PS5 Land Acquisition and Involuntary Resettlement, PS7 Indigenous People and PS8 Cultural Heritage are not expected to apply to this project for the following reasons: although the company leases land for sugar cane plantations and also owns land, no involuntary resettlement was identified during appraisal and all future land leasing for sugarcane plantations will be under market based transactions on existing agriculture or pastureland areas. The company will likely have flexibility over the location of such plantations, and therefore no involuntary resettlement is expected to take place. No Indigenous People areas or cultural heritage was encountered during the course of appraisal and assessment of this project as most of their facilities and plantations are located on consolidated areas of agriculture.

This Project has been classified as Category B according to IFC’s E&S Sustainability Policy. The Project’s principal E&S risks and impacts are associated with existing sugar, ethanol and energy production activities in Brazil.  Key E&S risks and impacts from this project are: biodiversity loss and offset (compliance with Brazilian Legal Reservation and Permanent Protected Areas requirements); child labor, forced labor and labor issues regarding workers in the sugarcane plantations (within the company’s own operations and those of its suppliers); wastewater (vinasse) treatment and discharge; air emissions from boilers; health (employees and communities) issues related to agrichemical exposure; OHS risk prevention and management; life and fire safety;  neighboring and community engagement. These risks and impacts can be readily addressed through well-established mitigation measures.

Environmental and Social Assessment and Management System: São Martinho has a written environmental policy stating its commitment to produce renewable energy while considering its environmental & social responsibility, aiming for sustainable development, meeting legal regulatory requirements and working to continuously improve its pollution prevention practices and thereby reduce environmental impacts. In addition, São Martinho has an Occupational Health and Safety Policy which states its commitment to comply with the law, apply loss prevention and reduce accidents, strive for continuous improvement, and implementation of applicable and mandatory management programs.

All elements of São Martinho’s policies are linked to specific objectives and targets with respective performance indicators. São Martinho achieved ISO 14000 certification for one of its sites (Santa Cruz Mill) and is currently implementing a corporate management system based on this model. São Martinho group is also on its way to implement a formal management system based on OSHAS 18000 to cover OHS aspects of its operations, as described below and in the PS2 section.

Going forward, as set forth in ESAP action #1, the client will complete ESMS implementation based on above mentioned international standards in accordance with IFC PS1 requirements.

Identification of Risks and Impacts: São Martinho identifies material impacts and risks from its operations, including air emissions, effluents, solids waste and main OHS risks under a Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA) required under Brazilian regulations. Although most sites from São Martinho were built much before the existence of environmental regulations and ESIA requirements in Brazil, São Martinho had to complete a full ESIA process according to Brazilian environmental licensing requirements for its newest site in Quirinópolis, Goiás State, and a full EIA was also required for São Martinho mill capacity expansion.

Management Programs: São Martinho has mandatory Environmental and Social Management Programs to avoid, control and mitigate identified impacts from the projects (called , Plano  de Ação, in Portuguese), as defined in the environmental license to operate.  These plans include monitoring and management programs for waste streams; air quality monitoring, surface water quality monitoring, vinasse application program, fauna and flora monitoring, traffic safety and control, environmental monitoring of field/agricultural activities; monitoring of erosion process, among others.

The company has adopted several policies and procedures to manage human resources and OHS matters related to its own activities and contracted works including, among others, OHS programs required under Brazilian law, such as a Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA), an Occupational Health Monitoring Plan (Programa de Controle Médico da Saúde Ocupacional – PCMSO) and a Hearing Protection Program (Programa de Conservação Auditiva). São Martinho also has specific procedures for hazardous work (working at heights, hot work, working with electrical systems, working in confined spaces, etc.), which must follow the company's mandated procedure for approving hazardous work activities.  

Organizational Capacity and Competency: At the corporate level, São Martinho has two managers taking care of Environment and OHS maters respectively. While the environmental manager reports to the COO, the OHS manager reports to HR. Under their supervision there is a dedicated team of staff at each site including an environmental analyst, OHS engineer, OHS technicians, nurses and physicians.

Training: São Martinho has structured training programs that include an EHS induction for new employees (and contractors) as well as job-specific training such as working at heights, working in confined spaces, work as machine or boiler operators, handling and use of pesticides, etc.

Monitoring and Reporting:  São Martinho monitors the main aspects and impacts from its operations included in mandatory monitoring programs defined during licensing process (surface water quality, fauna and flora, air emissions, aquatic ecosystem, social development, solid wastes generation and disposal, etc.)  as well as some internal indicators such as work-related injuries, water consumption and pesticide consumption.

Under the mandatory PPRA (Programa de Prevensão de Riscos Ambientais), OHS exposure to hazardous agents such as noise, dust and heat is also monitored every year. São Martinho also has mandatory occupational health monitoring programs in place (PCMSO, or Plano Médico de Controle da Saúde Ocupacional), which include periodic clinical assessments as well as regular testing (such as audiometry, eye testing, blood pressure, diabetes and urine and blood testing) to detect any exposure to workplace contaminants or other risks.

On a monthly basis São Martinho reports internally key EHS performance indicators, which are then discussed during periodic managerial meetings. The client also reports environmental compliance information to CETESB (Companhia Ambiental do Estado de São Paulo) in São Paulo State (Sào Martinho, Santa Cruz and Iracemápolis mills) as well as to SECIMA (Secretaria de Meio Ambiente e Recurços Hídricos) in the State of Goiás (Boa Vista Mill).  Information provided to environmental authorities includes the completion of required actions under the conditions of respective environmental licenses to operate, air emissions monitoring from boilers and transport fleet, wastewater quality and disposal, surface water quality monitoring data, water use permits, compliance with Brazilian biodiversity set asides (reserva legal, in Portuguese), solid and hazardous wastes management, among others details.

Finally, São Martinho reports its social and environmental performance to the external audience in the format of a sustainability report using the GRI (Global Reporting Initiative) framework, accessible at company’s website: http://www.saomartinho.ind.br/

Working Conditions and Management of Worker Relationship: São Martinho workforce comprises approximately 10,500 permanent workers. With the mechanization of the planting and harvesting process, cane cutters and other workers involved in heavy manual labor are no longer needed in significant numbers. 97% of workforce is hired locally, at nearby towns. Approximately 90% of workforce is male and 10% female, which is consistent with this industry/sector.

Through its human resources policies and practices, which are clearly articulated and readily available to workers, São Martinho seeks to abide by all Brazilian legal requirements regarding working conditions and management of the employer-worker relationship, to promote a positive work environment, and to retain and motivate its workforce. Employees are hired on the basis of clearly communicated contracts, they undergo an induction and training process, and end-of-employment formalities are carried out in a transparent and orderly fashion. Time clocks are electronic and readily accessible to the workforce, and overtime is calculated and paid. São Martinho reported paying all employer social security taxes and legally mandated benefits, as required.

In addition, the company provides a series of benefits that go beyond Brazilian legal requirements including additional health insurance, transportation arrangements or vouchers, complementary pension plan, life insurance and dental care. While meals are provided for all plant workers during working periods, vouchers are provided to rural workers, who bring their own meals to the field.

Workers’ Organization: Labor rights in Brazil are enshrined in the constitution and the consolidated labor laws (known as Consolidação das Leis do Trabalho, or CLT, in Portuguese), and labor relations are highly regulated under the country's laws and labor practices, including the requirement for most categories of workers to belong to a union. In São Martinho’s case the workforce can belong to any of 3 unions at each work place depending the nature of the job (e.g., Union of Food Industry, Union of Rural Workers or Union of Truck Drivers). São Martinho participates in the negotiations with the Union’s Federations at the State level, which define broader sector agreements (collective conventions) as well as direct collective bargaining agreements with local unions. Salary increases, profit sharing, overtime bank, and benefits are negotiated locally with Unions. There are union representatives working at all sites, and they organize internal workers’ committees to participate in the collective bargaining process. 

Human Resources Policies and Procedures: As mentioned above, São Martinho has a set of HR specific policies which defines HR framework. These policies includes Career Development and Succession Policy, Travel Policy, Benefits Policy, Social Responsibility Policy, Communication Policy; Recruitment Policy and Training and Education Policy.

Working Conditions and Terms of Employment: Many aspects of the work contract (such as working period, rest period, overtime, annual, sick and maternity leave) are defined by law and under collective bargaining agreements with worker’s unions. The standard working period is 44 hours per week and the daily working period cannot exceed 10hs (overtime included). 30 days of annual leave is granted for all workers, who can “sell” it back to the company, restricted to a sealing of 10 days and total voluntarily (optional). There are mandatory 1 hour breaks for meals (lunch or dinner) during the day and 15 minutes brakes during the day. Sick leave is granted but requires a physician assessment/request, and after 15 days absence workers are covered by mandatory social security program. All workers have the right to at least one full rest day per week. There is a countrywide official lump sum program called FGTS (Fundo de Garantia por Tempo de Serviço, in Portuguese), which can be accessed in case of contract termination. All workers receive a 13th salary per year and 1/3 additional salary during annual leave.  There is a national social security system in which both company and workers make monthly mandatory deposits.

Non-discrimination and Equal Opportunity: Although forced/child labor, harassment and discrimination are treated as crimes under Brazilian law, the company states its views and commitments against such practices in its Social Responsibility Policy. Hiring process and promotion follows well established policies and procedures based on merit and competencies, and no evidences of discrimination were found during appraisal.

Retrenchment: The company’s work force has been growing and Brazilian law provides a series of protection for workers in case retrenchment did occur. This includes National lump-sum program (FGTS), one month prior communication, negotiation with unions, and state sponsored unemployment security.    

Grievance Mechanism: São Martinho worker grievance system is grounded in its overarching HR policy, particularly the company's Code of Ethics, which applies to all employees. There are three channels for workers to raise complaints: with their line managers, directly through HR personnel, or through email and phone number in case there is the need of anonymous complaints.  Complaints raised through this latter channel pass through a fully confidential process under HR supervision/coordination that meets on an as-needed basis and has considerable internal authority to take corrective actions. São Martinho has formal records and consolidated data from all complaints, including follow up actions and resolution.

Protecting the Workforce: São Martinho follows Brazil's legislation regarding minimum age required for employment (18 years old.) The company checks the worker's age at time of application, recruitment, and contracting. The company does engage trainees of 16-17 years of age under the Brazilian government's Jovem Aprendiz training program, but it follows all requirements of the program, including limited work hours to allow for participants' schooling and prohibitions against exposing trainees to any forms of hazardous labor. In addition São Martinho has an approved program to train and retain people with disabilities seeking to meet mandatory quota from Ministry of Labor in Brazil.

Occupational Health and Safety:São Martinho has a well-structured team managing OHS hazards and risks facing the workforce, in line with Brazilian labor requirements. As mentioned above, São Martinho has mandatory OHS programs in place, such as risk prevention plans, health monitoring plans, accident prevention committees, and emergency response plans. There are appropriate collective prevention measures, and where necessary, Martinho also provides appropriate Personal Protective Equipment (PPE). After the implementation of phase I of its ESMS, the company saw a drop in injury frequency rates from 5.7 (2013/2014) to 1.2 accidents per million hours worked, which is considered good and below international reference values (i.e., 7 accidents for sugar manufacturing in the U.S. and 8 accidents for crop production).  Severity rates have also dropped from 189 (2014) to 42 (2015) and no fatalities were experienced. 

São Martinho has invested heavily in automation of industrial processes which resulted in the need for only a small number of workers inside the operational area, significantly reducing the exposure of workers to inherent risks found in an ethanol mill.  São Martinho has identified all confined spaces, which are identified with warning signs and workers must follow safety rules for working inside them consistent with Brazilian safety requirements (NR33) and WBG’s EHS general guidelines.

São Martinho is working to improve the safety of pressure vessels, conducting safety inspections, replacing unsafe bottoms and tops, adapting inspection windows, replacing relief and emergency valves and conducting pressure tests. São Martinho has also completed a technical safety standard for procurement of new equipment, ensuring compliance with national safety requirements (NR13).  São Martinho has also invested in machinery protection deploying appropriate protection to exposed moving parts and pitching points. And they have implemented fall prevention measures such as guardrails, lifelines and platforms for working at heights.

São Martinho has completed a safety assessment of its electrical circuits (Relatório Técnico de Inspeção das Instalações Elétricas) according to Brazilian safety standard NR10, and is making investments on the acquisition of insulated tools, electric arc resistant clothing, measurement instruments, safer opening switches, block out devices for circuit breakers, fuses and switch disconnectors, electrical panels, circuits signalization at electrical equipment, safety electric panels assessment for arc resistant and protective clothing specifications, fuses replacement for switch disconnectors, electric substations and hubs adequacy.

Going forward, as set forth in ESAP action #2, São Martinho will conduct an assessment to identify remaining gaps with all Brazilian safety standards including, Boilers and Pressure Vessels Safety (NR13), Electrical circuits Safety (NR10), Machinery Protection (NR12), Buildings (NR8), Transport, Moving, Storage and Handling of Materials (NR11), Confined Spaces (NR33) and working at heights (NR35). Once completed, the company will present to IFC a corrective action plan to bring all units into compliance with Brazilian national OHS safety standards (NRs). This corrective action plan must specify actions and dates for completion, indicate what additional resources are necessary, allocate budget and define responsibilities accordingly. The schedule for completing actions should be prioritized on the basis of identified risks to workers, communities and assets.

São Martinho conducts mandatory pre-hiring, periodic and contract termination health assessments of all employees that include basic clinical assessment and additional tests, such as audiometry, diabetes, high blood pressure, and blood tests cholinesterase and leucocytes counts, depending the job function and identified risks.

São Martinho monitors workers exposure to hazards in the workplace under its mandatory workplace risk prevention program (PPRA Programa de Prevenção de Riscos Ambientais) and has conducted a formal hazard/risk assessment of its operations.

São Martinho completed mandatory respiratory protection plan and ergonomic assessment of workplace, according to the requirements of Brazil's NR 17 worker safety standard, and implemented required corrective actions and a management program to prevent such injuries.

Basic infrastructure is provided for workers in the fields including safe transportation, trailers with toilets, appropriate space for meals and break rests, fresh water supply and electronic time clocks in accordance with Brazilian labor standard NR31. Since all field activities have been mechanized, field jobs are now mainly filled with qualified machine operators. There is a team of OHS specialists responsible for the supply and use control of PPEs. Harvesting operations are run 24hs in three shifts of 8hs periods. There is one hour of mandatory breaks for meals and two other mandatory breaks for personal needs in between.  

Workers Engaged by Third Parties: São Martinho hires external companies for transport, housekeeping, maintenance, some specialized agricultural functions (e.g. GPS mapping) and guard services.

For its contractors, São Martinho has a highly detailed procedure and checklist system to ensure that they are fully observing legal requirements with regard to their own workforces. Procurement, which manages contracting, EHS (the safety, health, and environment team), and HR are all involved in applying the checklist, requesting necessary documentation, and checking compliance before payments are authorized. Third-party workers undergo an EHS induction process upon their arrival to the site, and permission is granted for third-party workers engaged in hazardous work activities through the same procedures used by São Martinho for its own workforce.

Supply Chain: Approximately 30% of the total sugarcane processed by the company comes from third party suppliers, predominantly located in the State of São Paulo. As a result of mechanization process in the fields that took place during last 10 years, the reported cases of labor abuse has been reduced, especially with the elimination of migrant workers. Most of the sugar cane from suppliers are harvested (mechanically) by São Martinho and just a small group of suppliers conduct the harvesting themselves. São Martinho relies on contractual covenants with suppliers ensuring adherence to Brazilian labor laws, ILO conventions of child and forced labor, freedom of association and collective bargaining, respect to human rights and working conditions for all workers, including in-migrant and temporary workers.

Air emissions: The biomass boilers are the largest source of air emissions from São Martinho’s operations; the São Martinho mill alone has 9 large boilers varying from 40 MWth power capacity to 300 MWth. Boa Vista mill has two boilers of 250 MWth capacity. Iracemapolis has 3 boilers varying from 70 to 140 MWth power capacity and Santa Cruz has 3 boilers with 140 MWth capacity each . The client monitors emissions on an annual basis, achieving compliance with Brazilian requirements under CONAMA Res. 382/06 and CONAMA 436/2011, which are less stringent than the World Bank/IFC EHS guidelines (varying from PM 200mg/NM³ to 450 mg/NM3, NOX 350 mg/Nm³,depending the power capacity and year of manufacturing). As set forth in ESAP action #3, in the event of procurement of new boilers or reconditioning of old equipment with increase of power capacity, in addition to compliance to local emissions legal requirements, São Martinho must conduct pollution emission dispersion models prior to de construction/remodel of new boilers and demonstrate that air emissions will not result in pollutant concentrations that reach or exceed relevant ambient quality guidelines and standards by, applying national legislated standards.

Effluents:Wastewater from ethanol mills include: (i) process wastewater from ethanol production (vinasse), (ii) wet scrubber blow down from stack gas scrubbing, and (iii) miscellaneous wastewaters. São Martinho does not discharge industrial wastewater into rivers or surface water bodies, and all such wastewater is mixed together and used as a fertilizer in the sugarcane plantations under a ferti-irrigation management program. São Martinho applies vinasse on sugarcane fields following São Paulo State agency (CETESB) standard for wastewater used in sugarcane plantations. Vinasse is pumped to the fields through pipelines, intermediary storage ponds are lined with high density polyethylene cover to prevent groundwater contamination, and the amount of wastewater applied in the plantations is determined by the soil characteristics and the nutrient needs of the crop.  In two mills (Iracema and Boa Vista) vinasse is concentrated to optimize the distribution to the fields.

All truck/machine shops have vehicle washers, which in some cases are equipped with water treatment and reuse schemes, or either discharge to water bodies after decantation and physical separation of greases. Going forward, as set forth in ESAP action #4, São Martinho will deploy closed water reuse systems at all truck washer stations, or either monitor and treat wastewater to meet water body quality by class (Following Res. CONAMA 357/05).

Resource efficiency:

Water: Sugarcane cultivation in São Martinho operations rely exclusively on natural rainfall and vinasse application. Water is extracted from either surface or underground sources for process operations in the mill, and São Martinho reported to have obtained all required permits from state governments to extract water. With the mechanization of harvesting sugarcane washing at the mills has been eliminated, which has resulted in a significant reduction of water consumption. Water  catchment now varies from 1.98 (São Marinho Mill) to 0,81 (Sta Cruz Mill) m³/ton-cane. In the case of São Martinho mill results are above sector benchmarks and the reference values in the WBG’s EHS Guidelines for sugar production. Going forward, as set forth in ESAP action #5, São Martinho mill will therefore conduct a feasibility study to further reduce water consumption by adopting newer and better technologies such as replacing water cooling sprayer systems in the distillery to a water cooling tower.

Energy:São Martinho self-generates all its energy needs from sustainable resources through co-generation of electricity from thermal power plants fed with sugarcane bagasse. São Martinho has invested heavily in  new and highly efficient power cogeneration units (boilers) and implemented several measures to optimize internal energy consumption such as, modern and more efficient mills with crushing units reaching almost 95% of extraction efficiency, heat recovery opportunities, and process automation.  São Martinho has also conducted a feasibility study to replace steam powered crushers with more efficient electrical engines, but given the current low prices of energy in Brazil, it was concluded that the investment wouldn’t be cost effective. However, Boa Vista mill has been built incorporating newer technology and has all crushers run by electrical engines.

Greenhouse Gas Emissions:São Martinho has conducted an inventory of CO₂ emissions from its operations, which resulted in 194,679 ton of CO2eq (Scope 1 and 2). This figures far exceed IFC threshold of 25,000 tons annually, but considering that this is renewable energy from sugarcane plantations, most of the mills' GHG CO₂ emissions are naturally offset as they are captured from the atmosphere by growing sugarcane plants. In addition, the ethanol that São Martinho produces is used as a renewable fuel in the national vehicle fleet. Therefore, although São Martinho generates high volumes of gross GHG emissions, net emissions from the company's operations can be considered negative (as they are sequestrated in the sugar cane plantations and off-set in the ethanol that replaces use of fossil fuels).

Integrated Pest Management:Integrated Pest Management is employed at all plantations and is a very well established practice in the sector. São Martinho uses biological control techniques to control the sugarcane borer population with the Cotesia flavipes parasite, and Drury larvae are controlled with Metharizium bacteria. Only approved chemicals and fertilizers are used, and application rates and methods are adapted to minimize consumption. Currently in São Martinho group every mill has its own list of pesticides and as a result of its ESMS implementation São Marinho is reviewing those lists to consolidate them in a single approved list of products. After reviewing São Martinho Mills’ lists of pesticides, no products were found falling into WHO class hazard Ia or Ib, which will be periodically verified under Bonsucro standard audits São Martinho only uses closed tractors equipped with cabinets for spraying operations, and handling, storage and use of agricultural chemicals follow national regulations and can be considered best practices.

Hazardous Materials: São Martinho uses and stores significant amounts of chemicals such as soda, sulfur acid, chlorine, cyclohexan, pesticides and, of course, ethanol. A variety of storage arrangements can be found at different areas, but all of them have secondary containment, risk identification, warning signs, access control and emergency kits and showers. However in some cases there are visible signs of floor corrosion and damages on secondary containment. Improvements on warning signs and risk communication are necessary as is segregation of incompatible products (e.g., soda vs. sulfur acid). As set forth in ESAP action # 6, São Martinho will conduct an EHS assessment of all chemical storage fields and provide corrective action plans to bring all facilities into compliance with applicable regulatory and engineering standards.

São Martinho has centralized warehouses for pesticide storage. Products are segregated by hazard class, the floor is sealed, the area is contained, and there is proper ventilation and warning signs. Going forward, as set forth in ESAP action #7, São Martinho will deploy smoke detectors and fire alarms inside warehouse to provide for early detection of any fires that may occur in the absence of workers.

Solid Wastes:Sugar mills produce significant amount of organic wastes (filter cake and ashes from boilers). These are taken to a composting area, where they are mixed together to enable the composting process. This mixture is allowed to rest for 30 days and then applied to the fields.  Metal scrap is segregated, stored outdoors and sold for recycling. The solid waste from administrative areas and dining halls is collected and disposed of through the local public waste system. São Martinho collects all empty pesticide containers and delivers them to certified recycling companies.

Community Health and Safety: Although São Martinho’s mills are located in a rural areas, many towns can still be found very close to the operations. Potential impacts to communities from São Martinho operations could arise primarily from the explosions of ethanol tanks, from the distillery or from sugar warehouses. Air emissions from boilers, fugitive air emissions from trucks (dust) and drifts from aerial application of herbicides (to speed the sugarcane maturation process), can negatively affect communities as well.

São Martinho conducts aerial spraying of crops by contracted companies using crop-spraying airplanes. As set forth in the ESAP action #8, São Martinho will approve and enforce specific procedures to avoid the risks and impacts to health and other crops associated with aerial spraying of chemicals. This entails monitoring weather conditions during aerial spraying, prior communication with neighbors to advise them of spraying schedules and safety exclusion buffer zones to protect towns, small villages or households.

São Martinho relies on large number of trucks to transport the sugarcane from the field to the plant. The average distance of sugarcane plantations is about 50km from the processing operation. São Martinho has a formal road safety program; phone numbers for people to use to record grievances are displayed on the vehicles. Going forward, as set forth in ESAP action # 9, São Martinho will map out small rural villages and settlements across existing access roads used for sugarcane transportation and define additional applicable control and mitigation measures to reduce the risks and impacts to these communities, such as fugitive dust emissions, excessive noise during the night, and overall safety of traffic.

Infrastructure and Equipment Design and Safety: With the exception of Boa Vista Mill, São Maritnho operations were built several decades ago. As mentioned above in PS2 section, São Martinho is investing in improving the safety of pressure vessels, electrical circuits, distillery, sugar warehouses and ethanol tanking fields. As previously defined in PS2 section, São Martinho will elaborate a corrective action plan to bring its operations under applicable regulatory safety standards. Going forward, to ensure the safety of its operations and to reduce the risk to external communities, and as set forth in ESAP action #10, São Martinho will conduct a quantitative risk assessment of all operations, following CETESB standard P.4261, and develop respective risk management plan (or PGR, in Portuguese), including process safety information, a review of all process risks,  change management, maintenance and integrity of critical processes, operational procedures, training program, investigation of accidents, emergency response and periodic audits of the risk management plan.

Life and Fire Safety:São Martinho has been investing in fire prevention of sugar warehouses, and distilleries, employing intrinsically safe electrical circuits and engines, flameproof conveyor belts, proper grounding of idlers, idlers with enclosed ball bearing and thermographic monitoring of equipment. São Martinho obtained the L&F safety certification from State of Goiás authority for Boa Vista Mill, but its other, older, operations are in different stages of completing required project designs to upgrade their L&FS systems and submission of them to the authorities so as to receive approval of such systems.  Going forward, as set forth in ESAP action #11, São Martinho will complete all project designs of L&F safety systems and submit for authority approval. Once projects are cleared, São Martinho will complete engineering implementation projects, get budgeting approval and provide an implementation plan with completion due dates. 

Emergency Preparedness and Response:São Martinho has a mandatory emergency response plan covering all emergency scenarios such as fires, explosions and environmental leaks as well as fire brigade, evacuation and communication plans. As described in above previous sections, São Martinho will also improve emergency preparedness implementing all required firefighting and fire prevention systems according to local regulatory standards, as well as through the implementation of the Risk Management Plan and respective programs (including process safety information, a review of all process risks,  change management, maintenance and integrity of critical processes, operational procedures, training program, investigation of accidents, emergency response and periodic audits of the risk management plan.)

Security Personnel:   

São Martinho relies on armed guards to control access to the mills. Security personnel are sub-contracted through security services companies and personal must have cleared records, special training and certification from Federal Police to carry arms. São Martinho has identified all possible scenarios of security threats inside and outside the mills and specific guidance for security personal is provided that includes radio communication, support from central security, communication with security authorities and panic button. There are specific guidance for use of firearms exploring all alternatives to contain the situation without shooting. Use fire arms are allowed as a last resource and to protect employee’s lifes after a series of attempts to dismiss an attack.

Protection and Conservation of Habitats: Sugarcane plantations are located exclusively on areas traditionally used for agriculture, and no direct conversion of natural habitats to croplands or significant loss of biodiversity is expected from this project.

Depending on the region of the country (determined by biome), Brazilian farmers are required to set aside 20% to 80% of their lands as biodiversity conservation areas and to protect buffer zones along rivers and around water bodies. If deficient, riparian buffer zones should be reconstituted, and biodiversity conversation areas can be offset through the protection of intact areas in the same region.

São Martinho conducts an environmental assessment of the sugarcane fields and excludes the mandatory riparian areas and legal biodiversity offsets from the sugarcane plantations. At its owned land (52,000 ha) São Martinho has shown adherence to mandatory environmental and rural cadaster (CAR) to implement the regulatory requirements (offsets can be established on the farm or compensated in another area).  Rehabilitation or compensation of biodiversity set asides must follow regulatory timeframe for completion.

Sustainable Management of Living Natural Resources: As mentioned above, sugarcane plantations are located on already-converted land and consolidated areas of crop plantations in São Paulo and Goiás States. Soil conservation techniques are applied in the fields including contour planting, terracing and planting design to avoid run-off. Sugarcane leaves and straw are left on the ground to protect the soil from erosion.

São Martinho takes advantage of all possibilities to use organic wastes from ethanol production, including vinasse mixed together with other suitable wastes, in the plantation fields to reduce the need for chemical fertilizers. When such chemical fertilizers are applied, the prescription is based on soil fertility analysis and plantation extraction needs. As mentioned above, São Martinho monitors pests, which it seeks first to control through biological agents.  When used, agrochemical products are prescribed by qualified agronomists based on pest infestation and economical level of control. Throughout harvesting mechanization, there is no need of pre-harvesting burns of sugarcane fields, and the straw is left on the fields to better protect the soil from erosion effects.

Two of three mills from São Martinho (Iracema and Santa Cruz) have already achieved certification of industry good practice standard “Bonsucro”. As set forth in the ESAP action #12, São Martinho will manage all plantations in a sustainable manner and obtain Bonsucro certification for all mills.

Supply Chain: No significant conversion of natural or critical habitats is expected from São Martinho suppliers in this Project.

External Communications and Grievance Mechanisms: During the initial licensing phase, Boa Vista mill project was disclosed to the public under the format of an executive summary of the EIA, called RIMA (Relatório de Impacto Ambiental), meantime the full ESIA was made available for public local access. Public hearings were also conducted when the company had to present to the audience all the relevant conclusions from the ESIA as well as all the measures that would have to be implemented to mitigate and control the impacts associated to the project. The public hearings are mediated by a representative of the Environmental Agency, and the mayor and the local public attorney also had a seat. Finally, the Mayor has to sign a letter of endorsement before the Environmental Agency issue the Previous Environmental License, which is the first of a series of three environmental licenses.

Grievance mechanism -  São Martinho has available for the general public some channels of communication which the company has disclosed at their website, including email address, phone numbers and mail information: http://www.saomartinho.ind.br/. The system has means to receive, record, forward, treat and provide feedback to all complaints from the public, and the company keep records and shares results internally on managerial meetings.

On-going Reporting to Affected Communities:Iracema mill is located less than 1 km from the nearest town and impacts can also potentially affect some closer neighborhoods. Although impacts from sugarcane plantations are diffuse, it is expected that some rural villages or nearby farmers could be possibly affected by noise and dust emissions from trucks crossing unpaved roads or unintentional agrichemical spraying drifts, especially from air spraying.   As described in PS4 section, São Martinho will map villages and potentially impacted communities, and ensure they are informed about aerial spraying and truck traffic schedules and all mitigation measures.  Sào Martinho reports to the public selected aspects of its sustainability performance on its Annual Sustainability Report http://www.saomartinho.ind.br/. Key indicators from. The Sustainability Report is based on a materiality matrix resulting from consultations to key internal and external stakeholders.  In addition to existing consultation efforts, and set forth in ESAP action #13, São Martinho will map out potentially affected communities in Iracemapolis and define a program of consultation and communication with them.

Contact Person: Cristiane Pigatto

Company Name: São Martinho

Address: Edifício Panambi, Rua Geraldo Flauzino Gomes, 61 - Cidade Monções, São Paulo - SP, 04575-060

Phone: +55 11 2105 4100