PS5, Land Acquisition and Involuntary Resettlement, PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable to this investment. The nature of the project is to provide working capital for existing operations. Astarta’s operations are situated in in industrial zoned areas and on existing farming land; there is no land use conversion or use of natural or critical habitats anticipated.  There are no indigenous peoples or cultural artifacts in the project area. 

 The project is categorized as a category B project according to IFC’s Policy on Environmental and Social Sustainability as the IFC’s review of project activities indicates that the associated E&S risks and impacts are few in number, generally site-specific and readily addressable through mitigation measures.

Key environmental and social (E&S) issues associated with this project include: efficient implementation and maintenance of environmental health and safety (EHS) management systems; assurance of safe and healthy labor and working conditions in compliance with local regulatory requirements and Performance Standards; implementation of good and safe agricultural practices ; further implementation of modernization and the use of best available technology (BAT) to reduce water, electricity and natural gas consumption; and  improvement of wastewater management and minimization of hazardous materials use. 

 Policy 

Astarta developed and has implemented an overarching policy defining the environmental and social objectives and principles that guide the company to achieve sound environmental and social performance. Astarta management approved and the company communicated its policy to all levels of its organization and publicly disclosed it on the company’s web portal:  http://www.astartakiev.com/en/about/zahist-dovkillja.htm . Astarta also operates according to a policy committing to the voluntary agro-commodity initiative on responsible soy production the Roundtable on Responsible Soy (RTRS).

Management Programs 

Astarta established and successfully maintained EHS management system and programs adequate to the nature and scale of the company operations.  Management programs have been implemented across Astarta’s facilities and activities, including for its contractors and primary suppliers.  

The company has developed and implemented its EHS management system in line with international standards ISO 14001 (environment), OHSAS 18001 (occupational, health and safety), FSSC and ISO 22000 (food safety), and IFC performance standards requirements.  Currently Astarta’s facilities hold different variation of certificates in accordance with international standards.  Moreover, Astarta was the first company in Ukraine certified to ISO 50001 for energy management. 

Other Astarta facilities, even though they are not certified follow corporate principles and have implemented EHS management system procedures and work instructions.  Astarta’s management system is consistent with IFC PS requirements in providing adequate oversight, comprehensive risk assessment, monitoring, reporting and staff training. 

Organizational Capacity and Competency:
 
 EHS responsibilities and accountabilities are defined and communicated throughout headquarters, core business functions and individual facilities through detailed procedures and work instructions. An overall responsibility for EHS matters is assigned to a professional manager at the corporate level who monitors, and controls the implementation and effectiveness of the EHS management system. This individual report directly to Astarta senior management responsible for the review and determination of further actions for improvement, as applicable. Astarta’s EHS department has 54 EHS specialists with direct responsibilities for the environmental and social performance of individual facilities to which they are assigned.  
 
 Emergency Preparedness and Response
 
 Emergency preparedness and response plans are prepared, implemented and maintained at each Astarta facility in line with local laws and requirements under this PS. All facilities are equipped with life and fire safety (L&FS) equipment commensurate with types of L&FS risks and hazards. Electrical grounding, filtration and venting and low explosive detection systems are installed at areas of sugar and other dust generation to reduce explosion hazards. Equipment includes fire extinguishers and detached fire water tanks and hydrants and hose-reels. Emergency response drills are carried out by the state fire service jointly with the company staff semiannually and follow up action implemented if necessary. 

Monitoring and reporting:

Astarta established procedures to monitor the effectiveness of its EHS management system and programs in compliance with local legal requirements and its contractual obligations. 

Astarta and its facilities submit annual reports on air emissions, wastewater treatment results, and the amount of generated wastes to authorities that supervise compliance with Ukrainian limits. In addition, Astarta reports to IFC using the annual monitoring report which includes reference to WBG’s EHS Guidelines limits. Internal reporting about EHS issues is provided to company management within the framework of EHS management systems implementation. 

Astarta regularly assesses its compliance with social and environmental standards and requirements of its corporate clients (e.g., Coca-Cola, Nestle, Mondelez). Compliance with IFC Performance standards and integration of specific requirements into company management systems is reviewed annually and evaluated by independent experts who are engaged on behalf of international lenders. Astarta senior management receives semiannual performance reviews of the effectiveness of EHS and other management systems and take necessary steps to ensure that the main objectives of its EHS policy are met. 

 Human Resources Policy, Social Responsibility, Non-Discrimination and Equal Opportunity
 
 The company’s human resource policy is consistent with local labor laws and PS2 requirements.  Core non-discrimination and equal opportunity principles in hiring, employment, and promotion is merit-based.  Astarta follows social responsibility principles, being a member of United Nations Global Compact (UNGP) since 2008, and is committed to aligning its operations and strategies with principles of human rights, labor, environment and anti-corruption. The HR policy and associated documentation specify the terms of employment and working conditions and include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and dismissal, vacation, other leave, and retirement. 

Working conditions and terms of employment
 
 As of 31 December 2017, the company employed 13,967 workers, 33% female and 67% male. Astarta keeps written contracts with permanent and seasonal staff. Astarta employed 611 workers with disabilities, which is about 4% of the total number or staff. Employee contracts incorporate comprehensive terms of employment, including hours of work, wages and benefits, leave for illness, maternity, vacation or holiday, employees’ rights for labor protection, including right and freedom to associate with professional organizations, and trade unions. Astarta offers a social package to employees, including financial aid and social benefits. 
 
 Working conditions at Astarta’s facilities are aligned with national labor laws and IFC’s PS2. Ukrainian legislation prohibits employment of children below the age of 16 years; those below 18 years are not employed in dangerous, night or overtime work; forced labor is not permitted. 
 
 Workers’ Organizations
 
 About 80% of Astarta employees are members of trade unions. Workers’ councils cooperate with management within individual operations where employees don’t belong to a trade union. Collective agreements provide for additional terms and benefits for employees and their families.
 
 Grievance Mechanism
 
 Astarta has developed and implemented a formal, internal grievance process consistent with IFC’s PS2 that allows grievances to be presented without the risk of reprisal. All employees are informed about the grievance procedure upon employment. Additionally, the corporate code of conduct actively encourages employees and managers to openly discuss and resolve internal concerns. The grievance mechanism is designed also to ensure that anonymous complains can be submitted and resolved. The response to anonymous complains is posted at locations that can be seen by company workers. 
 
 Occupational health and safety
 
 As part of its EHS management system Astarta takes actions to ensure safe and healthy labor conditions in accordance with applicable national legislation and IFC requirements. The EHS management system is supported by corporate standards, a package of organizational and technical safety measures embedded into the technical design of facilities as well as rules, instructions, and operational procedures. 

The company provides regular assessment of hazardous factors at working places (e.g. chemical, physical, ergonomic.) and implements measures to improve working conditions. Occupational health and safety (OHS) procedures are developed for each type of operation and employees are trained in application of these measures.  

Work clothes and personal protective equipment are provided to employees in accordance with the type of work performed. The company carries out medical examination of employees at the time of employment and after that repeats health examinations on a regular basis scheduled according to specific working conditions.  

Astarta’s Lost Time Injury Frequency Rate (LTIFR) was reduced 37% compared with 2015 LTIFR statistic and is below internationally recognized benchmarks for the sector.  In compliance with the requirements of previous investments, Astarta enhanced its management of risks associated with pesticide and fertilizer handling through development of pest management procedures, training employees to safely use pesticides using the information contained within MSDS (material safety data sheet) and/or ICSCs (international chemical safety cards). Staff involved in operations with specific pesticides undergo regular medical examination and their rotation is enforced to avoid chronic exposures.

Astarta developed and started with the implementation of the Five Steps to Safety program to improve OHS practices and performance in 2017. The program expected outcomes will be supplementary reduction of the number of work-related injuries, and to increase the level of personal responsibility of employees and managers. As part of the program in 2017, more than 60 OHS internal and external audits have been performed and related corrective actions defined, and 350 chief engineers, managers, and EHS specialist were trained on the different aspects of the OHS management. Astarta will report the outcomes of the program through its Annual Monitoring Report (AMR) to IFC. 

 Resource Efficiency

Astarta enhanced the programs, which were launched on the basis of ESAP tasks for the previous projects, namely energy efficiency, hazardous materials management, replacement of R22 Freon refrigerant, asbestos containing materials replacement; impact assessment on flora and fauna with identified risks ranked from low to medium; and wastewater treatment improvement programs in the Globino cluster.

Astarta completed the first phase of a modernization and best available technology (BAT) program aimed at reducing natural gas and electrical energy consumption in the period 2013 - 2016. Astarta’s 2016 sustainability report publicly disclosed that the company reduced natural gas consumption from 30.1 m ³  per ton of sugar beet in 2012 to 25.1 m ³  per ton of sugar beet in 2016 representing a 16% reduction. 

Water is supplied from surface water bodies or ground water wells in accordance with permits. Drinking and processing water quality complies with local and the WBG/IFC thresholds and is confirmed through periodic sample collection and analyses.   Astarta continued improvement on reduction of water consumption. In 2016, implementation of the BAT program first phase resulted in water reduction of 20%, and the amount of wastewater pumped to filtration fields reduced by 29 %.  However, still the current average water consumption of the nine sugar plants in 2016 was above the industry benchmarks. 

In accordance with Astarta’s BAT program 2018 - 2019, Astarta will implement supplemental modernization and resource efficiency measures in sugar plants with the objective to further reduce natural gas consumption by approximately 3% and electricity consumption by approximately 1 kWh per ton of processed sugar beet. As part of this BAT program Astarta will also implement technically and economically feasible water conservation measures with the objective to reduce water consumption by approximately 40% per ton of processed sugar beet as defined by ESAP item 2.  

Greenhouse gases

Astarta direct greenhouse emissions are principally from the physical boundaries of company’s facilities from combustion of natural gas, diesel and coal in Narkevitchy and  Savinskyi  sugar plants. Indirect greenhouse emissions are associated with electricity consumption of the company. Astarta’s greenhouse emissions in 2016 were 476,000 tonnes of carbon dioxide. Going forward as part of the annual monitoring report Astarta will annually quantify direct emission of the facilities owned and controlled by Astarta and indirect greenhouse emissions associated with off -site production of electricity used by the company in accordance with internationally recognized methodologies and good practice.  

Pollution Prevention

Air Emissions
 
 Impacts of air emissions from sugar production are mitigated by capturing dust in the aspiration system and cyclones. Solvent vapors from the oil extraction process are absorbed in a mineral oil scrubber, condensed and returned to the process. According to monitoring data provided air emissions from production facilities are compliant with national and WBG EHS Guideline parameter limits. 

Astarta’s two sugar plants Narkevitchy and  Savinskyi  started with use of coal for energy and steam production in 2017.  Thus, the company will perform one year monitoring program to monitor sulfur dioxide (SO ₂ ), nitrogen oxides (NO _X ), particulate matter (PM), and carbon monoxide (CO); and, propose mitigation measures if needed as per ESAP action 2. 
 
 Wastewater Treatment
 
 Liquid effluents with high concentrations of organics from agricultural operations are collected in closed drainage systems and discharged to anaerobic lagoons and not discharged to

any receiving waters. The solid residue is temporary stockpiled on the special on-site concrete-enveloped area and then is used as organic fertilizer depending on seasonal conditions. Liquid residue from anaerobic lagoons (manure) spreading is carried out when the plants can utilize the fertilizer value, therefore run off risk associated with the animal waste is unlikely.
 
 Astarta developed a program for improvement of the wastewater management of its sugar plants. Liquid effluents currently from sugar plants go through on-site primary treatment facilities and discharge to anaerobic lagoons, without discharge to surface waters. To minimize leakage of wastewater into the groundwater, lagoons are lined with clay. The company conducts wastewater monitoring and monitoring of surface and groundwater water near sugar plants and anaerobic lagoons on a regular basis and their quality is compliant with national limits and the WBG EHS Guidelines. As part of the program for improvement of sugar plant’s wastewater management Astarta started with the construction of the first on-site wastewater treatment plant (WWTP) in Globino, that is a combination of anaerobic and aerobic treatment with a people equivalent (PE) capacity of 200,000 for the treatment of wastewater generated by sugar plant Globino's bioenergetic complex Globino and soybean processing plant.  

 
 Solid and Hazardous Waste Management 
 
 As part of its EHS management programs Astarta developed, implemented and maintained solid waste management program that addresses the cost-effective options for waste avoidance, waste sorting, waste recovery and/or waste disposal. Granulated soya husks are used as animal feed or burned in the boiler of the biogas facility, organic wastes from crop cultivation are used for cattle feeding and by turn cattle manure is used for soil fertilizing and solid domestic wastes is deposed to a closest landfill. 

Hazardous wastes management is also integral part of the Astarta EHS management system. Hazardous wastes such as used luminescent lamps, chemicals from the laboratory, asbestos, outdated pesticides, lubricants from the company’s machinery maintenance and repair facilities, parts cleaning solvents and paints are segregated and removed from the Astarta facilities by specialized licensed contractors for the further processing and disposal. Astarta obtains the chain of custody documentation from contractors for such hazardous wastes in accordance with good industry practice.   

Hazardous Materials Management 
 
 Astarta is in the final phase of implementation of the programs for the gradual replacement of asbestos containing materials (ACMs) and polychlorinated biphenyls (PCBs) and ozone depleting substances (ODSs) at all its facilities. The risks associated with handling of ACMs and its disposal were addressed through an ESAP task developed for the previous IFC project and included: development of safety procedures and training programs for personnel handling ACMs; provision of adequate PPE to employees and ensuring proper

 disposal of removed ACMs.
 
 Pesticide Use and Management
 
 Astarta has integrated pest management program (IPM) developed as a part of the ESAP for the previous project.   The IPM program includes crop management practices, insect and disease monitoring, pest and disease ecology, biological control, and other control components. The special scientific unit is responsible for IPM implementation and ongoing investigation of efficient measures for pest control, such as selection of pest resistant seeds, combination of agro-technical methods (crop rotation, soil pest control, etc.), as well as alternatives to pesticides use such as introduction of less toxic and more effective crop protection chemicals. 

 Astarta follows its Policy statement committing to not using WHO Class Ia/Ib chemical formulations. Norms for pesticides application, routine monitoring and agro commodities quality control is conducted regularly by Astarta’s specialized laboratories.

The specific community health and safety issues associated with dairy farming include the potential spread of animal diseases and food safety issues. As part of the EHS management system, Astarta developed, implemented and maintained adequate diseases-prevention procedures and protocols. Astarta established a procedure for the constant monitoring and quality improvements of milk. As a part of the IFC’s previous project, the company performed monitoring of drug and pesticide residues in milk to assess their compliance to maximum residue limits (MRLs) for veterinary drugs and pesticides recommended by the World Health Organization (WHO) and Food and Agriculture Organization of the United Nations (FAO). The results obtained were compliant with internationally recognized MRLs. Further, in 2017 Astarta initiated the food safety process of Hazard Analysis and Critical Control Point (HACCP) principles as the foundation for food safety program of its dairy farms.   

The risks to community health and safety associated with sugar production are addressed by integration of food safety practices and principles into management system that is maintained by Astarta in accordance with the international standard FSSC ISO 22000 (food safety) for four of its seven plants, the remaining three are certified in accordance with the national food safety standard 4161-2003. 

 The specific community health and safety issues associated with crop production include among others a potential exposure to pesticides and increased risk of vehicle or machinery injuries on roads and access routes around communities. As mentioned earlier, Astarta has an integrated pest management program (IPM) with adequate procedures for use of pesticides into EHS management system. Regarding transport management Astarta has introduced the transport management practices and procedures across all aspects of its operations and performs regular maintenance of vehicle and machinery to minimize potentially serious accidents caused by its malfunction.         

Security Personnel
 
 Astarta assessed the risk involved in their operations including potential negative impact to workers and the surrounding communities and based on that activity, a security management plan was developed. Security for Astarta’s offices and facilities is provided by a private security agency. The subcontractor is licensed and has staff trained according to the relevant national legal requirements. Security personnel are not armed. The grievance mechanism Astarta established did not capture any complaint from workers or potentially affected parties associated with the use of security personal in the last five years. Furthermore, security personnel are trained to act in emergency situations and in providing the medical first aid.  

•  Astarta confirmed its commitment to voluntary international initiative for Round Table on Responsible Soy (RTRS) aiming to sustainable use of natural resources for soybean growing and implemented a plan for gradual implementation of RTRS principles including measures for cultivation on areas, which are not native forest, conservation of high conservation value areas, maintaining of responsible labor and environmental conditions, community relations.
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• Good agricultural practices are employed for annual crops, sugar beet and soy growing including soil conservation practices, termination of the use of chemical pesticides belonging to WHO 1a/1b hazardous classes. Astarta’s laboratory conducts regular soil analyses and develops agronomical recommendations based on Integrated Crop Management. 

 Communications with stakeholders are covered by the corporate standard “Management of external relation of Astarta” which includes identification of stakeholders and various ways of communications, handling and response to enquiries in line with PS1. 

Consultations and meetings with local authorities and small land owners to introduce Astarta plans and discuss land owner concerns are arranged by the company’s representatives. The company maintains this approach in the areas of its operations through regular community consultations and meetings. Disclosure of E&S information about new projects and developments is carried out by the company through publications in local newspapers and public consultations and as a part of the EIA process. The company discloses general information on business activities, E&S performance and plans through its web sites:  http://www.astartakiev.com/en/slaider-na-glavnoi/vysokaja-socialnaja-otvetstvennost.htm

In addition, Astarta started implementing the reporting principles of the Global Reporting Initiative (GRI G4). This reporting system help stakeholders better understand the activities of ASTARTA and monitor such spheres as the functioning of resource consumption, spending on environmental and social needs, charitable projects. The report of the progress of 2016 is available at its web site:  http://www.astartakiev.com/modules/pages/files/Astarta_zvit_web_engl.pdf  .

Grievance mechanism for affected communities and external stakeholders is represented by the following tools: boxes for proposals, hot line complaint receipt system and a feedback option on the corporate website. 

Astarta’s grievance mechanism is a part of the corporate standard “Management of external relations”. The standard covers the following procedures: stakeholder engagement, the order of reporting and informing, state inspections and audits, relations with the community, grievances redress, propositions and requests. Based upon information provided by Astarta, no grievances regarding EHS issues were obtained during 2016.   

 Contact Person: Vorontsova Alina

Company Name: LLC firm “Astarta-Kyiv”

Address: 38/44 Pochaynynska str. 04070 Kyiv, Ukraine

Email:  alina.vorontsova@astarta.ua

Phone: +38 050 352-60-26