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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The company targets acquisitions of strategically located businesses with existing local or international facilities, typically located within commercial/industrialized areas; similarly, all current facilities are based in commercial/industrial zones. As such, PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Natural Resource Management; PS7: Indigenous Peoples; and PS8: Cultural Heritage are not considered applicable to the project. In going forward and prior to any future acquisitions by the company whether they are a majority shareholder or not, an environmental and social due diligence (ESDD) will be conducted to ensure that all social and environmental risks and impacts are adequately identified and managed in a manner compliant with local regulations, and consistent with all IFC’s Performance Standards.
.

The project is a “category B” project according to IFC’s Policy on Environmental and Social Sustainability because potential adverse environmental and social risks are limited, reversible and may be readily mitigated, through the implementation of the ESAP.

The key environmental, health and safety issues associated with this project include: i) adequacy of the company’s environmental and social assessment and management systems (ESMS); ii) labor relations, human resources policy and practices (particularly relevant for acquisitions beyond South Africa); iii) employee occupational health and safety, including training; iv) life and fire safety, including adequacy of emergency preparedness and response programs; v) energy, water, waste-water, and waste management; vi) product safety; and vii) stakeholder engagement.

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.

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts

Policies and practices for the regulation of Pharmaceuticals and Pesticides: Ascendis’s South African operations are subject to the statutory requirements of the South African Government. The registration, importation, manufacture and distribution of pharmaceuticals requires strict compliance to the Medicines and Related Substances Act (MRSA), 101 of 1965, and associated General Regulations (2013), for which a Medical Controls Council (MCC) Good Manufacturing Principles (GMP) license is issued. The MRSA regulations prescribe how pharmaceuticals must be registered, repackaged, monitored, stored, destroyed, labelled, advertised, and dispensed. All medicines for human use are subject to this law, including complementary and biological medicines. The company is MCC - GMP accredited which indicates that a recognized Quality Management System is in place, manufacturing processes are clearly defined and controlled, and all critical processes are validated to ensure consistency and compliance with the MRSA specifications and in accordance with the GMP Guidelines specified by the MCC (other countries have different administrative organizations that have their own GMP guidelines). The South African GMP Guidelines are based upon the WHO version of GMP, and this is enforced by the national Department of Health. Inspections are performed at each manufacturing site by inspectors appointed by the Department of Health every 2-3 years in order to ensure compliance with GMP as well as compliance with each registration dossier.

Access to, and the formulation of, pesticides is regulated by the Department of Agriculture, Forestry and Fisheries (DAFF) under the Pesticide Management Policy (2010) and the Fertilizers, Farm Feeds, Agricultural Remedies and Stock Remedies Act (1947), in partnership with other government departments that administer the MRSA, Hazardous Substances Act (1973); the Foodstuffs, Cosmetics and Disinfectants Act (1972); and the Occupational Health and Safety Act No. 85 of 1993. DAFF frequently conducts unannounced/random inspections of both manufacturing facilities and distribution points.

The manufacturing operations of Farmalider (and the companies proposed for acquisition, Scitec and Remedica) are governed by the applicable EU legislation and the company is compliant in this regard. Taking this in account, for the purposes of this document the following sections largely provide insight into Ascendis’s South African operations. The gaps identified in each section and subsequent ESAP items, will however apply to all the company operations, as well as any future developments/acquisitions.

Environmental, Health and Safety Policy: Ascendis has an Occupational Health and Safety (OHS) Policy and an OHS management system in place at operations in South Africa, which includes the Group ‘Health & Safety Key Items’, and an OHS Manual which contains the Safety Standards
. It is the responsibility of Human Resources to maintain the policy document and other Group-level OHS control arrangements. The Chief Executive Officer (CEO) is the Board member with specific responsibility for OHS. All manufacturing or repackaging sites of the company have an identified Health & Safety Coordinator, whose job function includes the coordination of health and safety control arrangements at that location. There is no specific reference to environmental responsibility in the policy, thus Ascendis will develop an overarching corporate policy that defines its Environmental, Health and Safety (EHS) objectives and principles and will apply this to guide the activities of all operations from an EHS perspective (ESAP #1).

Identification of Risks and Impacts: As mentioned, the Group applies the Good Manufacturing Practice (GMP) approach to its operations within the relevant statutory framework, and these are audited annually by SGS. The GMP is a quality management system which is designed to ensure the efficient and effective production of products, but does not include the identification of environmental risks / impacts and monitoring parameters beyond good house-keeping. Since the company growth is predominantly via acquisitions, the company will develop and implement an Environmental and Social Due Diligence (E&SDD) process that is applied prior to acquisitions or establishment of any new business, to identify the E&S risks while taking local legislation and the Performance Standards into account. Thereafter, the company will define measures directed at addressing E&S risks and material gaps against a time based plan. These actions are defined in the attached ESAP (ESAP #2).

E&S Management Programs: During the site visits of the South African operations it was clear that facilities were well managed with strict GMP administrative procedures that currently meet local legislative requirements. However, no formal environmental management system is in place, although some basic environmental monitoring is undertaken (as described in PS:3). Environmental issues are predominantly dealt with on a site-specific basis, and not via a conventional (corporate-wide) environmental management system. For example, the sports nutrition factory is in the final stages of implementing a HACCP (Hazard Analysis & Critical Control Points) system, which identifies food safety risks, prevent food safety hazards and addresses legal compliance, and which requires regular environmental monitoring. In Spain, the activities of Farmalíder are carried out following the European Good Manufacturing Practices, whose compliance is verified periodically by the Spanish Agency for Medicines and Medicinal Devices. The company has also implemented an environmental, health and safety system which is regularly updated to ensure that workplace/occupational risks are minimized, and environmental impacts are appropriately managed. Remedica’s four production facilities are EU c
ertified, and approved by the health authorities of the U.K., Germany, Denmark and Australia, among others, who have confirmed that the company’s Quality System meets the requirements of Good Manufacturing Practice. The entire Quality Control System is regularly audited by Quality Assurance to ensure that it continuously meets the increasing demands of the various regulatory agencies that randomly inspect Remedica’s premises.

Scitec has 700 product formulations registered with the European Food Safety Authority (EFSA),is certified by GMP, HACCP and EUROCERT ISO 9001 & 22000, and the facilities are registered with the Food and Drug Administration to allow trading into the US market. An in-house Quality Control Team monitors the quality of all products from raw materials to finished goods, with multiple QA/QC tests throughout the entire manufacturing process. Every product is engraved with a Unique Product Tracking Code (UPTC) for traceability from the plant to consumer.

Rapid expansion of the company and an increase in product diversity has introduced some complexity over time, and this is likely to continue; thus, it has been agreed that the company will develop a corporate approach to E&S management to ensure a consistent approach to this aspect within all activities across the Group. The approach will be to consolidate and enhance all existing policies and practices into an integrated environmental, social, and occupational, health and safety (OHS) system with mitigation measures, monitoring parameters and implementation responsibilities. A risk assessment process which includes the identification of environmental, labor, occupational health and safety (OH&S) and community-related risks and impacts, will form a core basis of the ESMS. Risks and impacts may be identified from regulations, permit conditions, review against the World Bank Group (EHS) Guidelines, and recognized international industry codes of conduct, such as the Food and Agriculture Organization of the United Nations (FAO) Code of Conduct on the storage and distribution of Pesticides, as well as the Global Manufacturing Practices under the Medicine Control Council of South Africa. Monitoring parameters and thresholds will be consistent with those referenced by national requirements and the World Bank Group’s General EHS and sector-specific Guidelines. Overall, the resulting E&S management system (ESMS) will be aligned with the requirements of Performance Standard 1 and other recognized international standards such as ISO 14001 and OHSAS 18001. Thereafter, this will become the corporate standard to be employed consistently across all Group operations, as well as all future businesses as articulated in ESAP #3. Ascendis will undertake annual EHS assurance audits against the EHS Policy to confirm the adequacy of the ESMS for all operations, and based on the findings, will address gaps/deficiencies.



Supply Chain: Ascendis is highly diversified and receives products from di
fferent countries. As part of the overall ESMS, Ascendis will develop a specific management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct which will be mainstreamed into contractual agreements with major suppliers, and reviewed over time as needed. The focus of the Supplier’s Code of Conduct will be on fair labor practice, environmental management and product quality (ESAP #4).



Organizational Capacity: Ascendis has a very strong management team with significant experience in the manufacturing and distribution of various consumer products. Ascendis does, not however have dedicated corporate Environmental, Health and Safety (EHS) capacity, although each site has a Health and Safety (H&S) officer that reports to the General Manager. Thus, the company commits to appoint an appropriately qualified person who will oversee the corporate development and implementation of the EHS Policy and integrated Environmental and Social Management System (ESMS) across the Group and for each new acquisition / development. In addition, the job description for the site level H&S officers will be enhanced to define specific Environmental and Social (E&S) roles and responsibilities. The individual responsible at the corporate level for EHS will also coordinate reporting on such efforts to the Board, compile the EHS input into the Annual Report as well as ensure implementation of the conditions of the ESAP (ESAP #5).



Monitoring and Review / Reporting: As mentioned, each site operated by Ascendis has an H&S officer who ensures compliance to local regulations and currently reports any incidents of non-compliance to the relevant General Manager. As per the ESMS, in future specific EHS key performance indicators will be monitored and reported upon, as follows: compliance with legal and regulatory requirements, including the ESMS progress and certification where applicable, energy and water consumption and efficiency; GHG emissions; solid and hazardous waste management and disposal, effluent discharges, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, supplier performance and community engagement activities, ESAP #6. Implementation will be supported by the provision of resources (qualified and competent staff, capital and operating budgets), be integrated throughout operations, and include training, to accomplish the program and its requirements, as well as measures related to the evaluation and monitoring of priority risks and impacts, and furthermore be extended to include contractors working on projects. During construction/renovation of projects, contractors will be required to provide regular EHS monitoring reports to the proposed EHS Manager, who will ensure adherence to local regulations and the policies of the company.



For the South African operations a Group Health and Safety Committee has recently been const
ituted which meets quarterly at the Head Office in Johannesburg. (comprised of H&S representatives, 4 fire marshals, first aiders level 1-3, facilities manager, 1 employee elected representative, i.e. 11 people, and there are subsidiary level committees in accordance with the South Africa Occupational Health and Safety Act). The Terms of Reference of this Committee will be expanded to include environmental aspects, and monitoring data on EHS will be reported to the Committee. Currently any material non-compliances, serious social or environmental incidents and/or accidents that may impact upon the businesses’ reputation or productivity are reported to the Board Social and Ethics Committee, and this will remain the approach in future.



Emergency Preparedness and Response: The South African operations of Ascendis have basic procedures in place for fire prevention, but no emergency response and evacuation policies or procedures for unforeseen events such as armed robberies, social unrest etc. The company will therefore implement a comprehensive Life and Fire Safety and Emergency Preparedness Policy and Plan for their premises, in cooperation with stakeholders on neighboring sites, and ensure training for all employees and security personnel in both emergency and LFS procedures (ESAP #7). As an integral part of the ESDD associated with each new acquisition (ESAP#2), the company will perform a review of the Life and Fire status of all facilities of the target business. The ESDD process will attempt to assess the level of compliance by the target business with local building fire, and legal/insurance requirements, as well as with internationally recognized LFS standards. Depending on the findings, Ascendis may draw up an LFS plan to implement relevant corrective measures on the facilities. In addition, greenfield projects shall comply with the WBG LFS requirements articulated in section 3.3 of the General EHS Guidelines.

Human Resources management: Ascendis currently employs approximately 1530 permanent staff members and 170 temporary/contract staff, with a total management team of 45 people, across the various brands. The company has an Employee Policy file which is available to each employee during induction. Should there be new policies or an update to a policy, employees are informed via a centralized newsletter which is emailed to all staff. In rare circumstances where an employee does not have access to email (e.g. warehouse staff), the relevant HR manager will ensure a hard copy of the notice or policy is given to those employees. The company is in the process of implementing an HR system where each employee will have access to their own profile, to verify that they have received, read and understood the policies.



Ascendis takes into account all South African legal requirements concerning working hours, minimum wages, overtime compensation, benefits, sick leave etc via comprehensive policies. The use of child labor is not tolerated. Similarly, Ascendis does not engage in or support the use of forced labor. Ascendis is supportive of employees’ choice to belong to a union or associating freely with any lawful worker’s association or collective bargaining association of their choice, although employees have opted not to belong to any major union, and therefore below the threshold to have a collective bargaining agreement. Ascendis does not discriminate on the base of sex, race, religion or culture. Finally, Ascendis does not tolerate any form of harassment, nor corruption including extortion, fraud or bribery. An Ethics Hotline is in place that can be used to anonymously report unethical practices, and a formal documented grievance mechanism is in place for all employees and contractors. South African labor standards are strictly applied, enforced and reported (to the Department of Labor) and alignment with these standards ensure compliance with PS2. The company will apply the same principles and standards to future developments and notably in other jurisdictions where such rigor is not required (ESAP #8). In so far as Farmalider is concerned, and the proposed two new acquisitions, the company will ensure compliance with all relevant national and EU labor requirements and in doing so ensure alignment with PS2 requirements.



Occupational Health and Safety (OHS): There is significant emphasis on OHS in the Group. The HR Manager ensures adherence to the Group’s Health and Safety (H&S) policies across all divisions, which includes all aspects of OHS. As described in PS1, each facility has an appointed Health and Safety committee to ensure all the policies and procedures are implemented and enforced, and Health and Safety issues are overseen from the Ascendis Head Office H&S Committee to ensure compliance. All members of the Health and Safety committees are sent on training so that they are aware of their roles and responsibilities. Farmalider complies in
this respect with all national / EU labor and OHS regulations, and this similarly applies to the two new acquisitions.



Every employee across the Group has access to and a basic understanding of the OHS policy document and documented responsibilities for H&S at work. Effectively establishing and maintaining day-to-day health and safety is a line management responsibility. H&S risk assessments and fire risk assessments are undertaken and updated annually. Employees are provided with H&S information, instruction and training on: provision and use of necessary personal protective equipment (PPE); documented procedures / safe systems of work; arrangements for emergency response/evacuation, first aid and occupational health; consultation on H&S issues; monitoring, investigation and reporting of any incidents, accidents or occupational ill-health; and corrective and preventative actions where any incidents, accidents or occupational ill-health occur. The Group conducts regular internal and external H&S audits to comply with the policy and the statutory requirements. Incidence registers are maintained (only 3 lost time incidents were recorded in the past financial year) and all incidents are investigated. The HR department are in the process of implementing H&S Toolbox talks.



No medical facility is available at any of the South African facilities, but an arrangement has been made with a medical group, Netcare 911 (through the company Benefits Scheme which is available to all employees), where they assist with all medical emergencies. First Aiders are capable of stabilizing any injured employee until Netcare assistance arrives.



It is envisaged that within a period of two years, any newly acquired company under management control will implement the corporate E&S management system, which will include OHS, LFS, emergency preparedness, and risk management (to comply with section 3.2-3.7 of the General EHS Guidelines).



Contractor management: Ascendis has Service Level Agreements (SLA) in place with contracted or outsourced parties. Prior to the SLA being signed, a review is undertaken to ensure compliance to the labor law, minimum wages, obtain declarations etc. All contract staff are included in the H&S induction, with training on PPE, and security procedures, access control, appropriate behavior and emergency procedures. Contract staff also belong to the Netcare 911 program.



Once the corporate ESMS is in place, Ascendis’s service level agreements (SLAs) will be amended to include actions and measures necessary for them to perform their services in a manner consistent with the Group’s ESMS, policies and programs. Likewise, bidding documents for any future construction will include a mandatory section in the contract committing to the Group’s HSE requirements. The same principles will be followed by acquired businesses, subject to local conditions.



Medical surveillance: Employees in all the manufacturing divisions are tested bi-annually, as
per regulations. The tests conducted are for hearing (noise impact) and eyesight; blood glucose levels (diabetes); and TB or exposure to dust (X-rays of the chest and lung function test). Employees that are involved in the formulations plant, loading bay, storage, warehousing and cleaning services of the pesticide manufacturing factory are also tested monthly for acetyl choline esterase (AChE) levels (these are compared with baseline levels taken on the date of employment). All employees have the opportunity to participate in events such as Discovery Health (Medical) days where an additional series of tests can be performed (by consent) and referred to specialists, should this be required.



HIV/Aids program: The Group has an HIV/Aids policy, which is included in the induction of new employees. Ascendis Health provides employees with up-to-date training regarding certain life threatening diseases (i.e. HIV and AIDS, TB, etc) to reduce the potential risk for employees to contract the disease. It is also aimed at reducing and removing discrimination against employees suffering from a life threatening disease, and to ensure strict confidentiality of all employees’ medical information.

Product safety : Pesticides are imported and prepared (diluted, repackaged and branded) by a subsidiary of Ascendis (Avima), whose products (pesticides) are registered with the DAFF, formulated according to the World Health Organization’s (WHO) specifications, and are compliant with the FAO Code of Conduct on the storage and distribution of Pesticides. The factory follows Standard Operating Procedures (SOPs) for Production Planning, Purchasing and Manufacturing; Contamination Prevention and Quality Assurance in the Warehouse; Waste Management and Record Keeping.



The company currently trades in several WHO Class Ia,1b and Class II pesticides. In order to align with IFC’s requirements, Ascendis has agreed to institute and communicate internally and externally a policy statement committing the company to eliminate all activities related to the purchase, storage, use, manufacture or trade in WHO Hazard Class Ia or Ib chemical formulations in its operations by December 2021, or as otherwise agreed with IFC. Thereafter, the company will work towards phasing out activities associated with such materials in accordance with agreed milestones, as defined in the ESAP. In addition, the company will review the technical and economic feasibility to replace remaining WHO class II compounds with less hazardous material; considering alternatives such as cultural practices, biological, genetic, and as last resort chemical means (#ESAP 9).



Storage and handling of hazardous substances: In South Africa all substances classified as hazardous are stored in certified hazardous storage facilities, with bunding, fire suppression systems, and Rapid Spill Response kits (as well as contracts with Rapid Spill Response teams). Warehouses are segregated according to their hazard classification (Group I, II or III; pesticide type, flammability physical nature) and category (raw materials, finished ingredients, active ingredients). Guidelines are strictly followed to focus on segregation rules to prevent contamination, while considering safety procedures (e.g. in the case of incompatible products). Access is controlled, and no materials may be accepted or stored without proper identification, classification, marking, labelling or if containing improperly packed or damaged materials. In the event of leakages, leaking products and surrounding/affected products are removed in accordance with an SOP for non-conformance. Employees are trained in Hazmat procedures and specialized PPE use. For all new acquisitions / developments the ESDD (ESAP #2) will review these against the requirement of this Performance Standard and address any gaps via the associated action plan if required. Farmalider’s approach to the management of hazardous substances is equally as per the approach described above and in accordance with EU requirements.



Hazardous waste: Hazardous waste arising from the Pharma or Pesticide (Avima) factories are recorded and stored in bunded areas with access contr
ol. Different types of waste are separated according to their class, i.e. medical/pharma waste, used oil, toxic waste etc. These are collected weekly by government-licensed hazardous waste handlers/transporters and thermally destroyed (incinerated), after which the company issues a certificate of destruction/disposal. All records are kept on the premises for at least three months. The contract with the certified waste company specifies the nature and properties of the waste, emergency procedures, loading procedures etc. All Avima’s empty HDPE or steel drums (pesticide containers) are triple rinsed, and sent to a licenced waste disposal company. Rinsing water and other chemical waste is contained in a waste holding tank and 1000L at a time discharged into an evaporation dam; once evaporated, the dry cake is also collected and disposed by a licensed hazardous waste removal company. The EU regulations relating to hazardous waste disposal are particularly stringent, and have been applied by Farmalider, and are equally applicable to Remedica and Scitec.



Waste water and sewerage: Waste water arising from existing (South African) operations (other than that described below) – from vitamin and sports nutrition manufacturing processes, laundries, showers, basins and other office activities – and sewerage, is currently discharged to the municipal sewer for treatment at municipal waste water treatment sites. Waste water discharge sites and waste areas are periodically monitored by Environmental Health inspectors from the municipality. As part of the ESMS described in PS 1, monitoring of waste water volumes and parameters will be undertaken as per the WBG General EHS Guidelines (sections 1.1-1.3).



Water consumption: Ascendis (South Africa) implements basic water conservation measures through efficient manufacturing processes, to minimize the use of potable municipal water. Consumption is 4,575,000 L a month. The PharmaNatura facility utilizes 3000L/month of borehole water (which was tested at the time of installation) and purifies this via a reverse osmosis plant. The treated water is tested weekly by an external accredited laboratory to ensure compliance with the manufacturing standards.



Waste management: The Divisions each implement a waste management program, depending upon the activity, and waste storage areas are demarcated according to the category. Waste volumes are not monitored at the South African operations. General waste is collected in municipal waste skips and collected weekly by the municipality. Cardboard and paper waste is recycled.



GHG emissions: Security of electricity supply in South Africa has necessitated the installation of 2 diesel generators of 250 KVA capacities. Ascendis monitors its fuel (25,200L consumed per month) and electricity consumption (841,000 KWh per month) which equates to approximately 9,687 tons of CO2e per annum. This is below IFC’s reporting threshold of 25,000t CO2e per annum, and it is unlikely tha
t the company’s planned expansion plans will exceed this threshold.



Energy conservation: Energy use is monitored closely as the Group utilizes machinery for its manufacturing operations; rising costs have been a driver for the implementation of energy efficiency initiatives and alternative energy sources. In South Africa, the Group has recently explored light bulb substitution, solar panels, heat pumps, and various other technologies to save energy, and is in the process of initiating an energy saving program.



For each majority-owned business acquisition, compliance and consumption data will be reported annually as part of the Integrated Annual Report which is published annually on the Group’s website.

Product safety: All pesticide packaging and safety information is regulated via the South African Bureau of Standards SANS 10234 (2008): Globally Harmonized System of classification and labelling of chemicals (GHS), which specifies color coding, specific toxicological information and emergency contact numbers (among other requirements) for the protection of users. Online Material Safety Data Sheets can been downloaded for the pesticide products on the Efekto website. South Africa has one Poisons Information Centre which provides advice on the prevention, diagnosis and management of poisoning in both adults and children, and provides a toll-free line for the public (Poisons Information 24 hour Helpline 0861 555 777). The Center has produced and maintains the database AfriTox® which is available to doctors throughout Southern Africa to manage poisoning cases. It allows fast access to accurate information immediately after poisoning is suspected or confirmed so that a patient can be treated appropriately and effectively.



Pharmaceutical labelling is similarly regulated under the General Regulations in terms of the Medicines and Related Substances Act 101 of 1965, as amended. Complementary medicines are included in the regulations. A complaints procedure is defined and implemented in the Pharm Division, allied to the above regulations, where issues such as an adverse drug reaction, technical or distribution complaint could have severe consequences. An SOP is in place to ensure that these are handled effectively. Ascendis complies with these regulatory provisions.



The Sports nutrition products are classified as foodstuffs, and are regulated by the Foodstuffs, Cosmetics and Disinfectants Act (1972): Regulations relating to the labelling and Advertising of Foods (Amendment: 2015). As the company is in the process of implementing HACCP (ISO 22000) in the new factory, the products are certified as safe.



PS1 confirms that the operations in Spain and Cyprus are subject to, and comply with, GMP as well as the applicable EU legislation and EU standards for manufacturing and product safety.



Emergency Preparedness and Life and Fire Safety (LFS): As indicated in PS1, there is need to enhance / develop an Emergency Preparedness Plans and thus as per ESAP # 7 this will be addressed. Although most of the buildings are leased, they are in compliance with the South African Building Standards and are certified by the Fire Department and Department of Health (LFS compliance is a condition of the lease agreement in all cases). Ascendis has implemented the following for LFS at the various facilities: directional signage to exits; an evacuation plan that has been communicated to employees via a Health and Safety induction session; first aid boxes which are clearly visible in central positions; fire hydrants, fire blankets and fire sirens; first aiders and fire fighters that are trained within the various divisions. An independent company (Trustfire and Secu
rity System) has audited the premises and issued a certificate of compliance in accordance to the applicable regulations with regards to fire equipment in the Health and Safety Act.



Security Personnel: Ascendis employs reputable (registered) third-party companies for security. Personnel are accredited with the appropriate security association, are suitably trained, equipped, and regularly rotated. They are unarmed and follow a Standard Operating Procedure prescribed by the security company with whom they are employed and trained. Additional security measures also include access control gates and booms; electric fences, security lighting; CCTV which is monitored 24/7; emergency lighting; intercoms; and access to armed response in the case of an emergency.



Vehicle/Driver safety: Ascendis owns a small fleet of 15 delivery vehicles (under 8T), and forklifts. All drivers are trained in defensive driving and Hazmat (hazardous substances handling), and accredited before being allowed to operate. This training is refreshed annually. Fleet drivers of registered distributors must have a defensive driver’s license at all times.



Pest management (manufacturing sites): Pest management is outsourced to a reputable pest control company who monitors rodents (using bait) every month. Fumigation for cockroaches, flies, pests is undertaken by Rentokil on a quarterly basis.

Ascendis has identified its significant stakeholders. These differ between the various companies/divisions. Stakeholder Engagement Plans therefore exist within these companies/divisions. There are various platforms through which the public can reach Ascendis, should they have questions or complaints. The most commonly used one is the Group website, where various email addresses are provided for this purpose. The company does not, however, have a specific corporate stakeholder grievance procedure, which will be developed and applied across the Group, as ESAP #10. The company will ensure that for all new acquisitions in other territories, affected local communities are engaged via a communication/stakeholder engagement process and grievance procedure.

Contact Person: Ms Lara Grieve
Company Name: COAST2COAST
Address: 22 Sloane Street, Bryanston, Johannesburg, South Africa.
Email: mailto:Lara@c2c.co.za
Phone: +27 84 645 7206

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop and implement an overarching corporate environmental, health and safety (EHS) policy inclusive of objectives aligned with the requirements of Performance Standard 1, the World Bank Group EHS Guidelines, ISO 14001 and OHSAS 18001.	07/30/2016
Develop and implement an Environmental and Social Due Diligence (ESDD) procedure for application to the acquisition or establishment of any new business prior to the occurrence of such. This procedure is to define the approach to assessing potential impacts and risks against national EHS legislation, the requirements of Performance Standard 1 and the World Bank Group EHS Guidelines (the latter includes the requirements to assessing activities relative to life and fire safety requirements). The outcomes of the ESDD are to be a defined in a time based EHS action plan to ensure acquisitions / new developments align with the criteria against which they are being assessed within a period of 2 years.	12/30/2016
Develop and implement an integrated Environmental and Social Management System (ESMS) at the corporate level that is aligned with the requirements of the Performance Standard 1, the World Bank Group EHS Guidelines, ISO 14001 and OHSAS 18001 and extent this to existing and new developments, and : 1. Apply this ESMS to existing operations.	12/30/2016
Develop and implement an integrated Environmental and Social Management System (ESMS) at the corporate level that is aligned with the requirements of the Performance Standard 1, the World Bank Group EHS Guidelines, ISO 14001 and OHSAS 18001 and extent this to existing and new developments, and : 2. Apply the ESMS to acquisitions / new developments.	07/30/2018
As part of its overall ESMS develop and implement a specific management procedure for its supply chain, which will include the development and implementation of a Supplier’s Code of Conduct (aimed at environmental compliance, labor standards and product safety) which will be mainstreamed into contractual agreements with major suppliers.	12/30/2017
Appoint an appropriately qualified person who will oversee the development of the corporate ESMS as well as implementation thereof at each facility (existing, or to be acquired/developed) and will coordinate reporting on such efforts to the Board, as well as compile the EHS input into the Annual Report.	12/30/2016
Prepare an integrated EHS report format based on critical EHS key performance indicators (e.g., compliance with legal and regulatory requirements, including the ESMS progress and certification where applicable, energy and water consumption and efficiency; GHG emissions; solid and hazardous waste management and disposal, effluent discharges, compliance with national OHS requirements, including accident rates (lost-time accidents); customers and community complaints, supplier performance and community engagement activities) for submission to IFC and the company Board.	12/30/2016
Develop and implement a comprehensive Life and Fire Safety and Emergency Preparedness Policy and Plan to be applied to all premises such that these are aligned with national requirements, and good international industry practice, in cooperation with stakeholders on neighboring sites if applicable, and ensure training for all employees and security personnel in both emergency and LFS procedures.	08/30/2016
Ensure that all acquisitions / new developments comply with the company existing approach to human resources in South Africa.	12/30/2017
Update existing company policy and procedures to meet IFC’s Performance Standard 3’s requirements on the purchase, storage, use, manufacture or trade in WHO Hazard Class I &II products. So as to achieve this the company will: a) Institute and communicate internally and externally a policy statement committing the company to eliminate all activities related to the purchase, storage, use, manufacture or trade in WHO Hazard Class Ia or Ib chemical formulations in its operations by December 2021 or as otherwise agreed with IFC.	07/30/2016
Update existing company policy and procedures to meet IFC’s Performance Standard 3’s requirements on the purchase, storage, use, manufacture or trade in WHO Hazard Class I &II products. So as to achieve this the company will: b) Develop and deliver pesticide impact/usage/disposal training to all manufacturing and distribution staff/outlets. This training shall include the risks associated with WHO Class I & II products and their safe mitigation.	12/30/2016
Update existing company policy and procedures to meet IFC’s Performance Standard 3’s requirements on the purchase, storage, use, manufacture or trade in WHO Hazard Class I &II products. So as to achieve this the company will:c) Implement the Class 1a / 1b phase out plan, leading to the optimal utilization of product with a particular focus on eliminating the use of WHO Class Ia and b products in the distribution operations. This will be based on phases as follows or as otherwise agreed with IFC:	12/30/2021
1) Develop new, less hazardous formulations for 50% of current Class 1a and 1b by reducing concentrations of actives, adding safeners to liquids or using micro-encapsulated actives by December 2019, 2) All trials completed or progressing towards eliminating Class 1 products will be independently audited in December 2019,	12/31/2019
3) Consult a certified toxicologist or conduct toxicological studies to re-assess the hazard classification of all formulations of Class 1a and 1b products to award a less hazardous classifications that are based on internationally accepted scientific principles by December 2020,	12/31/2020
4) Replace all Rotterdam Annex III active ingredients with alternatives to meet the requirements of the Rotterdam Convention by December 2021, and 5) Confirmation that all activities related to the purchase, storage, use, manufacture or trade in WHO Hazard Class Ia or Ib chemical formulations in its operations have been eliminated by December 2021 or as otherwise agreed with IFC	12/31/2021
The company will review the technical and economic feasibility to replace remaining WHO class II compounds with less hazardous material; considering alternatives such as cultural practices, biological, genetic, and as last resort chemical means. The company will consult a certified toxicologist to review the formulation toxicology of Category II formulations and/or conduct studies to verify that such formulations are awarded less hazardous classifications by 2021.	06/30/2018
Develop and implement a formal stakeholder grievance policy and procedure, which will be applied across all divisions, acquired businesses, and contractors working on the premises	09/30/2016