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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

IFC has categorized this equity investment as a Category A project, according to its Policy on Social and Environmental Sustainability (January 1st, 2012). The rational underlying this categorization is based on the well documented significant adverse biodiversity risks associated with soybean sourcing in the ecologically sensitive Humid Chaco in Argentina and Paraguay, and in the Amazon and Cerrado biomes in Brazil.

Key E&S risks and impacts associated with this investment included: (i) acquisition or renewal of necessary operational licenses; (ii) performance effectiveness of environmental, social (labor), occupational health and safety, and food safety management systems, procedures, management programs, and timely implementation of recommendations from internal and external/third-party audits; (iii) provision of fair and safe working conditions, compliant with local labor law, Noble Agri’s corporate Human Right and OHS policies and IFC PS2, for permanent and temporary (seasonal) employees, contractors and supply chain labor; (iv) emergency preparedness and response (ref. use of hexane in soybean oil extraction and storage and transport of bioethanol); (v) quality and sustainability of water supply, management of air emissions from all sources, including any bagasse fired steam and co-generation activities, integrated pest management in agriculture operations, raw material/product storage activities; management of solid, liquid and hazardous wastes from agriculture and processing activities; energy consumption and energy efficiency, including greenhouse gas emissions and carbon finance opportunities; (vi) community engagement; (vii) land acquisition process for sugarcane plantation development, facilities expansion and, land use permitting; and (viii) biodiversity related issues for its direct operations, and traceability and sustainability sourcing of its sugar cane, cotton and coffee from its third parties suppliers (ref. supply chain).

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.

Environmental and Social Policies: Since its split from Noble Group, Noble Agri has been re-designing its sustainability vision, principles and strategy so as to ensure it is tailored to an agriculture company. Specifically, its sustainability approach is driven by the following principles: i) contribute to global food security and safety by optimizing production and efficiency; ii) respect human rights, provide safe and productive work conditions for its staff; iii) measure, communicate and pro-actively reduce its environmental impacts; iv) contribute to the economic and social development of communities, to develop the capacity and resilience of suppliers and smallholder farmers; v) cultivate partnerships through collaboration and transparency with key stakeholders to further develop shared goals. These principles have been translated into corporate-level policies (environment, occupational health and safety “ including life and fire safety and emergency preparedness plan and response, human (labor) rights policy, stakeholder engagement and community grievance mechanism policy, sustainable sourcing policy, and responsible land acquisition and leasing policy. These updated policies have incorporated the principles and requirements of national legal and regulatory requirements, IFC Performance Standards and Voluntary Agro-Commodity Standards (e.g. Bonsucro, RTRS). Noble Agris Board of Directors approved these corporate policies on October 13, 2015. Since their approval, these policies have been translated into five languages and are in the process of being communicated to its stakeholders, including its employees, contractors and consultants. These policies have been disclosed on Noble Agri website (http://www.nobleagri.com) on December 20, 2015. Appropriate training will be conducted over the next months to ensure that all stakeholders are aware of these policies and supporting procedures to promote effective and timely implementation. Copies of the EHSS policies will be shared with every new employee at the time of hiring and through induction training. Specific operationally-based QEHS policies have been adopted at numerous operations, as part of ISO 9001, ISO 14001, OHSAS 18001, and HACCP/ISO 22000 management system preparation and certification process.Noble Agri is signatory to the UN Global Compact since 2008, the Carbon Disclosure Project since 2010 (as part of the Noble Group, Noble Agri achieved the "Best Climate Disclosure Score for the last 2 years), pro-actively participated in sustainable/responsible sourcing initiatives in coffee (Rainforest Alliance, 4C, Organic, UTZ and responsible sourcing code with all coffee suppliers worldwide), sugar (Bonsucro certification at one of its sugar mill) and is member of the Roundtable on Responsible Soy (RTRS) and the Soy Moratorium. Going forward, and as set forth in the Environmental and Social Action Plan (ESAP), Noble Agri will provide supporting evidence of its EHS policies communication across Noble Agri operations, including its employees, contractors and consultants.

Environmental and Social Assessment: Noble Agris identification of environmental and social risks and impacts is defined by nationally and locally applicable environmental and social assessment regulatory requirements. Since IFCs investment in October 2014, Noble Agri also follows IFCs Performance Standards requirements in its EHS risk assessment and management process. For example, in Brazil and China, Noble Agri identifies risks and impacts associated with its operations that include both normal operations and those from non-routine or emergency situations. For example, risks and impact assessments have included hexane used in soybean oil extraction, ethanol storage and transport, air emissions, effluents, and solids waste generation. OHS risk assessments are included as part of the Risk Prevention Plan (e.g. Plano de Prevenção de Riscos Ambientais “ PPRA in Brazil).

While greenfield developments are typically required to complete a full environmental and social impact assessment (ESIA) process according to Chinese and Brazilian environmental licensing requirements, the extent of assessment requirements applicable to the expansion of existing plants can range from a full ESIA to a more simplified Rapid Environmental Assessment, depending on the nature of the expansion, its potential E&S impacts, and the judgment of the local environmental authority. Noble Agri has completed both. For example, a full ESIA was undertaken for its Sugar Mill in Meridiano as well as for its soy crushing and combined Biodiesel facilities in Rondonópolis (Brazil) and Timbues (Argentina); Rapid Impact Assessments were completed for Votuporanga and Catanduva Mills expansions (Brazil). Completion of a full ESIA for its soybean crushing plants in China (Qinzhou and Fuling) also took place and was validated in a recent IFC supervision.

In Brazil, the suitability of land for the production of various crops, and specifically for sugarcane production, is assessed following Brazils CTC (Centro de Tecnologia Cana) framework, which includes soil type and fertility, erosion risk, topography, rain fall, sun light, temperature, and other factors which determine sugarcane productivity. Noble Agri has recently developed a comprehensive questionnaire for early EHS risk screening of its processing and plantation operations. Going forward, and as set forth in the ESAP, Noble Agri will develop and implement a corporate level procedure for the assessment of environmental and social impacts, applicable to any future expansion of commodity sourcing, own plantations, processing facilities, and logistics activities. This practice will refer to applicable country-level legal and regulatory requirements, the IFC Performance Standards and Voluntary Agro-Commodity Standards (e.g. RTRS, Bonsucro, Rainforest Alliance, BCI). For existing assets or those to be acquired over time, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFCs Performance Standards requirements and relevant requirements of the World Bank Groups general and sector-based Environmental, Health and Safety (EHS) Guidelines (e.g. annual crop production, perennial crop production (sugar), sugar manufacturing and vegetable oil production and processing). Noble Agris grains and oilseed operations maintain a legal and regulatory registry in order to pro-actively and timely ensure permit and license renewal process. This practice will be expanded to all 39 Noble Agri operational units in the near future.

Environmental and Social Management Programs: Noble Agris management programs are defined at the corporate, regional or local level depending on a number of factors which include size and structure and type of operating activity of the respective business lines (mainly grains and oilseeds “ G&O, and sugar). Regional management programs for environmental, health, and safety (EHS) are complemented by locally defined or plant level requirements. For example, the sugar cane mills in Brazil as well as the soybean crushing plants in China have detailed, plant-specific, EHS plans and procedures whose scope is defined in the ESIAs during the environmental licensing phase and which consists of E&S management programs spelling out prevention, control, mitigation, and monitoring requirements for each of the identified impacts (e.g. in Brazil, this E&S management program is referred to as PBA, or Plano Básico de Ação in Portuguese). These plans include aspects related to both construction and operational phases of these facilities. The agriculture division from sugarcane mills also has an annual sugarcane plantation and harvesting management program that includes specific procedures for soil conservation, use of fertilizers and integrated pest management program. In Brazil and Argentina, similar programs have been developed to cover occupational health and safety (OHS) aspects, as further described in the respective section below under PS2, Labor and Working Conditions. As a matter of corporate policy commitment, Noble Agri attempts to pursue applicable industry certifications of owned assets including in many cases specific environmental, health, safety and social (EHSS) management plans and procedures. Below is a list of EHSS certifications currently held by Noble Agris assets and subsidiaries:


Commodity
Asset
Country
Asset Type
Current Certification
Coffee
Casa Nobre Coffee Processing and Storage Facility, Alfenas, Minas Gerais
Brazil
Processing Facility, Storage Facility
TN-CC 020, ISO 14064
Sugar & Ethanol
Catanduva Sugar Mill and Ethanol Production Facility
Brazil
Processing Facility
Ethanol Verde, Labour Cert., ISO 14064
Sugar & Ethanol
Meridiano Sugar Mill and Ethanol Production Facility
Brazil
Processing Facility
Ethanol Verde, Labour Cert., ISO 14064
Sugar & Ethanol
Potirendaba Sugar Mill and Ethanol Production Facility
Brazil
Processing Facility
Ethanol Verde, Labour Cert., ISO 14064
Sugar & Ethanol
Votuporanga Sugar Mill and Ethanol Production Facility
Brazil
Processing Facility
Ethanol Verde, Labour Cert., ISO 14064
Sugar
Santos, Dry Bulk Export Terminal
Brazil
Port
ISO 14001, ISO 9001, OHSAS 18001, OCP 0044, Vessels Oil Spill Emergency Plan, ISO 14064, US FDA
Grains & Oilseeds
Jordan Grain Handling Co. (JOGCO), Amman
Jordan
Storage Facility
GIPSA, GAFTA, ISO 14064
Grains & Oilseeds
Fuling Oilseed Processing Complex
China
Processing Facility
HACCP, ISO 9001,
ISO 14001, ISO 14064
Grains & Oilseeds
Timbúes Oilseed processing facility,River Port Grain Terminal & Biodiesel Production Plant
Argentina
Harbor Terminal & Processing Facility
GMP+ B2 (includes guidelines HACCP+ISO 9001), ISO 14001, OSHAS 18001, 2BSvs, RFS2 individual scheme (EPA), ISO 14064, US FDA, KOSHER.
Grains & Oilseeds
Longkou Shandong Oilseed Processing Complex
China
Processing Facility
HACCP, ISO 14064
Grains & Oilseeds
Mingfa Taixing
China
Processing Facility
HACCP, ISO 14064
Grains & Oilseeds
Qinzhou Oilseed Processing Complex
China
Processing Facility
HACCP, ISO 14064
Grains & Oilseeds
Nantong Oilseed Processing Complex
China
Processing Facility
HACCP, ISO 9001,
ISO1 7025, ISO 14064
Grains & Oilseeds
Terminal Graneleras Uruguayas (TGU)
Uruguay
Port
ISO 9001, ISO 14064
Animal Feedstuffs
Noble Resources South Africa (Pty) Ltd
South Africa
Business Entity
AFMA, ISO 14064
Grains and Oilseeds
Corpus Christi silos
Paraguay
Storage Facility
2BSvs; ISO 14064
Grains and Oilseeds
Katuete silos
Paraguay
Storage Facility
2BSvs; ISO 14064
Grains and Oilseeds
La Paloma silos
Paraguay
Storage Facility
2BSvs; ISO 14064
Grains and Oilseeds
Maganini silos
Paraguay
Storage Facility
2BSvs: ISO 14064
Grains and Oilsseds
Troncal 3 silos
Paraguay
Storage Facility
2BSvs: ISO 14064

Going forward, and as set forth in the ESAP, in order to ensure greater consistency of its EHS performance-based requirements and management practices across its business lines and its operations, Noble Agri will develop and implement a corporate Environmental, Health and Safety, and Social (EHSS) Management System (MS) in accordance with IFC PS1 “ and consistent with ISO 14001 and OHSAS 18001, applicable to the development, construction and operational phases of business activities globally. The EHSS Management System shall include EHSS management plans and procedures applicable to the companys business activities in order to comply with applicable national laws and regulations, IFCs Performance Standards requirements and applicable WBGs general and sector-specific Environmental, Health and Safety (EHS) Guidelines. The new global EHSS plans and procedures shall be communicated to all company operations, including employees, contractors and consultants. Noble Agri shall make available supporting evidence of complete and effective implementation of the EHSS Management System (MS) at the regional, country, and local operational level (e.g. final documentation of the EHSS MS, including policies, plans, manual of procedures and programs, e.g. training logs, monitoring records, minutes of progress reviews). Noble Agris G&O division is scheduled to launch an internal ISO 14001 and OHSAS 18001 audit for all its soybean crushing plants and oil refineries in Asia (China), India, Central Europe and South Africa in December 2015. Findings and corrective actions will be available by March 2016.

Organizational structure and management capacity: Accountability of sustainability and EHS issues in Noble Agri is managed, at the corporate level, by two recently hired co-Directors who are leading the grains and oilseeds (or G&O, Mr. Kevin Brassington) and sugar (Mr. Marcelo de Andrade) business lines. These co-Directors report directly to Noble Agri CEO (Matt Jansen) who has been recruited in May 2015.

The company has nominated a number of thematic champions to support the effective and timely implementation of Noble Agris EHS Policies and procedures. In September 2015, Noble Agri formalized the establishment of a corporate sustainable/EHS team consisting of three professionals and strengthened the EHS accountability for the existing three Regional Technical Directors for the G&O Division, and Commodity E&S Coordinators for coffee, sugar and cotton. Noble Agri recruited in November 2015 (as specified in the ESAP of #34738), a Sustainability Manager for Latin America. At the plant-level, EHS managers and/or coordinators are officially assigned and explicitly identified in the plant organigram. For example, the Noble Bioenergy division in Brazil has an EHS manager that is also supporting soy operations in Latin America and who is further supported by the following typical arrangement: Environmental Monitoring is under the responsibility of quality assurance (QA); OHS management is part of the Human Resources (HR) department; and the management of environmental control equipment/ facilities is under the responsibility of plant or site operations. The sugar mills operations in Brazil have a dedicated environmental analyst and a team of OHS professionals (OHS engineers, OHS technicians, doctors and nurses) reporting to the Environmental and OHS Coordinators respectively. The same structure was seen in operation at the two soybean crushing facilities in China.

Training: The definition of EHS training requirements takes place at the regional and local level and depends on the structure and nature of the operations as well as being responsive to local regulatory requirements. For example, Nobles operations in Brazil and China have structured annual training programs that include an EHS induction for new employees (and contractors), as well as specific trainings, as needed for the job in industrial or field operations, such as obligatory safety precautions (e.g. working in heights, working in confined spaces), emergency and fire drills, machine operators, boiler operators, pesticides use and handling, vinasse irrigation, and general environmental best practices, among others. Going forward, and as set forth in the ESAP, Noble Agri will develop and implement a management system procedure and provide evidence of the implementation of the staff training, at corporate (and for each business lines, e.g. G&O, sugar, and supply chain) and plant-level, including mainstreaming into corporate, business line and plant-level training manual, addressing the companys EHSS and Sustainability Sourcing policies, IFCs PS requirements (direct operations and supply chain) and WBGs EHS Guidelines (for direct operations).

Monitoring and Reporting: EHS monitoring, internal, and external reporting practices at Noble Agri are defined by the respective business units at the global, regional, and local levels and depend on the respective business unit practice defined by experience and local regulatory requirements. For example, within the G&O Division, Noble Agri monitors key performance indicators (KPIs) pertaining to OHS matters of its employees and contractors, such as Medical Aid Frequency Rate, Lost-Time Injury Frequency Rates, Accident Severity Rate, Decreasing Failure Rate, Safety Index, and Fatalities at all its operations. The G&O Division also monitors training hours and overall safety performance of each site which are recorded in a monthly operational safety report compiled for the whole G&O Division. Brazilian operations are further monitored to comply with local regulatory requirements such as work related injuries, air emissions, watershed quality, field application of vinasse wastewater, pesticides consumption, water consumption and solid wastes generation and disposal. In the State of Sao Paulo, Brazil, the sugar mills report indicators defined by state environmental regulator CETESB (Companhia de Tecnologia de Saneamento Ambiental) and federal environmental regulator IBAMA (Instituto Brasileiro de Meio Ambiente), on an annual basis. Brazilian soy crushing facilities and combined biodiesel plants also have their own EHS monitoring plans, which include air emissions and wastewater monitoring, OHS accident and severity rates, waste production and disposal, and environmental noise monitoring. OHS exposure to hazardous agents such as noise, dust and heat is also monitored at all sites. Noble Agri also has an OHS health monitoring program (PCMSO “ Plano Medico de Controle da Saúde Ocupacional) that includes periodic clinical assessment as well as specific tests and exams such as audiometry, eye testing, blood pressure, diabetes, urine and blood testing for specific chemical contamination indicators.
Environmental data collected at all owned facilities include energy consumption, including carbon emissions, water consumption, waste generation and management and characterization of wastewater effluents before and after on-site treatment. Such baseline data have allowed some facilities and port terminals (16 out of the 39 facilities) to establish environmental and/or resource efficiency targets for electricity, steam, natural gas, water, and hexane consumption. As an example, for its sugar mills, Noble Agri has set a target to consume 0.7 tons of water consumption per ton of sugar processed, which is within industry benchmark as defined under WBGs EHS guidelines for sugar manufacturing. Carbon intensity has also been monitored at all facilities for the last 5 years. Noble Agris facilities are subject to various third party certifications (previously summarized in this report) and are further audited as part of the certification renewal process.
As part of the ESAP requirements of the IFC equity investment in October 2014 (#34738), Noble Agri undertook a gap analysis of its existing KPIs monitoring system and began expanding them for each facility, including establishing key KPIs that would help enhance its overall EHSS management, monitoring and performance. Further standardization and formalization of environmental KPIs (carbon, water, energy, wastewater and air emissions) and safety KPIs, such as retention and training, at all Noble Agri facilities are planned. As set forth in the ESAP, Noble Agri will, for its direct operations (e.g. plantations and processing facilities), continue to review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including a) Safety “ Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability “ Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees.
Noble Agri will further prepare an integrated annual EHSS report format based on critical EHSS KPIs (e.g. compliance with legal and regulatory requirements, EHSS management system progress report and audit covering aspects such as facility and commodity certification initiatives; energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and hazardous waste management and disposal, effluent discharges from on-site WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities). A summary of the EHSS report shall be publicly disclosed annually following a format equivalent to the Global Reporting Initiative (GRI). Noble Agri commit itself to report its Sustainability/EHS performance using the Global Reporting Initiative (GRI) G4 Guidelines by June 2017 and to disclose its report on its website (http://www.nobleagri.com/en/).

Emergency Preparedness and Response. Noble Agri has updated a corporate Plant Emergency Preparedness Policy and Procedures which has been implemented at all its industrial facilities having fire and explosion risks. As an example, from a normative standpoint, Noble Agris crushing operations in Argentina are required to meet the National Fire Protection Standards (NFPA, #36) specifically applying to industrial plants using hexane in chemical oil extraction. Verification of compliance with NFPA is undertaken by insurance company while local fire authorities approve fire prevention and fighting systems for the other plants. In Brazil, Noble Agri sites have obtained the required emergency response plans covering scenarios of typically applicable emergency situations such as fires, explosions, and leaks to the environment as well as fire brigade, evacuation and communication plan. During the recent supervision of Noble Agris soy crushing facilities in Qinzhou and Fuling in China, IFC confirmed the effective implementation of such policy and procedures. Fire brigades exist at all plants and for the sugar and soybean crushing plants; each member of the fire brigade has received specialized training from local fire authorities, including quarterly internal fire drills and annual joint fire drills with local authorities. As mentioned above (see training section under PS1), use of fire extinguishers and how to respond to different types of fires is included within the annual EHS training of all workers. During recent IFC supervision at Noble Agri soy crushing plants in China, verification of effective implementation of the hexane storage, boiler operations, and thermal oil heaters and vaporizers, including 47 safety critical instruments, has been validated.

Stakeholder Engagement Plan. The consultation process inherent in the preparation of ESIA Studies include interaction with surrounding communities. As an example, new project developments have to be disclosed in public hearings and ESIA reports, following Brazilian and Argentinean licensing procedures. In general, however, Noble Agris industrial operations are located in industrial areas and/or port terminals with no immediate surrounding communities. As such, due to this limited interface, Noble Agri has yet to develop a comprehensive stakeholder engagement plan for all its operations. A community grievance mechanism has been fully operational in Brazil since August 2013 and will shortly be expanded to Colombia (http://www.ouvidorianoblebrasil.com.br). In order to harmonize such mechanism across all countries of operations, and in accordance with ESAP under #34738, Noble Agri has adopted in October 2015 a Stakeholder Engagement and Community Grievance Mechanism Policy. The procedures for the effective implementation of this policy are presently under development and will consist of the development of a Stakeholder Engagement Plan (only for the sites having exposure to surrounding communities) and a dedicated community grievance mechanism through a dedicated platform (http://www.navexglobal.com/) scheduled to be available online by August 2016.

Human Resource Policy: Globally, Noble Agri has a total of 9,600 permanent workers and contractors. Latin American sugar and soybean harvesting operations are mechanized and thus do not require the use of migrant laborers. As mentioned above, Noble Agri is a signatory to the UN Global Compact which includes public commitments to manage its activities in according with the principles of Human Rights, Freedom of Association including workers right to collectively bargaining, and eradication of child and forced labor, etc.



Noble Agri adopted in October 2015, in accordance with ESAP #34738, an updated Human Rights (Labour) Policy, in compliance with IFC’s Performance Standard 2 which commit the company to i) respect employees’ rights to freely associate, organize and bargain collectively in accordance with applicable laws; ii) comply with national labor laws/codes and industry norms on employees’ pay, work hours and conditions; iii) ensure no discrimination in hiring and employment practices with regard to race, color, religion, sex, age, physical ability, political opinion, social or ethnic origin and sexual orientation; iv) not tolerate any form of forced, involuntary or harmful child labor; v) apply OHS systems, procedures and personal protective equipment to create a safe and healthy work environment. Implementation of these principles is the responsibility of Noble Agri’s Human Resource (HR) Director. For example, in Brazil Noble Agri has a formal General HR policy with key core objectives and further details according to Brazilian labor regulations. The core objectives include a commitment to promote a fair and safe workplace; to follow the labor laws and best sector practices; to recognize the workers’ rights of freedom of association; to avoid any form of forced and child labor; to stand against sexual or other forms of harassment. The HR Policy further defines terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday are established by national labor regulations and applicable sector specific collective bargaining agreements. Although Brazilian workers in general are familiar with the national terms of employment, the company also informs them during the induction phase about the specific terms of the job position and additional benefits. In Brazil, Noble Agri has further adopted a range of HR operational procedures to guide the work of the HR department, such as a recruiting and hiring, termination, performance assessment and promotion, payment of wages and salaries and induction.



Going forward, and as set forth in the ESAP, using its recently approved corporate Human Rights Policy as performance benchmark requirements, Noble Agri will review and update all its country-level operations Human Resources policies and procedures to ensure consistency with PS2 requirements and with national labour law, and will ensure its operat
ionalization in each country of operation, as defined by locally applicable labor, OHS, life and fire safety, and emergency preparedness requirements. The corporate and the local HR policies will make explicit reference to Noble Agri’s corporate Human Rights policy commitments to non-discrimination and equal opportunity; minimum work age requirements; workers’ rights to freedom of association; respect for collective agreements, if these are present; maximum working hours; and working conditions and terms of employment. As part of the deployment of the global HR policy, Noble Agri will develop and disseminate a corporate worker grievance policy and procedure applicable to its workers and contractors according to IFC PS2 and ensure implementation at the plant-level.



Nondiscrimination and equal opportunity: In addition to its commitment to the UN Global Compact, Noble Agri’s management of non-discrimination matters is defined by locally applicable requirements. For example, as any form of discrimination is considered a crime in Brazil, Noble Agri has set up local procedures to avoid discriminatory practices (including sexual or moral harassment) in hiring and every day operations. Brazilian law also requires companies to investigate any complaints of misconduct and take corrective actions, as appropriate. Medical exams are requested as part of the hiring process and according to the function the worker will perform. In Brazil no HIV or pregnancy testing is performed as part of the hiring process or regular medical screening. Women employees are allowed to work in administrative or operational functions. Noble Agri has also established recruiting and hiring procedures to meet Brazilian requirements and quotas for the hiring of disabled persons.



Retrenchment: Although the prospects for retrenchment in Noble Agri’s current operations are unlikely given the company’s future expansion plans, going forward, and as set forth in the ESAP, Noble Agri will develop a retrenchment policy and procedure that complies with local requirements and IFC Performance Standard 2 to be applied in the event that the company’s business plans lead to retrenchment at any of Noble Agri’s current operations.



Protecting the Work force: s Noble Agri’s management of non-discrimination matters is defined in its Human Right Policy and comply with locally applicable requirements. For example, in Brazil Noble Agri ensures that no Child Labor or Forced Labor is used at their operations through their hiring and selection procedure. Child labor is illegal in Brazil and there is a task force from the Ministry of Labor that inspects and enforces the law. In the recent years, the sugar industry has agreed in a progressive approach to eradicate manual harvesting of sugarcane in the State of São Paulo, which significantly reduced the cases of forced labor in the region. Regarding their supply chain in Brazil, Noble is in constant dialogue with suppliers providing technical ass
istance and monitoring compliance regarding labor (and environmental) issues. A list of identified cases of child/forced labor are publically available at MTE (Ministério Trabalho e Emprego, in Portuguese) website (sistemasiti.mte.gov.br/ and portal.mte.gov.br/trab_escravo/resultados-das-operacoes-de-fiscalizacao-para-erradicacao-do-trabalho-escravo.htm) and no cases of child/forced labor in sugarcane industry were identified in the region of Noble Agri’s sugar plantations and mills. As set forth in ESAP (ref. Supply Chain Risk Assessment and Management), Noble Agri will periodically check if suppliers are enrolled in the lists for Child/forced labor in Brazil. Noble Agri will also develop and implement a chain of custody verification system, in accordance with Bonsucro Standards, to verify the existence of child/forced labor across its supply chain, and will also periodically check if its suppliers are enrolled in the Child/forced labor lists.



In the soy sector in Brazil, child/forced labor is not common owing to the high rate of mechanization of production. However, as set forth in ESAP, the company will develop and implement a supply chain verification system to periodically verify if their suppliers are enrolled in one of the child/forced labor lists in Brazil. However, Noble Agri has a high risk of reputational exposure to harmful child labor in its supply of coffee and cotton. This issue will be further address through the implementation of the Supply Chain Risk Assessment and Management described in the ESAP.



Life and fire safety: Noble Agri’s management of life and fire safety of its operations is defined by locally applicable requirements. In Brazil, Noble Agri is deploying required life and fire safety equipment such as fire detectors, alarm systems, hydrants, foam chambers, and portable extinguishers following São Paulo State Fire authority Standard IT 27/2004. Noble has the permits from local fire departments (Auto de Vistoria do Corpo de Bombeiros – AVCB, in Portuguese) Industrial sites are classified according its risk of explosion (following Brazilian Standard NR10) and in those areas considered with high risk (a.e. distillery, sugar storage warehouse or soy silos) Noble Agri deploys means of access control as well as intrinsically safe electrical equipment. Per CETESB request, sugar mills develop Risk Management Plans including (i) safety records of process maintenance (ii) maintenance and assurance of critical systems integrity; (iii) Operational Procedures; (iv) training and (v) Emergency Preparedness and Response Plan (Plano de Ação de Emergêncais – PAE, in Portuguese).



Occupational Health and Safety: Noble Agri has recently adopted an updated Occupational Health and Safety Policy which commits itself to comply with applicable country-level OHS legal requirements and IFC Performance Standards requirements. The implementation of this policy is under the accountability of the two Co-Directors leading the G&O and Sugar D
ivision; Noble Agri corporate EHS team monitors trends in OHS accidents from all Noble Agro operations. Nonetheless, practical implementation of Noble Agri’s OHS management systems, including the design and implementation of policies, procedures and training to prevent accidents, based on workplace risk assessment, is defined by locally applicable requirements. For example, in Brazil and China, Noble Agri has developed well-structured team managing the OHS hazards and risks consistent with Brazilian and Chinese labor requirements. Noble Agri has mandatory OHS programs in place, such as risk prevention plans, health monitoring plans, an accident prevention committee, and emergency preparedness response plans. In Brazil, Noble Agri has adopted policies and procedures to manage OHS, including, among others, OHS Management Program (ref. Programa de Gestão de Segurança do Trabalho e Saúde-PGSST) that includes preventive/corrective inspections, accidents and incidents analysis, and OHS mandatory programs, such as Risk Prevention Plan (Plano de Prevenção de Riscos Ambientais – PPRA), Health Monitoring Plan (Programa de Controle Médico da Saúde Ocupacional – PCMSO), Hearing Protection Program (Programa de Conservação Auditiva), Respiratory Protection Program (Programa de Proteção Respiratória). Noble Agri also has specific procedures for hazardous works (working at heights, working with heat, working with electrical systems, working in confined spaces, working in explosive atmospheres), which must be followed by the hazardous works permitting procedure. Verification of such permit system has been validated at two Noble Agri soy bean crushing operations in China in November 2015. This supervision has also confirmed the effective implementation of 25 OHS policies and procedures which systematically applies to all Noble Agri’s soybean crushing operations. OHS performance at these two crushing plants was deemed excellent with no permanent employees and contractors experiencing lost-work days since 2012.



Consistent with Brazilian and Chinese requirements, Noble Agri has implemented appropriate collective prevention measures and, where necessary, provided the appropriate Personal Protective Equipment (PPE). Noble Agri has adopted centralized pesticides storage warehouses for its sugar plantations in Brazil, where products are mixed with water into trucks that deliver to the product to spraying front. All units are in the process of implementing this system. Noble Agri had identified all confined spaces and developed a procedure for working inside confined spaces consistent with Brazilian and Chinese Safety requirements and WBG’s EHS general guidelines. Noble Agri mills are in different stages of making an inventory of all pressure vessels, documenting its technical specifications and developing individuals’ maintenance books, under a corporate program in accordance with Brazilian Safety Standard (NR13). Noble Agri is also conducting an assessment of all pl
ants to identify gaps with Brazilian Safety Standard of Electrical Systems (NR10). Going forward, as set forth in the ESAP, Noble Agri will conduct OHS audits of existing and newly acquired assets against local legal requirements and applicable IFC Performance Standards and will prepare a Corrective Action Plan to bring operations into compliance with these requirements. In Brazil, the audit will include specific reference to Brazilian National Standards NR10 and NR13. Since IFC investment in October 2014, two fatalities have occurred in Noble Agri’s Brazilian operations, namely at Rondonopolis soy crushing plant in July 2015 and at Meridiano sugar mill in December 2015. Another fatality has occurred in Noble Agri’s Nantong Oilseed Processing Complex in December 2015. Investigations reports have been shared with IFC and corrective actions have been implemented.

Air emissions monitoring: Noble Agri’s management of atmospheric emissions is defined by locally applicable requirements. For example, in Brazil, Noble monitors emissions from all boilers every year, seeking compliance with CONAMA Res 357/06 and 436/11 requirements. Same monitoring system have been established for its soybean crushing operations in China. This system has been verified during last site supervision in November 2015. In some cases and per Brazilian’s CETESB request, air dispersion models were conducted and more restricted emissions thresholds were defined for Particulate Matter emissions. Verification of air emissions parameters from coal-based boilers at the soy crushing plants in China confirmed compliance of SO2, NOx and particulate matter with WBG EHS’s general guidelines for point source emissions to air (PM10: 50mg/Nm³; NOx: 460 mg/Nm³; SO2: 2,000mg/Nm³).



Effluents: Noble Agri’s management of effluents from its operations is defined by locally applicable requirements. In Brazil, for example, wastewater from sugar/ethanol mills in the State of Sao Paulo include: (i) process wastewater from ethanol production (vinasse), (ii) wastewater from cane washing, (iii) wet scrubber blow down from stack gas scrubbing, and (iv) miscellaneous wastewaters. Noble’s mills do not discharge wastewater to rivers or surface water bodies and all waste water is used as a fertilizer in the sugarcane plantations under a ferti-irrigation system. At the mills, effluents are used in irrigating fields within a radius of 30 kilometers by trucks. Noble Agri has a formal management plan for vinasse application in the field and follows the CETESB standards of wastewater used in sugarcane plantations. The amount of wastewater applied in the plantations is determined by the soil characteristics and the nutrient needs of the crop. At least one of the mills, Potirendaba, has vinasse concentration process, which recovers 60% of the water that is re-used in the mill.



Vegetable oil and Biodiesel plants generate significant amounts of wastewater from the oil extraction process, and Noble Agri plants relies on on-site wastewater treatment facilities that includes physical chemical treatment unit and a sequence of aeration and polishing lagoons. Wastewater treatment is designed to meet local regulatory requirements, and typically COD, BOD, Suspended solids, temperature, PH, oil and grease are monitored. Verification of effluents parameters after treatment at on-site WWT plants at the two soybean crushing plants in China confirmed compliance with WBG’s indicative values for treated sanitary sewage discharges for all above mentioned parameters.



Solid Wastes: Noble Agri’s management of solid wastes is defined by locally applicable requirements. For example, its Brazilian sugar mills produce significant amount of organic wastes (filter cake, ashes from boilers and sand from sugar production tanks). These are taken to a composting area where they are composted
and then applied to the fields. Metal scrap, is segregated, stored outdoors and sold for recycling. The solid waste from administrative area and dining-hall is collected and disposed to the local public waste system. Noble Agri collects back all empty containers of pesticides and sends it to certified recycling companies. Going forward, as set forth in ESAP, Noble Agri will evaluate, as part of the E&S monitoring of existing facilities and assessment of future acquisitions, the atmospheric emissions, wastewater effluents, and solid waste management practices of agricultural and industrial operations. The company will ensure that emissions from sources, such as boilers, effluents from oil pressing and sugar processing facilities, and wastes from all facilities are managed according to applicable WBG EHS Guidelines for existing facilities at a minimum complying with local regulatory requirements if it is not technically and/or economically feasible to achieve the IFC Performance Standards and WBG EHS Guidelines. Verification of such requirements took place during IFC supervision of two Noble Agri soy crushing plants in China. IFC confirmed compliance with these requirements



Sustainability of Water Resource: Noble Agri’s management of water resources is defined by locally applicable requirements. In Brazil, for example, sugarcane cultivation in Noble Agri’s operation relies exclusively on natural rainfall. Extraction of water from surface or groundwater sources for process operations is done at the sugar mills in Sao Paulo State where Noble Agri indicates that it has obtained all required permits from the state government to extract the water. Water usage at the mills vary from 0.7 to 1.0 m3/ton-cane and is consistent the WBG’s EHS sugar production Guidelines reference and benchmark in the sector.



Greenhouse Gas Emissions: Noble Agri’s management of greenhouse gas emissions is defined by locally applicable requirements. In Brazil, for example, Noble Agri’s sugar mills generate their energy from sustainable resources through co-generation of electricity from burning bagasse. Soy crushing and processing facilities in Brazil depend on a mix of woodchips, natural gas and crude oil to generate steam and energy from the boilers. Noble Agri deployed new modern boilers (high volume and high pressure) to achieve high efficiency in energy production. Woodchips are sourced exclusively from planted forests to reduce total GHG emissions. For all Noble Agri assets, the estimated carbon emissions are estimated at 633,260 t CO2 equivalent in 2014. This carbon footprint has been calculated and externally verified.



Integrated Pest Management: Noble Agri’s pest management approach is defined by locally applicable requirements. For example, in Brazil the company applies the principles of Integrated Pest Management (IPM) in its plantations. IPM practices include the use biological techniques to control sugar cane borer population with Cotesia flavipes parasi
te and Drury larvae control with Metharizium Bacteria. Approved chemicals and fertilizers are used, and application rates and methods are adapted to optimize consumption. As required under ESAP #34378, Noble Agri has reviewed its list of pesticides and has phased out all products falling in WHO Class Ia and Ib. This phase out has been successfully completed for its Brazilian farming (sugar) operations and in the process of being completed for its South African farming operations. As mentioned before, Noble Agri is adopting a centralized system of storing and, handling and mixing pesticides that goes to the field ready to use. Noble Agri uses exclusively tractors with cabinets for spraying operations, and handling, storage and use agricultural chemicals follow national regulations and can be considered best practices.



Hazardous Materials: Noble Agri’s management of hazardous materials is defined by locally applicable requirements. Hazardous materials used and stored in Noble Agri’s Brazilian sugar mills include significant amounts of chemicals, such as soda, sulfur acid, chlorine, cyclohexane and pesticides. New greenfield mills (Meridian and Potirandaba) have very good bulk chemical storage areas, with secondary containment, risk identification, warning signs, access control and emergency kits and showers. In Votuporanga, Noble Agri is investing in a new sugar mill aligned with Brazilian and World Bank EHS guideline requirements. Noble Agri Bioenergia is also investing in chemical containers warehouses that have been storage outdoor for a while. Noble Agri will also improve gas cylinders storage area following Brazilian standard requirements. Recent supervision in China confirmed compliance for hexane storage in accordance with local safety code as well as existence of appropriate secondary containment structures consisting of walls capable of containing more than 110 percent of the tank volume. Used oil is collected in drums and disposed through qualified service provider.

Community Health and Safety. Noble Agri’s management of community health and safety risks is defined by locally applicable requirements. As an example, potential risks to communities from Noble Agri’s operations in Brazil are primarily associated with the risk of explosions of ethanol tanks or sugar storage silos, air emissions from boilers, fugitive air emissions from trucks (dust) and aerial application of herbicides (to speed the sugarcane maturation process). In Brazil, most locations use aerial spraying of crops by licensed companies using crop spraying airplanes which follow local regulatory requirements. To improve oversight of these operations and minimize risk, Noble Agri is in the process of developing a management procedure associated with aerial spraying of chemicals in accordance with the FAO Guidelines for its sugar plantation under its direct management. This procedure will avoid the risks and impacts to health and other crops and include weather conditions monitoring during aerial spraying, pro-active communications with neighbors and safety exclusion buffer zones from towns, small villages or households. As set forth in the ESAP, Noble Agri will provide this procedure, for IFC review and clearance. Noble’s Agri sugar mills have annual sugarcane transportation plans, in which communities are mapped and routes of trucks are designed to avoid proximity with them. Access roads safety conditions are assessed and improvements are designed to ensure overall traffic and people safety. A report with the assessment and improvements is provided to the environmental authority. Noble Agri’s mills assess environmental noise outside their fences following Brazilian standard NBR 10151, and sometimes noise levels (62dbA) can be higher than the threshold for rural areas (45dbA), however since there are no direct receptor close by mills’ fences, this is not a concern for the time being.

Security Personnel: Noble’s approach to site security management is defined by locally applicable requirements. In the case of Brazil, Noble Agri has access protocols for its operations which include checkpoints prior to entry into company facilities. Also in Brazil, security personnel are unarmed and are trained to respond to potential treats to company facilities and infrastructure, including procurement of public safety officials to address criminal activities. In accordance with ESAP #34738, Noble Agri has successfully conducted a security risk assessment at its 39 operations, including use of weapons. Based on the results of this internal audit, Noble Agri is in the process of developing and implementing a management procedure for site security issues which will include the Voluntary Principles on Security and Human Rights. Noble Agri will also systematically include contract provisions when using third-party security agencies, to ensure proper training, including prevention and resolution in case of violent and armed conflicts.

Noble Agri’s management of biodiversity conservation is defined by its corporate Environmental Policy which mainstream IFC Performance Standard 6 requirements, locally applicable requirements and by Voluntary Agro-Commodity Standards (e.g. RTRS, Bonsucro) commitments associated with various commodities certifications programs used by local operations.



Protection and Conservation of Habitats: In Brazil, sugarcane plantations are located exclusively on traditional areas of agriculture in Sao Paulo State, and no direct conversion of natural habitats to croplands or significant loss of biodiversity is expected from this project. However main concerns related to land conversion in critical habits are linked to soy supply chain in the Amazon, Cerrado and Chaco biomes, as described below. In Brazil farmers are required to set-aside 20% to 80% of their lands as biodiversity conservation areas and also protect a buffer zone along rivers and water bodies. Noble Agri sugar mills have a program to protect and reforest riparian areas at leased farms and implement ecological corridors following CETESB requirements. Noble has a program to educate and help land owners to move forward into compliance with Brazilian Forest Code which cover the gaps with biodiversity set-asides requirements.



Sustainable Management of Living Natural Resources: As previously mentioned regarding Brazilian operations, sugarcane plantations take place in already converted land and consolidated areas of crop plantations in São Paulo state. As set forth in the ESAP, Noble Agri will manage plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the company’s owned sugar plantations will be managed as defined in Bonsucro Standard and obtained Bonsucro certification for all these operations.



Supply Chain: Noble Agri has adopted, in accordance with ESAP #34738, a Sustainability Sourcing Policy in October 2014. The policy will be applicable to agro-commodity suppliers, with whom Noble Agri has a direct (pre-financing) contract, and outlines a set of principles to support Noble Agri’s objective to source agricultural commodities in a sustainable and responsible manner, in accordance with IFC Performance Standard supply chain related and Voluntary Agro-Commodity Standards requirements.



Noble purchases soy from regions with significant conversion of natural and critical habitats, such as Amazon forest and Chaco region in both Argentina and Paraguay, and also has plans to possibly expand operations into Brazilian Savanna (Cerrado). In Brazil, total soy production area has expanded from 23.5 million ha in 2009 to 29.2 million ha in 2014 and jumped from 68.7 in 2009 to 88 million tons in 2014. Although soy has been growing in all regions of Brazil, the Cerrado biome is the area with greatest expansion. Noble Agri has one large crushing plant and combined biodiesel processing in Rondonópolis, and additional 3 storage units in Nova
Maringá, Sorriso and Campo Verde in the North region of Mato Grosso State (Amazon region), where they originates approximately 5% of its soybean needs from producers with whom they have direct contract (pre-finance). Noble Agri provides the inputs and some working capital and producers are committed to sell the crops under predefined conditions. On the other hand, eighty percent (80%) of the total soy originates from spot market suppliers, which can be either from other small traders or farmers who sell their crops in the market without any contract agreement and from whom Noble Agri has limited leverage and information such as their tax registry number, farm name, and region (municipality). In Argentina Noble Agri has one dedicated port with crushing plant and combined biodiesel processing in Timbues and additional warehouses in Salta, Córdoba, S. D. Estero and Chaco. IFC invested in 2009 in the Timbues operation. In Paraguay, they have logistic warehouses in Katuete, La Paloma, Troncal, Magagnin and Corpus Christi. In both countries, the Grand Chaco is the target area for soy expansion.



In Brazil, Noble Agri is a member of the Roundtable on Responsible Soy (RTRS) and the Amazon Soy Moratorium, in which Soy industry has agreed with civil society to not purchase soy from the Amazon Biome that has been deforested after 2006. Monitoring and verification is conducted by a third party, coordinated by soy industry association ABIOVE that provides annually a list of farms that must be banned from soy crushers and traders suppliers. It is Soy Moratorium Member’s responsibility to block these farmers from their cadaster. IFC appraisal findings identified the need for improved management governance to ensure that Noble Agri would not be buying from banned suppliers. In Argentina, as part of previous commitment with IFC, Noble Agri has agreed to develop and implement a policy to ensure responsible soy purchasing and pilot program to develop a suppliers’ database and monitoring of illegal clearings in Chaco region. Noble Agri has engaged with the Round Table of Responsible Soy (RTRS) and, during 2012, Noble Agri´s supply chain management has been certified by the Biomass Biofuels and Sustainability Voluntary Scheme (2BSVS) to help greater supply chain transparency and integrity of the suppliers’ EHS performance, and which allows the company to export soybean oil and biodiesel to Europe; during 2014, provided and audited by independent body an individual private scheme to meet the requirements of EPA''s RFS2 program to export biodiesel to the U.S. Noble Agri is also sourcing crude palm oil which it refined in its refineries in India and China. As it does not have management control over its CPO suppliers, Noble Agri has not yet established any specific E&S requirements for its CPO suppliers.



A pilot phase with Brazil soybean sourcing has started in November 2015. Specifically, Noble Agri’s soybean suppliers must satisfy the following conditions: i) c
ompliance with all applicable environmental laws and regulations, including, but not limited to, registration in the Brazilian Rural Environmental Cadaster (CAR), when enforced; ii) respect for High Conservation Value (HCV) areas mapping (soy supplied shall be sourced from land that has not been converted from HCV areas to other categories of land-use, applying the following cut-off dates – except if provided for otherwise under national legislation and duly authorized by the competent authority – in the Amazon Biome, suppliers will respect the existing Soy Moratorium and not source from areas cleared of natural habitats after July 2008; suppliers will respect the cut-off dates for land conversion as defined by the Roundtable on responsible Soy (RTRS) and not source from land converted to soy production from an HCV area after May 2009; iii) respect for indigenous Peoples land, including Free, Prior, and Informed Consent (FPIC) must be obtained from indigenous and local communities for the use of their customary lands prior to agricultural development; iv) absence from the forced labor list issued by the Brazilian Ministry of Labor and Employment (MTE); v) absence from the embargoed areas list issued by the Brazilian Institute of Environment and Renewable Natural Resources (IBAMA); and vi) implementation of good agricultural practices. Noble Agri has started developing a supplier database which identified 24 pre-financed soy suppliers which themselves have their own suppliers (this account for roughly 5% of its total suppliers).



With the recent hiring of the Sustainability manager in Latin America, comprehensive supply chain management system procedure will be developed and implemented (e.g. supplier database, geo-mapping, verification of compliance with above mentioned criteria defined in Noble Agri Sustainable Sourcing Policy, training, monitoring and reporting). Following the pilot test of the Noble Agri Sustainable Sourcing Policy for its soy sourcing in Brazil in 2016, Noble Agri will expand its supply chain procedure to Argentina’s soy sourcing (as required under ESAP of #26959, ref. Noble Agri’s Timbues Soy Crushing Plant) and to all other commodities (coffee and cotton) in all countries of origin (if considered “high risk” based on IFC’s GMAP or in IFC’s Good Practice Handbook on Agro-Commodity Risk Assessment and Management) in 2017. Based on the above, Noble Agri is committed by 2018 to develop sustainable sourcing strategies for all its “high-risk” commodities.



For example, in coffee and cotton in West Africa, Noble informs its suppliers on its Supplier’s Code of Conduct and invites them to report on their social and environmental practices. This is an ongoing process to engage suppliers and provide impetus to make progress on their E&S performance. Noble Agri is sourcing its coffee in Vietnam, Brazil, Colombia, Indonesia, India, Ethiopia, Uganda, Rwanda, China, Honduras, El Salvador, Papua New Guinea, Congo, Peru and Kenya. N
oble Agri is sourcing its cotton from the USA, Ivory Coast, India, China, Brazil, Australia, Mali, Benin, Burkina Faso, Cameroon and Greece. All sourcing transactions are forward and spot market based (aside from Brazil/coffee), resulting in the absence of management control over third-party suppliers. Noble Agri looks for ways to ensure its products are grown in a responsible way and works to improve the labor standards in the agriculture community.



Going forward and as set forth in the ESAP, Noble will develop and implement a comprehensive Supply Chain Risk Assessment and Management System. The system will be comprised of several discrete aspects, including a policy; supplier database and monitoring procedures; training program; and management monitoring and guidance. Given the significant current sourcing of soy from Brazil, Argentina and Paraguay, the Supply Chain Risk Assessment and Management System will include specific requirements for soy, coffee and cotton sustainability purchasing plan from these countries, only when Noble Agri can reasonably exercise control over third-party suppliers, including monitoring and verifying land use and land use change.

Noble Agri’s approach to community engagement is defined by local needs and, where applicable, local legal requirements. In Brazil and Argentina, for example, Noble Agri has a communication program that includes community communication of company’s activities such as pesticides spraying and waiting period, sugarcane transport, and harvesting.

As part of Noble Agri’s corporate social responsibility (CSR) initiatives, Noble Agri indicates that it is transferring agricultural and business skills to raise the incomes and protect the biodiversity of coffee farmers in Brazil, Colombia and Vietnam. CSR initiatives originate at the local Noble Agri operations which usually fund them as well. A CSR oversight committee reviews proposals which require funding from corporate sources.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. Noble Agri will also be requested to place an advertisement on its website (http://www.nobleagri.com) to inform the public from IFC’s environmental and social review (ESRS) findings.
Name and Address.

A James Shafter
General Counsel and Managing Director, Corporate Affairs
Noble Agri
207 Route de Ferney, Geneva
Switzerland
Tel: +41 21 331 4308
E-mail: mailto:shafter@nobleagri.com


Charlie Watson
Sustainability Manager
Noble Agri
207 Route de Ferney, Geneva
Switzerland
Tel: +41 21 331 1692
E-mail: mailto:charleswatson@nobleagri.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Noble Agri will develop and implement global corporate Environmental, Health and Safety, and Social policies and Manual of Procedures for each business line (grains and oilseeds, sugar and sourcing divisions) applicable to the Company’s business activities and in compliance with applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines.This shall include, but not limited the development and publication of following policies and accompanying procedures: i. Global Corporate Environmental Policy ii. Human Rights Policy iii. Stakeholder Engagement and Grievance Policy (incl. security arrangements & use of security personnel) iv. Occupational Health & Safety Policy (incl. life and fire safety, emergency planning) v. Responsible Land Acquisition and Leasing Policy The new global E&S policies shall be adopted by the Board of Directors of the Company and communicated to all Noble Agri operations, including employees and contractors. Copies of the EHSS policies will be shared with every new employee at the time of hiring and induction training.	06/30/2016
Noble Agri will develop and implement global corporate Environmental, Health and Safety, and Social policies and Manual of Procedures for each business line (grains and oilseeds, sugar and sourcing divisions) applicable to the Company’s business activities and in compliance with applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines. This shall include, but not limited the development and publication of following policies and accompanying procedures: i. Global Corporate Environmental Policy ii. Human Rights Policy iii. Stakeholder Engagement and Grievance Policy (incl. security arrangements & use of security personnel) iv. Occupational Health & Safety Policy (incl. life and fire safety, emergency planning) v. Responsible Land Acquisition and Leasing Policy The new global E&S policies shall be adopted by the Board of Directors of the Company and communicated to all Noble Agri operations, including employees and contractors. Copies of the EHSS policies will be shared with every new employee at the time of hiring and induction training.	03/31/2016
Noble Agri will develop and implement global corporate Environmental, Health and Safety, and Social policies and Manual of Procedures for each business line (grains and oilseeds, sugar and sourcing divisions) applicable to the Company’s business activities and in compliance with applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and Safety Guidelines. This shall include, but not limited the development and publication of following policies and accompanying procedures: i. Global Corporate Environmental Policy ii. Human Rights Policy iii. Stakeholder Engagement and Grievance Policy (incl. security arrangements & use of security personnel) iv. Occupational Health & Safety Policy (incl. life and fire safety, emergency planning) v. Responsible Land Acquisition and Leasing Policy The new global E&S policies shall be adopted by the Board of Directors of the Company and communicated to all Noble Agri operations, including employees and contractors. Copies of the EHSS policies will be shared with every new employee at the time of hiring and induction training.	06/30/2016
Noble Agri will develop and implement formal corporate ESMS applicable for all existing and future owned sites (primary agricultural production, processing facilities, elevators, port terminals), commensurate with the level of the environmental and social risks and impacts in order to comply with applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank’s general and sector-specific Environmental, health and Safety Guidelines. This EHSS Management System shall include policies and procedures (as required under ESAP #1, above), risk assessment procedure (as required under ESAP #3, below), assignment of organizational EHS structure, management and training programs, monitoring KPIs, minutes of progress review, inspection and internal/external audit, and stakeholder engagement plan and community grievance mechanism. .	12/31/2016
Noble Agri will develop and implement formal corporate ESMS applicable for all existing and future owned sites (primary agricultural production, processing facilities, elevators, port terminals), commensurate with the level of the environmental and social risks and impacts in order to comply with applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank’s general and sector-specific Environmental, health and Safety Guidelines. This EHSS Management System shall include policies and procedures (as required under ESAP #1, above), risk assessment procedure (as required under ESAP #3, below), assignment of organizational EHS structure, management and training programs, monitoring KPIs, minutes of progress review, inspection and internal/external audit, and stakeholder engagement plan and community grievance mechanism. .	12/31/2017
Over time, Noble Agri will be constructing new sites and/or acquiring existing operations. While constructing and/or acquiring these industrial sites and/or plantations, Noble Agri will undertake an Environmental and Social Impact Assessment and/or EHS Audits of these assets in accordance with national requirements and IFC’s Performance Standards, and will include in EPC contracts provisions to ensure adherence to E&S requirements (EHS, Labor and Community), including those defined in ESIA and respective Terms and Conditions underlying Environmental licenses, and the right to audit EPC contractors (construction firms) concerned as part of daily business. Noble Agri will monitor and document EPC contractor’s performance as part of daily business of its owned sites and reports will be shared with corporate senior management. Noble Agri will formalize monitoring contractor’s performance as part of job description responsible employee (s) for applicable sites. For existing assets, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and WBG EHS Guidelines. For new assets acquired or any new brownfield or greenfields projects approved after September 28, 2014, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and safety Guidelines.	07/31/2015
Over time, Noble Agri will be constructing new sites and/or acquiring existing operations. While constructing and/or acquiring these industrial sites and/or plantations, Noble Agri will undertake an Environmental and Social Impact Assessment and/or EHS Audits of these assets in accordance with national requirements and IFC’s Performance Standards, and will include in EPC contracts provisions to ensure adherence to E&S requirements (EHS, Labor and Community), including those defined in ESIA and respective Terms and Conditions underlying Environmental licenses, and the right to audit EPC contractors (construction firms) concerned as part of daily business. Noble Agri will monitor and document EPC contractor’s performance as part of daily business of its owned sites and reports will be shared with corporate senior management. Noble Agri will formalize monitoring contractor’s performance as part of job description responsible employee (s) for applicable sites. For existing assets, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and WBG EHS Guidelines. For new assets acquired or any new brownfield or greenfields projects approved after September 28, 2014, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and safety Guidelines.	12/31/2015
Over time, Noble Agri will be constructing new sites and/or acquiring existing operations. While constructing and/or acquiring these industrial sites and/or plantations, Noble Agri will undertake an Environmental and Social Impact Assessment and/or EHS Audits of these assets in accordance with national requirements and IFC’s Performance Standards, and will include in EPC contracts provisions to ensure adherence to E&S requirements (EHS, Labor and Community), including those defined in ESIA and respective Terms and Conditions underlying Environmental licenses, and the right to audit EPC contractors (construction firms) concerned as part of daily business. Noble Agri will monitor and document EPC contractor’s performance as part of daily business of its owned sites and reports will be shared with corporate senior management. Noble Agri will formalize monitoring contractor’s performance as part of job description responsible employee (s) for applicable sites. For existing assets, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and WBG EHS Guidelines. For new assets acquired or any new brownfield or greenfields projects approved after September 28, 2014, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and World Bank Group’s Environmental, Health and safety Guidelines.	12/31/2015
For its direct operations (e.g. plantations and processing facilities), Noble Agri shall review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including: a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees.	12/31/2015
For its direct operations (e.g. plantations and processing facilities), Noble Agri shall review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including: a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees.	06/30/2017
Noble Agri will adopt a corporate Stakeholder and Community Grievance Policy and will then implement Stakeholder Engagement Plan (appropriate to Noble Agri’s level of community impacts) and Community Grievance Mechanism at plant level. This Community Grievance Mechanism should meet IFC Performance Standard requirements, including at least: a formal procedure to follow every grievance, a local phone number, a grievance book in each facility and, a local contact person, among others. In addition, Noble Agri is in the process of recruiting a CSR/Sustainability Manager for Latin America and will expand its existing community programs and implement comparable community initiatives in countries of operation, appropriate to Noble Agri’s level of community impact by its local operations.	08/31/2016
Noble Agri will adopt a corporate Stakeholder and Community Grievance Policy and will then implement Stakeholder Engagement Plan (appropriate to Noble Agri’s level of community impacts) and Community Grievance Mechanism at plant level. This Community Grievance Mechanism should meet IFC Performance Standard requirements, including at least: a formal procedure to follow every grievance, a local phone number, a grievance book in each facility and, a local contact person, among others. In addition, Noble Agri is in the process of recruiting a CSR/Sustainability Manager for Latin America and will expand its existing community programs and implement comparable community initiatives in countries of operation, appropriate to Noble Agri’s level of community impact by its local operations.	06/30/2017
As part of the supply chain component of its corporate EHSS Management System, Noble Agri will develop and implement a Sustainable Sourcing Policy. As a minimum, the Company’s pre financed suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chaco, and Cerrado) must be consistent with sector specific cut off dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of date (June 2008) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land and verification of embargoed areas as identified by the Brazilian Environmental Agency IBAMA. Should the aforementioned Amazon Moratorium cease to be extended, IFC and Noble will explore and agree on alternative sustainability criteria that are applicable to pre-financed suppliers. The criteria will, at a minimum, achieve IFC's Performance Standards requirements applicable to supply chains and will not contravene local laws.	12/31/2015
As part of the supply chain component of its corporate EHSS Management System, Noble Agri will develop and implement a Sustainable Sourcing Policy. As a minimum, the Company’s pre financed suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chaco, and Cerrado) must be consistent with sector specific cut off dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of date (June 2008) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land and verification of embargoed areas as identified by the Brazilian Environmental Agency IBAMA. Should the aforementioned Amazon Moratorium cease to be extended, IFC and Noble will explore and agree on alternative sustainability criteria that are applicable to pre-financed suppliers. The criteria will, at a minimum, achieve IFC's Performance Standards requirements applicable to supply chains and will not contravene local laws.	04/30/2016
As part of the supply chain component of its corporate EHSS Management System, Noble Agri will develop and implement a Sustainable Sourcing Policy. As a minimum, the Company’s pre financed suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chaco, and Cerrado) must be consistent with sector specific cut off dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of date (June 2008) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land and verification of embargoed areas as identified by the Brazilian Environmental Agency IBAMA. Should the aforementioned Amazon Moratorium cease to be extended, IFC and Noble will explore and agree on alternative sustainability criteria that are applicable to pre-financed suppliers. The criteria will, at a minimum, achieve IFC's Performance Standards requirements applicable to supply chains and will not contravene local laws.	12/31/2016
As part of the supply chain component of its corporate EHSS Management System, Noble Agri will develop and implement a Sustainable Sourcing Policy. As a minimum, the Company’s pre financed suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chaco, and Cerrado) must be consistent with sector specific cut off dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of date (June 2008) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land and verification of embargoed areas as identified by the Brazilian Environmental Agency IBAMA. Should the aforementioned Amazon Moratorium cease to be extended, IFC and Noble will explore and agree on alternative sustainability criteria that are applicable to pre-financed suppliers. The criteria will, at a minimum, achieve IFC's Performance Standards requirements applicable to supply chains and will not contravene local laws.	12/31/2017
As part of the supply chain component of its corporate EHSS Management System, Noble Agri will develop and implement a Sustainable Sourcing Policy. As a minimum, the Company’s pre financed suppliers (approximately 5% of total global supply) located in environmental sensitive regions (Amazon, Chaco, and Cerrado) must be consistent with sector specific cut off dates for land conversion (May 2009) and High Value Conservation Areas mapping (where it does exist), Amazon Soy Moratorium cut of date (June 2008) requirements in Brazil as well as legal requirements such as Rural Environmental Cadaster (Cadastro Ambiental Rural, CAR, in Portuguese), respect of Indigenous People Land and verification of embargoed areas as identified by the Brazilian Environmental Agency IBAMA. Should the aforementioned Amazon Moratorium cease to be extended, IFC and Noble will explore and agree on alternative sustainability criteria that are applicable to pre-financed suppliers. The criteria will, at a minimum, achieve IFC's Performance Standards requirements applicable to supply chains and will not contravene local laws.	12/31/2018
In order to implement its Supply Chain Policy as defined in this action plan above, Noble Agri will include in their existing credit review process/requirements for pre-financed agro-commodity suppliers, the following E&S verification points: - Absence from Amazon Soy Moratorium list of banned farmers - Absence from Brazilian official Forced Labor list (from Ministry of Labor) - Farmers must have a valid Registry number in the Environmental and Rural Cadaster (CAR, in Portuguese) or valid Environmental License. - Farms are not enrolled in IBAMA's embargoed list (Brazil) - Farms Should not be encroaching Indigenous People Lands (verifiable through CAR Website, in Case of Brazil) - Farms were not converted to agriculture prior to May 2009 and High Value Conservation Areas Mapping (where it does exist, using CAR information and/or land use change information where available)	06/30/2016
In order to implement its Supply Chain Policy as defined in this action plan above, Noble Agri will include in their existing credit review process/requirements for pre-financed agro-commodity suppliers, the following E&S verification points: - Absence from Amazon Soy Moratorium list of banned farmers - Absence from Brazilian official Forced Labor list (from Ministry of Labor) - Farmers must have a valid Registry number in the Environmental and Rural Cadaster (CAR, in Portuguese) or valid Environmental License. - Farms are not enrolled in IBAMA's embargoed list (Brazil) - Farms Should not be encroaching Indigenous People Lands (verifiable through CAR Website, in Case of Brazil) - Farms were not converted to agriculture prior to May 2009 and High Value Conservation Areas Mapping (where it does exist, using CAR information and/or land use change information where available)	12/31/2016
Noble Agri will implement a training program for their field staff dealing with pre-financed agro-commodity suppliers to: - Create awareness on - and ensure knowledge of Noble Agri’s enhanced Sustainability Sourcing Policy as outlined under point 7; - Raise external awareness of pre-financed suppliers on sustainable agricultural practices to help farmers improve yields, quality, and achieve third party certification of commodities from widely accepted bodies. The set-up may be comparable with current online existing programs of competitors in the market.	06/30/2016
Noble Agri will implement a training program for their field staff dealing with pre-financed agro-commodity suppliers to: - Create awareness on - and ensure knowledge of Noble Agri’s enhanced Sustainability Sourcing Policy as outlined under point 7; - Raise external awareness of pre-financed suppliers on sustainable agricultural practices to help farmers improve yields, quality, and achieve third party certification of commodities from widely accepted bodies. The set-up may be comparable with current online existing programs of competitors in the market.	06/30/2017
Noble Agri will implement a management procedure for periodic reporting and monitoring of the implementation of its Sustainable Sourcing Policy, incl. Supply Chain’s E&S risks and management, and sustainability initiatives to senior management, to allow monitoring of progress of the dynamics of supplier’s classification, keep track of emerging environmental and social issues, determine E&S capacity building needs of field staff and suppliers, and ensure a proactive response and periodical realignment of the Company’s sustainability priorities and mitigation of potential Company exposure to commodity business risks in the short and long term. Noble Agri’s senior management will identify any needed changes in the corporate's ESMS for the management of pre-financed suppliers to reduce, within a commercially realistic way, risks in the supply chain.	07/31/2016
Noble Agri will implement a management procedure for periodic reporting and monitoring of the implementation of its Sustainable Sourcing Policy, incl. Supply Chain’s E&S risks and management, and sustainability initiatives to senior management, to allow monitoring of progress of the dynamics of supplier’s classification, keep track of emerging environmental and social issues, determine E&S capacity building needs of field staff and suppliers, and ensure a proactive response and periodical realignment of the Company’s sustainability priorities and mitigation of potential Company exposure to commodity business risks in the short and long term. Noble Agri’s senior management will identify any needed changes in the corporate's ESMS for the management of pre-financed suppliers to reduce, within a commercially realistic way, risks in the supply chain.	12/31/2016
Noble Agri will further implement a chain-of-custody verification system for its direct sugar production in accordance with Bonsucro Standard.	03/31/2016
Noble Agri will develop and implement a global corporate Human Rights policy consistent with IFC Performance Standard 2 with further reference to local labor laws. Noble Agri will review country level operations Human Resources policies and procedures to ensure consistency with PS2 requirements and national law. The corporate Human Rights and the local Human Resources policies will make explicit reference to the Company’s commitments to non-discrimination and equal opportunity; minimum work age requirements; workers’ rights to freedom of association; respect for collective agreements, if these are present; maximum working hours; and working conditions and terms of employment and local labor laws	06/30/2016
As part of the deployment of the global HR policy, develop and disseminate a corporate worker grievance policy and procedure according to IFC PS2 and ensure implementation at the plant- level.	03/31/2016
As part of the deployment of the global HR policy, develop and disseminate a corporate worker grievance policy and procedure according to IFC PS2 and ensure implementation at the plant- level.	06/30/2017
Noble Agri will conduct OHS audits of all its existing and newly acquired assets against local legal requirements and applicable IFC Performance Standards and will prepare a Corrective Action Plan to bring operations into compliance with these requirements. In Brazil, the audit will include specific reference to Brazilian National Standards NR10 and NR13	09/30/2016
Noble Agri will conduct OHS audits of all its existing and newly acquired assets against local legal requirements and applicable IFC Performance Standards and will prepare a Corrective Action Plan to bring operations into compliance with these requirements. In Brazil, the audit will include specific reference to Brazilian National Standards NR10 and NR13	12/31/2016
Noble Agri will evaluate as part of the E&S assessment of existing facilities and future acquisitions the atmospheric emissions, wastewater effluents, and solid waste management practices of agricultural and industrial operations. Noble Agri will ensure that emissions from sources, such as boilers, effluents from oil pressing and sugar processing facilities, and wastes from all facilities are managed according to applicable WBG EHS Guidelines for existing facilities at a minimum complying with local regulatory requirements if it is not technically and/or economically feasible to achieve the IFC Performance Standards and WBG EHS Guidelines.	12/31/2015
Noble Agri will evaluate as part of the E&S assessment of existing facilities and future acquisitions the atmospheric emissions, wastewater effluents, and solid waste management practices of agricultural and industrial operations. Noble Agri will ensure that emissions from sources, such as boilers, effluents from oil pressing and sugar processing facilities, and wastes from all facilities are managed according to applicable WBG EHS Guidelines for existing facilities at a minimum complying with local regulatory requirements if it is not technically and/or economically feasible to achieve the IFC Performance Standards and WBG EHS Guidelines.	12/31/2015
Noble Agri will review its list of pesticides and will phase out all products that follow under WHO Class 1a and 1b, over time.	04/30/2016
For all Noble Agri direct agricultural plantations and direct production, in order to improve oversight of these operations and minimize risk, the Company will develop a procedure, in accordance with FAO Guidelines (“Good Practices for Aerial Application of Pesticides”), to avoid the risks and impacts to health and other crops associated with aerial spraying of chemicals, which entails in weather conditions monitoring during aerial spraying, previous communications with neighbors and safety exclusion buffer zones from towns, small villages or households	03/31/2016
As part of the development of its Corporate EHSS Management System, the Company will develop and implement policies and procedures to manage any owned plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the Company’s owned sugar plantations will be managed as defined in Bonsucro Standard of production and/or in a credible certification system as defined in IFC Performance Standard 6. For its South Africa farming operations, agricultural production will be managed as defined by a credible and relevant standard as defined in IFC PS6 and as demonstrated by independent verification and certification.	12/31/2016
As part of the development of its Corporate EHSS Management System, the Company will develop and implement policies and procedures to manage any owned plantations in a sustainable manner following agribusiness/food industry good management practices. In Brazil, the Company’s owned sugar plantations will be managed as defined in Bonsucro Standard of production and/or in a credible certification system as defined in IFC Performance Standard 6. For its South Africa farming operations, agricultural production will be managed as defined by a credible and relevant standard as defined in IFC PS6 and as demonstrated by independent verification and certification.	12/31/2017