pollution, and taking appropriate actions to ensure these occurrences are minimised; iv) compliance with all national EHS legislative requirements and authority regulations and codes of practice; and v) continual review and revision of health and safety policy and programs to achieve continual health and safety improvement. This Policy is signed annually by plant management.



PTBB has a Human Resources (HR) Policy based on national requirements and B. Braun’s standard employment practices, consisting of a set of Standard Operating Procedures (SOP). Other key policies include the Company Regulation covering employee and employer obligations, and the employee Code of Conduct specifying good conduct requirements.



Organizational Capacity and Competency



During plant operation a full-time EHS manager is appointed, supported by a qualified team that will be recruited and trained to implement the EHS program. Key EHS management positions at the operating plant will be the Plant EHS Manager, Assistant EHS Manager, EHS Engineers, Fire Protection Officer, and Security Manager (similar to management positions at the Penang plant). Staff to be recruited for each of these positions will typically have between 5-15 years EHS experience and appropriate qualifications. PTBB’s HR Deputy Manager will manage plant human resources matters.

Emergency Preparedness and Response



The manufacturing plant has been designed to meet Indonesian standards for earthquake resistance according to the Circular Letter from Ministry of Public Works No. 12/SE/M/2010 on Indonesian Earthquake Zoning Map Enforcement and FM Global 100-year Earthquake Zone. The plant’s mechanical and electrical components have been designed in accordance with the US National Fire Protection Association’s extinguishing codes and are under review by FM Global, PTBB’s and PT Pharma’s insurer. The plant fire suppression system includes automatic sprinklers in all area
s, underground water supply lines for firefighting, and an access road around the external sides of all buildings to provide fire truck access. FM Global will provide a fire protection system performance report after a system joint test, and certification shall be issued upon completion of the project. The design of the chemical/hazardous materials storage area incorporates segregated rooms each with retainment capacity.



A site-specific Emergency Prevention, Preparedness and Response Sub Process will be developed for the plant in consultation and coordination with the industrial park operator, Indotaisei. As no communities reside within 300 m of the plant, with the nearest two communities separated from the plant by major highways, PTBB’s plant emergency preparedness and response planning will not involve local communities.

Monitoring and Review



B. Braun conducts ongoing reviews of EHS programs and practices as a routine part of operations, with the aim of achieving continual improvement. Reviews include assessing working hours, risk assessment, communication plan, inspection and audit, emergency response. This review and reporting system will be developed by PTBB for the Indonesian plant based on established practices at B. Braun. Environmental parameters will be monitored on a regular basis (as detailed in the PS3 section) to identify issues and non-compliances, to ensure that approval and license conditions are met.

PTBB currently employs 591 full-time staff in Indonesia, including 42 staff working at the plant (October 2015). Plant staff numbers are estimated to reach 198 permanent employees once the installed capacity is reached (approximately one year after plant production commences). Some workers are hired on a temporary basis, on a 6-12 month contract, during which period they are evaluated before being offered permanent employment. These workers, usually recent high school graduates, will be involved in tasks as such as production and packaging, quality control and maintenance. The human resource policies and procedures are applicable to both permanent and temporary employees alike. In addition, PTBB will utilise contractors for non-core operational activities such as cleaners, canteen workers and drivers.

Human Resource Policies and Procedures

PTBB’s HR Policy, based on Indonesian requirements and B. Braun’s standard employment practices, is supported by PTBB’s Company Regulation (required under Indonesian law) and Code of Conduct – Statement of Compliance. The HR Policy consists of a set of SOPs that cover recruitment, personnel planning, promotion, transfer and demotion, travel policy, and company regulations. HR is managed by the HR Department in Jakarta.



The Company Regulation, required by the Ministry of Manpower and Transmigration for all enterprises with more than 10 employees, contains employee and employer obligations, including working hours, entitlements, leave and termination provisions. The Regulation has almost been finalised and will be distributed to all PTBB employees in Indonesia once it has been approved by the Ministry (expected December 2015).



The PTBB Code of Conduct (currently for 2014-2016, and renewed every two years), written in both Bahasa and English, is provided to every worker upon employment and they are asked to sign it. The Code contains employee responsibilities regarding adhering to applicable laws, conducting ethical practices, protection of PTBB property, information confidentiality, equal employment opportunity, safety, avoiding corruption and bribery, and product safety.



The recruitment of production staff has commenced but will only be completed once the plant commences commercial production in 2018. Vacant positions are advertised on jobs portals and through campus recruitment. All local employees will be hired before commercial production commences. PTBB aims to employ 30% of workers from nearby communities. The approximate breakdown of positions at the plant is: engineering (10%), other technical (40%), and unskilled (50% – to be trained as plant operators, security and other support staff). The HRBP (Human Resources Business Partner) will handle all plant workforce management matters. Monthly meetings on human resource management are held between the HR Director, HRBP and Plant Head.



Working Conditions and Terms of Employment



B.Baun benchmarks its remuneration rates and employment package
against other employers (pharmaceutical producers and other industries), contracting Mercer (an independent consultant) to do this. PTBB exceeds the minimum wage rates set by regional government in Indonesia by between 5-10% for plant operators and clerks, while for skilled positions the minimum wage is commonly exceeded by 20-30%.



PTBB pays the mandatory national health insurance contributions and provides additional private medical insurance coverage for permanent and short term staff. Other staff benefits include access to subsidized canteens and provision of company transport for workers to and from the plant. The target is to keep employee turnover to a minimum (i.e., at or below the national average for the manufacturing sector). A Cooperative of PT. B. Braun’s employees (the “Koperasi”) was established in 2010, pursuant to Indonesian law, to engage in activities for the advancement of members’ welfare. Membership of the Koperasi is for full-time Indonesian employees of PT. B. Braun Medical Indonesia and Group.

The minimum age of employees is not specified in the HR Policy or Company Regulation, but PTBB does not employ anyone below 18 years of age.

Workers Organizations



PTBB complies with ILO Conventions covering union freedom, the protection of union rights, the right to organize and collective bargaining. Union membership is allowed by PTBB staff, but no employees are currently union members in Indonesia. In Indonesia, workers organizations have the right to be affiliated with the Indonesian Trade Union Confederation. Indonesia has ratified 19 ILO conventions, including the abolition of forced labour, freedom of association, minimum age and collective bargaining.

Non-Discrimination and Equal Opportunity



Hiring plant employees will be based on merit, including experience, qualifications and ability. PTBB undertakes equal opportunity employment, with no discrimination based on gender and has a formal policy statement to this effect. At present contract worker benefits are not completely streamlined with permanent staff. For all new contracts, B. Braun will align working conditions and benefits for workers to the extent the benefits are eligible to that category of employment and that position. An estimated 30% of plant staff will be female, mainly employed in plant production and quality control. All employees will receive skills development as per PTBB policy, an essential component of the quality control and compliance system.



Under Indonesian regulations PTBB is required to employ one person with a disability per 100 employees. Accordingly, PTBB shall adhere to this requirement, ensuring that the type of disability allows the applicant to perform the required job.



Grievance Mechanism

PTBB does not have a formal grievance redress mechanism in the HR Policy or existing Company Regulation, although the right of an employee to raise an issue of concern with management is set out in PTBB’s new Company Regulation that
is about to come into effect. This process will enable a staff member to raise an issue with the HR department if it relates to a manager, either in person, by phone or email, and this can be done anonymously. For purposes of the new plant PTBB will implement this mechanism and ensure this is aligned with the requirements of this Performance Standard. This requirement is defined in the project ESAP.

Child Labor and Forced Labor

PTBB does not permit the use of child or forced labour by the company or its contractors.

Occupational Health and Safety



A single OHS management system exists for all B. Braun plants across the world, from which local plans are developed that take into account any additional national requirements. The PTBB OHS system is under development, consisting of SOPs, forms and reports. In total around 2,000-3,000 documents/procedures/forms will be produced for plant operation, based on B. Braun’s approved European and Malaysian manufacturing plant procedures, incorporating continuous OHS improvement. Key documents in this system include: an Environmental, Health, Safety Management Manual; SOPs for EHS risk assessment, emergency prevention and preparedness response, dangerous substance/pollution prevention; and Work Instructions for personal protective equipment (PPE) use, contractor management, chemical exposure monitoring and spill response, chemical waste disposal, and industrial truck use. In addition and as previously noted, the plant will be certified against OHSAS 18001.



Standard staff injury and incident prevention measures in Penang that will be introduced at PTBB’s plant include: EHS orientation/induction training for new employees; on-the-job training; tool box meetings; safety and health talks and campaigns; contractor management; regular workplace EHS inspections; hazard identification, risk assessment and risk control; new machine/process validation; and EHS training. EHS training of staff will cover such topics as GMP, basic microbiology, personal hygiene, machinery/ chemical/ forklift/ fire safety, hearing conservation, and emergency response and first aid.



EHS reports will be provided to the Operations Head and a monthly EHS report is prepared for Board review. A Safety Council made up of management and employee representatives will meet quarterly to identify any issues and develop solutions.



The Penang plant has a formal accident escalation process to ensure timely action is undertaken to rectify a risk or hazard, which shall be applied at the PTBB plant. This process involves manager notification of the incident, completion of an Accident Incident Notification Report (AINR) within 24 hours of the case being reported, identification and implementation of corrective and preventative action/s, and close out of the AINR. In 2014 the Penang plant had 47 “non-reportable” cases (where more than 1 working day was lost per case) and 13 “reportable” cases (where more than 4 days was lost per case).



An
indication of the level of OHS management that will be achieved at the PTBB plant is provided by the Penang plant where highly effective OHS management and enforcement was evident. Indicators included: excellent housekeeping and hygiene within production areas; appropriate safety and hygiene signage throughout the facility; procedural information available at point of use; equipment design to reduce OHS accidents; and no observed violations of EHS procedures.



During plant operation, one safety officer will be provided per shift with 25-150 workers, with an additional officer to be provided for every additional 150 workers. Adequate medical facilities are provided at each B. Braun operating plant to treat most cases apart from acute emergencies. For example, the Penang production plant has three doctors and 24 hr nurse care operating out of three site clinics. The new PTBB plant will have a first aid room in the production area and an ambulance bay in the warehouse area.



A pre-employment medical check is conducted of all potential employees. One of the main OHS risks in the manufacture of parenterals is repetitive strain from the visual inspection and packing of LVPs. Injection moulding of plastic presents a low OHS hazard for the majority of production workers. Other lower occupational health risks include crush injuries from dropping materials, heat injuries and lifting injuries. PTBB will implement the comprehensive approach to OHS implemented by the Penang LVP plant that consists of strict hygiene practices, clear signage on personal protective equipment requirements, standard operating procedures available at the point of use with OHS information included; material safety data sheets available where chemicals are being handled and effective ventilation systems to maintain good workplace air quality.

Workers Engaged by Third Parties



Construction of the plant civil works is being undertaken by Shimizu, a Japanese construction contractor who has been engaged by B. Braun to build a similar plant in Vietnam. This contractor is implementing a high standard of OHS management on site, as evidenced by appropriate signage across the construction area, safe work practices including the use of appropriate personal protective equipment (PPE) by all workers (e.g. use of harnesses when working at height), and regular toolbox and safety committee meetings.



PTBB requires the construction contractor to meet national labour requirements, with conditions stated in the contracts. The contractor has to fulfil minimum OHS requirements that include chemical management, control of compressed gas cylinders and working at height requirements. The contractor’s Safety Officer produces Daily Safety Inspection Reports to ensure appropriate OHS practices are being upheld at all times, with penalties incurred by the contractor for violations.



During plant construction PTBB has an Employer Representative on site to review and advise the construction contract
or on a range of requirements, including OHS management. PTBB conducts weekly safety meetings with the construction contractors to identify and resolve issues, as well as random site inspections of OHS. During PTBB plant construction one safety officer is provided on site by the civil construction contractor per every 35.



Shimizu’s construction workforce was 250 in mid October 2015, and is set to peak at around 500 in mid-November 2015. Reported worker safety on the civil contractor’s workforce for the five months from May-October 2015 is one “near miss” incident out of 407,000 person hours, with 328 person hours of training conducted. A total of 130 main tool box meetings have been conducted, covering each new construction activity, with 404 regular safety inspections conducted to date.



PTBB will utilise contractors for non-core activities such as cleaners, canteen workers and drivers. Following practices in other operations, PTBB will establish policies and procedures for managing the performance of these contractors in relation to the working conditions, terms of employment, and occupational health and safety of these workers to ensure these align with this Performance Standard. PTBB will also ensure its grievance mechanism is easily accessible to third party workers.



Supply Chain

The primary suppliers of raw materials to all B. Braun plants worldwide for the manufacture of parenterals (and hence to PTBB) are located in: Germany - plastics (polyethylene – LDPE and HDPE); the Netherlands - sugar (dextrose monohydrate); Spain - salt (sodium chloride, calcium chloride dihydrate, potassium chloride, magnesium chloride, sodium lactate, sodium acetate, magnesium chloride); and New Zealand and Japan - malic acid. As such, expectations on primary supplier performance on labor and safety is handled at corporate level.

B. Braun’s Global EHS Department provides a policy framework for operating companies that includes resource efficiency through all aspects of the life cycle, including building design, equipment selection, equipment operation and product life cycle (e.g., raw material conversion rates, water and energy used per good lens). Operating companies must set annual EHS objectives to define, monitor and demonstrate continuous improvement.



The design of the PTBB plant buildings did not incorporate green building design principles except for optimising natural light entering the buildings where possible. The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) standard was used for the HVAC system. Energy efficient equipment to be installed in the plant includes a multi stage distiller to produce water for injection (WFI) designed with the lowest steam pressure, variable frequency drive (VFD) motors for the heating, ventilating and air conditioning (HVAC) system, clean air compressor, chiller and pump for water distribution to reduce electricity consumption, and a water treatment system with low waste and high output.



The plant design has gone to FM Global for fire hazard review, with the applied fire safety standard being close to the US standard Some construction materials and mechanical, electrical, plumbing (MEP) require certification in accordance with FM Global recommendations.

Greenhouse Gas Emissions



Plant electricity consumption from the grid at production is estimated to be 13.65 million kW(h) per annum, with 150,000 m3 per annum of natural gas used to run the boiler (with diesel used as a backup fuel supply when there is a gas shortage). Based on these major uses of energy, the estimated annual volume of GHG emissions from the plant is 9,800 mtpa CO2e, well below IFC’s annual quantification and reporting threshold (25,000 mtpa).Water Use

Water will be supplied to the plant by the Indotaisei industrial park water supply system. The estimated average daily consumption of water by the plant at production is 45 m3/day, with the majority used in LVPs. Industrial park water supply is pumped from the Tarum Timur River under licence and treated to industrial water standard. No incidents are known of an inadequate water supply to other river water users due to park water extraction.

Pollution Prevention



The main sources of plant pollution will be natural gas and diesel combustion emissions from boiler heating, sludge from water purification and solid waste from a range of activities. The permissible levels for emissions specified in the plant approval conditions and World Bank EHS Guidelines will be adhered to.



The plant will produce an average of around 25 m3/day of wastewater from water purification, evaporator, plant processes, sanitary wastewater and canteen waste. Industrial process wastewater (mainly from clean in place and the ion exchanger plant) will be buffered by dosing it to meet an accepta
ble pH level and to reduce the temperature prior to discharge into the industrial park wastewater treatment plant (WWTP) for further treatment. All plant sanitary wastewater will go directly to the park WWTP for treatment. Wastewater will be treated to meet the applicable government standard for treated effluent (West Java Governor’s Decree No. 6/1999, Date March 13, 1999 re. Waste Water Quality Criteria due to Industries in West Java) before being released into a local creek that flows into the Cibalukluk River.



Solid waste will be generated from injection moulding trimmings, packaging, machinery maintenance and repair, canteen operations, and other miscellaneous activities. Waste materials will be recycled where possible. For example, clean plastic trimmings will be crushed and mixed with virgin plastic material to produce bottles. Dirty plastic trimmings and rejected bottles will be crushed in the milling area and sold to a licensed collector.

Refrigerant used on site will be 134a in the air cooled chiller and R-410a in the air conditioners. Hazardous chemicals and other materials will be used in production, laboratory analysis and maintenance activities, including acids, ethanol, methanol, potassium hydroxide and diesel. Hazardous waste will be produced from laboratory testing. This material shall be disposed of by a third party licensed contractor who shall recover the metals and dispose of the residual as scheduled waste at a registered government landfill. All wastewater will be discharge to park WWTP.



Stormwater from the plant site will be discharged into an open roadside stormwater drain and then into an open watercourse within the industrial park. Stormwater quality from the site will be partly controlled by directing all site stormwater through hard drains to minimise erosion and discharging all stormwater through a sediment/pollutant trap on the boundary of the site.



Regular monitoring of environmental conditions at the Penang plant consists of: inspection on the scheduled waste area (weekly); recycling and disposal of scheduled waste (weekly); update of the inventory of scheduled waste (monthly); industrial effluent test (weekly); scrubber performance monitoring; air emission test (quarterly); inspection of WWTP performance (daily); and oil mist test (quarterly). A similar monitoring regime will be established for the Indonesian plant based on the local requirements and good practice.

As a producer of medical supplies, product safety and compliance are critical components of B. Braun’s business. The major risk to public health from PTBB’s production of parenterals relates to the potential patient health issues if these medical supplies are not sterile or are faulty in some other manner. While the risk of producing faulty supplies is very low based on B. Braun’s excellent track record of manufacturing high quality paranterals at plants in different countries (Germany, USA, Malaysia, Spain, Switzerland, Vietnam), the potential health consequences of a substandard product could be significant. Accordingly, B. Braun applies a comprehensive approach to quality control and assurance as described above, and this approach will be strictly applied by PTBB at the new plant with in-process-controls and finished product analysis.

The plant is located within the Indostaisei industrial park, where access is controlled and private security is provided by Indotaisei. PTBB will also provide its own site security. The PTBB plant site has direct access to the adjoining Nasional 1 highway to the north and Jalan Tol Cipulareng highway to the east, therefore the transport of raw materials to and products from the plant will not create traffic issues. The nearest dwellings to the plant site are located over 300 m away, separated by the two highways. The maximum plant noise levels will be attenuated by the setback distances and masked by intervening highway traffic noise, and hence the effect of the plant on noise levels received in these residential areas is expected to be negligible. During plant operation noise level monitoring will be conducted prior to and during boiler operation to asses if plant operation is impacting on noise level beyond that specific in national legislation and the WBG EHS Guidelines. Based on these results, PTBB will implement remedial measures to reduce noise levels if necessary; this requirement is defined in the project ESAP.

Given the location of the new plant within the industrial park the stakeholder engagement as part of the EIA was largely limited to authorities.

PTBB does not have a corporate-level stakeholder engagement policy or a project stakeholder engagement plan, nor does it have an external grievance mechanism at corporate or project level. There are no communities directly affected by the new plant, with the nearest existing settlement located over 300 m from the boundary of the site. Formal procedures for external communications and grievance redress will be developed by PTBB as management system components. This is defined as a requirement in the ESAP.

PTBB will support corporate social responsibility (CSR) initiatives once the manufacturing plant is operational. Examples of the types of initiatives that PTBB may support are indicated by the programs that B. Braun Malaysia run, including: supporting a dialysis centre; providing education to school students on environment, health and safety; internship programs; and factory visits for schools.

Mr Eko Peryatno
General Manager – Plant
Palma One Building, 14th Floor Suite 1401
Jl. HR Rasuna Said Kav, X-2 No. 4
Jakarta 12950, Indonesia

Tel: +62 21 5290 7177

Broad Community Support is not applicable for this project.

Broad Community Support is not applicable for this project

BBraun Indonesia(37527) Appraisal Disclosure Snapshot – Version 2
Description	Anticipated Completion Date
External Grievance Mechanism: Develop and an implement a grievance mechanisms that is applciable to external parties.	30-Jun-2016
Worker Grievance Mechanism: Develop and implement grievance redress mechanism for employees and contract staff alike aligned with the requirements of PS 2: Labor and Working Conditons. This mechanism is to be applicable to contractors workers and communincated to all employees once developed.	30-Apr-2016
Contractual provisions for contractors: Develop and implement procedures for contract workers to ensure compliance with their working conditions with Performance Standard 2: Labor and Working Conditions.	30-Apr-2016
Noise monitoring: Undertake noise monitoring once the plant is operational to assess the impact of the plant on nearly communities. If necessary, implement remedial measures accordingly.	31-Aug-2017