This is a Category B project according to IFC’s 2012 Policy on E&S Sustainability. Key E&S risks associated with the 2nd production line and its wood sourcing operations are limited, site-specific, and can be readily addressed through generally accepted mitigation measures described in this document. The E&S risks and issues are: (i) implementation effectiveness of E&S Management System (ESMS) at existing facility, including the proposed expansion, and at its owned/leased forest plantations; (ii) organizational capacity/competency of EHS/HR/Supply Chain function; (iii) existing HR/OHS policies  and procedures for fair and safe working conditions for direct and seasonal workers, and contractors, including workers’ grievance mechanism; (iv) FSC certification of Sudati’s owned/leased plantations; (v) third-party wood procurement, including traceability and risk screening procedures, and independent annual verification; (vi) stakeholder engagement plan and community grievance mechanism, including risks from transportation activities.                                                 

 Environmental & Social Risk Assessment. Sudati was not required, as per the applicable Brazilian regulations, to prepare an Environmental Impact Assessment (EIA) study for the existing MDF facility in 2009. A simplified E&S assessment (“Estudo Ambiental Simplificado – EAS”) as per the Santa Catarina state’ regulatory requirements was prepared. The latest environmental license, covering the facility, energy substation, transmission line, potable water and wastewater treatment plants was secured in 2019 and is valid until 2023. The license defines specific management plans and programs for wastewater treatment, air emissions, solid waste, among others.

For the proposed expansion, Sudati de­veloped a new EAS which was submitted to the Santa Catarina state Environmental Agency – “Instituto de Meio Ambiente” (IMA) and recently approved (disclosed herewith). The study included a brief description of the proposed project, E&S baseline and Project’s area of influence, assessment of the key E&S risks and impacts, and mitigation measures to be implemented. The study presented the expansion plan, including production flowchart, estimation of atmospheric emissions, effluents, and waste generation. The performance-based requirements of this assessment did not include IFC Performance Standards (PSs) and applicable WBG EHS General and Sector-Specific Guidelines. 

Based on IFC’s review of the EAS, Sudati will be required to amend this study to cover the following issues: (a) community risks (associated with transport of wood products and hazardous waste); (b) final design of air pollution control systems for all the stacks in the new production line and the boilers with their guaranteed emission values, (c) impacts of air emissions on communities and sensitive receptors through quantitative assessment of atmospheric emissions, including dispersion modeling, mitigation measures and monitoring frequency, particularly for those pollutants found in sludge from the evaporator which will be used as fuel for the boiler, (d) assessment of rainwater drainage and earthworks project, including assessment of soil quality and disposal sites (dumping ground); (e) assessment of impacts to natural habitat at the plant’s site (to be conducted by a qualified ecologist, including terrestrial and aquatic ecosystems); and (f) cumulative impact assessment from the proposed expansion, considering the existing facility and the proposed expansion plan and its supply chain (ESAP#1).

E&S Management System. The E&S Management System (ESMS) at the existing MDF facility is under development. Sudati has implemented stand-alone management procedures and plans for E&S aspects of its operations, such as potable water, wastewater, solid waste, quality control of boilers, cooling towers, and chemical handling. Sudati is certified for Quality at its MDF and Medium Density Particle Board (MDP) wood panels facility by the “Programa Brasileiro de Qualidade e Produtividade do Habitat – PBQPH”, issued in August 2022. Going forward, for the construction activities, Sudati will develop specific procedures for overseeing the contractor’s performance in relation to environmental, social, labor and working conditions, and OHS aspects, including contractor selection requirements/qualifications, monitoring procedures, and actions to be taken for non-compliance. (ESAP#2). For operational phase, Sudati will develop and implement a plant-level ESMS for its MDF production plant, including the proposed expansion. The ESMS will incorporate the following elements: (i) E&S policy; (ii) identification of E&S risks and impacts; (iii) E&S management plans/programs at production plant, owned/leased forest plantations, and wood sourcing operations, including (but not limited to): a) solid waste and hazardous materials aligned with Brazilian legal requirements and WBG EHS Guidelines, including storage areas; b) pesticide use and management; c) heavy vehicles transporting wood and hazardous products to the MDF facility; d) Land Acquisition Procedures; (iv) organizational capacity/competency; (v) emergency preparedness and response, including socialization with nearby community; (vi) stakeholder engagement and community grievance mechanism; (vii) Security Management Plan (SMP), including rules of engagement, appropriate conduct toward workers and community, and training requirements; (viii) Supplier Code  covering PS2 and PS6 requirements (ref.  ESAP#9); and, (ix) E&S monitoring and reporting procedures, including Key Performance Indicators (KPIs).

EHS organizational structure and competency. The E&S aspects at the MDF facility are currently managed by the General Manager and supported by an EHS supervisor, responsible for EHS aspects. Two safety technicians, four firefighters and five environmental technicians are also at the facility. Sudati has recently hired a senior forestry expert to design and manage its wood supply and one forestry professional. Going forward, Sudati will strengthen the EHS and wood sourcing unit at its MDF plant, including formalizing E&S roles and responsibilities for the effective development and implementation of the ESMS and the traceability/risk screening system of its owned and leased plantations, and third-party wood suppliers. Sudati will add one EHS officer for managing the forestry/supply chain issues and one E&S professional responsible for the development and implementation of the E&S management system at the production plant (ESAP#3).

EHS Training. Permanent and temporary employees at the MDF facility receive EHS training during induction, which includes incident reporting, emergency response procedures, hazard communication, injury prevention and use of PPE, first aid, fire prevention, chemical handling, and hygiene. In 2022, training on work safety and work permit system (e.g., confined space, work at height, hot work) was provided. As part of the development of its plant-level ESMS, Sudati will implement an E&S training program on updated EHS policies, SOPs Manual, management plans, including worker's grievance mechanisms and emergency response, and KPIs for E&S monitoring and reporting (ref. ESAP#2).

Emergency Preparedness and Response. Sudati has established an emergency preparedness and response (EPR) system for its existing MDF plant to respond to accidents and emergencies, such as fire, explosions, significant OHS events. Sudati is supported by the Santa Catarina fire department. At site, Sudati has fire extinguishers, fire hydrants, emergency lighting system, fire alarm system, and emergency exits and exit signs. Sudati has yet to undertake emergency evacuation drills. Although the MDF facility is within an industrial area and the nearest residential area is at 800 meters distance, Sudati will update its emergency preparedness and response plan to include offsite emergency scenarios, such as hazardous materials spill (i.e., during transportation). Depending on site-specific conditions and emergencies scenarios that could affect nearby communities, the emergency preparedness plan will include procedures for awareness training and drills, in coordination with local government emergency authorities. The EPR Plan will be socialized with the potential affected nearby community. As part of EPR update, Sudati will develop a risk identification matrix for emergency scenarios for the proposed expansion (construction and operation phases), including its owned/leased plantations for risk of forest fires. Its staff/contractors will be trained on the EPR, including bi-annual drills (ref. ESAP#2).

EHS Monitoring and Review. Sudati has environmental monitoring programs for wastewater quality and point source air emissions which are implemented twice a year, as per IMA regulatory requirements. Going forward, Sudati will further strengthen its monitoring procedures and KPIs to measure the implementation effectiveness of the ESMS and associated mitigation measures, including procedures related to energy/water usage and efficiency, GHG emissions and hazardous materials management in line with applicable and relevant sections of the WBG EHS Guidelines.  (ref. ESAP#2)                                                  

 Human Resources Policies and Procedures. HR procedures exist for the selection, recruitment, induction, benefits, overtime, and disciplinary measures of its workforce. Sudati has yet to define an HR policy that set out its approach to managing workers consistent with the Brazilian labor law or IFC PS2 objectives. Sudati will develop HR policies, Manual of Procedures and a Code of Ethics which will outline workers’ rights, including the prohibition of child/forced labor, and develop and implement worker’s grievance mechanism, including formal channels and comprehensive procedures that allow anonymous complaints to be reported, including sexual and labor harassment at the workplace, and required training for staff responsible for their management (ESAP#4).

Working Conditions and Terms of Employment. Sudati’ MDF plant employs 311 individuals (77% male; 23% female). Twenty-five percent of its management positions are female. In addition, 66 employees are hired through third-party companies. Sudati meets local law requirements for working hours - maximum of 8 hours a day and 44 hours a week. The facility operates on three shifts of 8 hours. The HR department has a legal adviser who regularly audits workers' payroll. Workers' benefits are appropriate, with the base salary being 20% above the Brazilian minimum salary. A cafeteria and transport for workers is freely provided. Sudati has a policy for promoting employees through training opportunities, including a leadership training program (“Programa Evoluir”). Managers select participants for leadership training on a performance basis. In the current program, women represent 56% of the participants.

Workers' Organization. Sudati signed collective bargaining agreements (CBAs) with a trade union that represents the workers from the wood sector of nine municipalities of the state of Santa Catarina, including Otacílio Costa. This agreement comprises wage and labor clauses, such as minimum wage, wage adjustment, overtime pay, benefits, layoffs, and unionization. Sudati does not restrict workers’ organizations; however, few staff belong to unions.

Non-discrimination and Equal Opportunity. Sudati applies a practice of non-discrimination and equal opportunity in recruitment; however, they do not have a specific written policy in place to ensure that this is clearly communicated and understood, nor is it specified in the HR staff manual. Interviewed workers confirmed a work environment of diversity and inclusion without cases of sexual harassment. There are no HR policies or procedures (including specific Grievance Mechanism) to manage sexual harassment. As part of the update/strengthening of its HR Management System, Sudati will develop such policy and procedures (ref. ESAP#4).

Workers’ Grievance Mechanism. There is no formal grievance mechanism for workers in place. Complaints and requests from workers are made directly to their supervisors or to the HR function. Some complaints (including anonymous) are made through the cafeteria complaint book and through the boxes intended to collect safety-related occurrence reports. Sudati will enhance its HR procedure for capturing and resolving workers grievances (ref. ESAP#4).

Protecting the Work Force. Sudati indicated that they do not employ child and/or forced labor although no specific HR procedure was identified to track the age of workers other than keeping a copy of the identification document. It runs an apprentice scheme for under 18’s within the scope of a governmental employment promotion program. As mentioned above, a Code of Ethics will be developed, including provisions for prohibiting child and/or forced labor in its direct operations, including contractors, and its third-party suppliers (ref. ESAP#4).

Occupational Health and Safety. Sudati has elements of an OHS management system in place in compliance with Brazilian legal requirements (“Normas Regulamentadoras - NR Ministério do Trabalho e Previdência”), including relevant policies/procedures, safety induction, OHS training programs, toolbox talks for permanent and contract workers, safety infrastructure, internal and external OHS audit, and an incident system that includes accident reporting, investigation, and corrective actions. In compliance with the norms of the Ministry of Labor, Sudati has one EHS supervisor, two safety technicians and four firefighters. In addition, it has an internal accident prevention committee (in Portuguese Comissao Interna de Prevençao de Acidentes - CIPA), made up of workers from different workstations to identify and assess occupational risks. During this field appraisal, deficient OHS practices were observed, including, but not limited to, lack of use of PPE, signage at the facility, lack of safety procedures, and insufficient toilets. Sudati monitors its OHS performance using KPIs (frequency, severity, and time lost). These KPIs should include leading and lagging indicators. Sudati will strengthen its OHS management system, including: i) develop a process to map critical issues, using HAZOP (Hazard and Operability Study) methodology for continuous risk identification assessment; ii) implement corrective action plan, as needed (ESAP#5).

Workers Engaged by Third Parties. Sudati uses third-party contractors for provision of services, e.g., maintenance and production processes and auxiliary sectors (cleaning, cafeteria, and forestry services). At the time of this appraisal, there were 66 workers. The contracts with third parties require compliance with legal labor/OHS requirements. Provisions in contractual agreement allow Sudati to (i) request the necessary documentation to carry out labor audits; (ii) in the event of legal/regulatory non-compliance, retain the amounts owed to contractors’ employees for later transfer; (iii) terminate the contract, if non-compliance with labor rights by the contractor, remain, and (iv) in the event Sudati is sued due to the non-payment of services, Sudati may enter into an agreement and file a lawsuit action against the service provider. There are no written procedures for monitoring and auditing working conditions in the contractual agreement. Going forward, Sudati will establish policies and procedures for managing and monitoring labor/OHS performance of its contractors, as per Brazilian labor law and PS2 requirements, including adequate grievances mechanism for contractor’ workers. This set of policies and procedures must ensure that migrant workers have the same working conditions and benefits under Brazilian law as non-migrant workers carrying out similar work. Sudati will incorporate these requirements in the contractual agreements with its contractors (ESAP#6).

Labor Risks in Supply Chain. As migrants from the northern part of Brazil live in the region, there is contextual risk of forced labor and safety issues in the wood supply chain. There may also be a risk of child labor, considering that suppliers might include family members in the workforce. Sudati has three types of wood suppliers: (i) areas directly managed by Sudati, through service providers, (ii) producers under contracts for forestry development (iii) wood traders, where the sourcing has the highest risk.

The contracts for forestry development include a generic clause related to labor/OHS provisions. Moreover, Sudati recently implemented a Supplier Code to limit sourcing from traders and direct providers who do not meet traceability requirements. The Code states that suppliers must have service contracts in place with registered employees, include rural property registration, among other conditions, and allow for site visits to verify conditions. Sudati will update the Supplier Code to include in all contracts clauses prohibiting forced/child labor in its wood sourcing operations, in addition to biodiversity related requirements (ref. Supply Chain section in PS6). The implementation of this Supplier Code, including training to third-party suppliers, will be carried out by Sudati's forestry professionals (ref. ESAP#3). Implementation effectiveness of the Supplier Code will undergo annual independent site verification. This procedure will also state that if a non-compliance with this prohibition is detected, Sudati will suspend the supplier’s eligibility to sell wood product from any plantations until an investigation is conducted and corrective actions are implemented (ref. ESAP#9 below).

 Resource (energy/water) efficiency. Electricity for the MDF facility is sourced from the national grid and the expected electricity demand for the second production line is 250 kWh/m³ which is less than the benchmark as per Table 3 of WBG EHS Guidelines for Board and Particle-based Products (i.e. 260 kWh/m³). The existing MDF plant has its own 138 kW electrical power substation, which is connected to the existing substation in the municipality of Otacílio Costa through a 1.8 km transmission line.

The on-site water supply system has a treatment capacity of 30m³/hour, captured in a 100 meters groundwater well, in the Canoas River watershed. Sudati has the right to use water resources, issued by the Santa Catarina state Environment Department. The average consumption is 18 m³/hour. The expected water demand for the expansion is 0.6m³/m³ of production, which results in a volume of 880 m³/day. This volume is granted by the Secretary of the Environment of the State of Santa Catarina. The following water sources are planned to meet this increase: implementation of a rainwater reservoir, with an expected storage capacity of 750 m³, reuse from the proposed condensation process, and use of water from the existing well. The plant has installed meters to monitor its water use. Sudati will define resource efficiency programs, including KPIs as part of the ESMS (ref. ESAP#2).

Greenhouse Gases Emissions. Sudati does not track its GHG emissions. Based on its energy and fuel consumption at the MDF plant, GHG emissions are above 25,000 t CO2 eq. per year.  Sudati is mainly using biomass (wood waste from its own operations) as feedstock for its boilers; it envisages using biomass to generate electricity leading to reduce its consumption from the grid. The 2nd production line will use Best Available Technology (BAT) and automation systems. Thus, overall plant-level productivity and efficiency will improve significantly compared to the existing line. Sudati will use an internationally recognized methodology to estimate and report annual GHG emission levels.

Wastewater Treatment. Process wastewater from the 2nd production line, will be treated in a closed-circuit evaporator resulting in zero effluent discharge. The condensate from the evaporator will be reused in the production process and the sludge from will be used as fuel in the boiler, together with the biomass (waste wood). As such, water consumption for the expansion plant is expected to be significantly (about 95%) lower per unit of production compared with industry benchmark.

Air emissions. The main sources of air emissions from the MDF production process include hot presses, dryers, and boilers for steam generation, using biomass as feedstock, which generate particulate matter (PM), nitrogen oxide (NO), carbon monoxide (CO) and volatile organic compounds (VOCs) emissions.  As per the last monitoring report, Sudati is in compliance with the local law for the existing facilities.

For the proposed 2nd production line, sludge from the evaporator will be used together with biomass as fuel for the boiler (60.75 MW) and multicyclone filters will collect and remove the associated pollutants from the air emissions. However, based on the current vendor estimation, particulate matter emissions may exceed WBG EHS Guideline limits. As such, Sudati will review the final design specifications of the process equipment and air pollution control systems for all the stacks in the new production line and the boilers with their guaranteed emission values, and identify corrective measures as needed, so that the air emissions meet the applicable WBG EHS Guidelines for Thermal Power and EHS Guidelines for Board and Particle-Based Products referenced earlier, and will deliver to IFC copies of the final equipment design and performance guarantees (ESAP#7).

Solid and Hazardous Waste. Sudati currently follows procedures and management practices for storing, handling, transport and disposal of waste (63% of wood debarking waste, 12% of hazardous waste and 25% domestic waste and sludge from biological treatment). Sudati will update SOPs and management plan for its solid and hazardous waste management, including on-site handling and storage, transportation, treatment, and final disposal by qualified contractors (ref. ESAP#2). The solid waste storage, as well as substances considered as hazardous/toxic will be managed in accordance with Brazilian regulations and applicable sections of the WBG EHS Guidelines, including proper fencing measures, waterproof flooring and cover, classification, and containment basin for hazardous waste or absorbent material in case of spillage. The adhesive resins used in the MDF manufacturing process, such as phenol-formaldehyde, melamine formaldehyde, urea formaldehyde, and melamine urea formaldehyde, are considered toxic.

Pesticide Use and Management. The wood supply involves the use of pesticides, mainly ant killer and granulated bait (Sulfluramid), which although it is considered a prohibited substance, Brazil holds an exception for its use as ant bait as no effective alternative has been found to date. The company is not using WHO Class Ia and Ib products within its plantations and processing operations. Sudati does not have written procedures for handling and related OHS controls. Therefore, Sudati will prepare and implement a Pesticide Use and Management Plan to reduce and mitigate the impact of pesticide use (ref. ESAP#2). It will include adequate provisions for the strict use of PPE, such as face masks, rotation of labor, regular medical checkups, appropriate disposal of empty pesticide containers, and environment monitoring aimed at tracking pesticides compounds (surface and underground water). Sudati will ensure that the requirement of the Pesticide Use and Management Plan is also applicable to third-party wood suppliers and included in the Suppliers’ Code (ref. ESAP#2                                                  

 Community Health and Safety. Transport of raw material (wood) products and hazardous products is done by suppliers and buyers and is not under Sudati’s direct management. There is a procedure aimed at controlling the truck loading process in the MDF facility, in which equipment (ropes, straps, tarps) is verified. Going forward, Sudati will develop a management procedure/plan to manage heavy vehicles transporting wood and hazardous products to the MDF facility, including due diligence of these service providers, routes selection, documentation and training for drivers, vehicle inspections, etc. It will also include a Code of Conduct for truck drivers, with specific provisions to avoid GBV risk (ref. ESAP#2).

Security Personnel. Sudati has contracted a service provider for security services of its personnel and property, including armed security. There are no available written guidelines driven by the principle of proportionality in the use of force and/or requirements defined for the selection and training of security personnel. According to HR function, there have been no significant complaints from workers or communities regarding the security guards. Minor complaints about the manner of the relationship (impolite ways of speaking), both from workers and security guards have been verbally reported to HR, but not recorded. Going forward, Sudati will develop a Security Management Plan (SMP), including provisions for security providers in terms of selection of security personnel, rules of engagement (including use of force), appropriate conduct toward workers and communities, training in the use of force, monitoring of security personnel workers and grievance mechanism to receive complaints about the security arrangements and personnel, in line with The Voluntary Principles on Security and Human Rights (ESAP#8), and consistent with the United Nation’s (UN) Code of Conduct for Law Enforcement Officials, and UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials                                                  

 Sudati produces and purchases forestry products essential to its core business from the Araucaria moist forest ecoregion of the Atlantic Forest (WWF), an area which has been reduced by 87% of its original footprint and is further protected by Law No. 11.428 of Dec 22, 2006 on the use and protection of the Atlantic Forest Biome. For the new production line, Sudati will expand its operational footprint by 12 ha within the existing industrial lot of its MDF facility on modified habitat and will protect natural habitat as an Area of Permanent Preservation (APP) as required by the Forest Code. No impacts to Critical Habitat are expected from expansion of the MDF facility.

Sudati owns/leases 1,800 ha of forests spread across 13 plantations, of which 40% consists of plantations  that contribute less than 10% of material for MDF production. Of these, two are located within KBA/IBAs: Painel/Urupema and Campo do Planalto das Araucarias where no recent natural habitat conversion has occurred. Sudati shall certify its plantations as sustainably managed by the Forest Stewardship Council (FSC). To do so, it will (i) commission an external audit of owned and leased plantations to verify that management practices are in line with FSC and PS6 requirements, including no loss of natural habitat (as defined by PS6), and (ii) provide timetable to implement any identified corrective actions to achieve FSC certification and PS6 compliance (ESAP#9).

Biodiversity Issues in Supply Chain. The MDF operation is within a region significantly modified by forest plantations, where over 360,000 ha of pine and eucalyptus plantations (estimated to produce 11.5 million m³/year) can supply the mill within a 150 km radius. Significant additional habitat conversion of forest habitat in this region is considered unlikely given legal requirements, namely Mata Atlantica Forest Act and Brazilian Forestry Code.  Sudati currently consumes 400,000 m³/year (3.5% of regional supply).

About 99% of raw materials is sourced from third parties, both directly from farmers and through traders. For the new MDF line, Sudati expects to source about 4% of required material from their own plantations and 96% from third parties (73% directly from eligible third-party suppliers and 27% from eligible traders). To secure future wood supplies, Sudati established a partnership program (SEMEAR) through which Sudati provides seedlings and technical support as part of contracts with producers. Sudati’s SEMEAR program currently includes 410 hectares of plantations. 

Sudati has in place internal procedures to collect business licenses, rural land registration, and verify wood quality of third-party suppliers. Recently Sudati added a Supply Code requiring suppliers to (i) include rural property registration, (jj) ensure material is traceable to origin, and (iii) allow for site visits to verify conditions. Going forward, Sudati will not purchase products (directly or through traders) from plantations that infringe on Conservation Units, Internationally Recognized Areas, Indigenous Lands, Quilombola Communities’ Lands, or plantations infringing on land claims registered under National Institute of Colonization and Agrarian Reform (“Instituto Nacional de Colonização e Reforma Agrária” – INCRA). For this, Sudati will update the Supplier Code and procedure for traceability, risk screening and monitoring of its supply chain vis-à-vis its Supply Code. The Supply Code will include requirements that need to be met by all the suppliers i.e. direct suppliers (including those under SEMEAR program) and indirect suppliers through traders, such as compliance with Brazilian law to protect and maintain Legal Forest Reserves and Areas of Permanent Preservation and non- conversion of any natural habitat. Traders willl need to present evidence of compliance with Sudati’s Supplier Code for their suppliers, or provide supplier details directly to Sudati for screening (ESAP#10).

Sudati is limiting the sourcing from traders without traceability of their suppliers. Sudati will require that traders sign the Supplier Code, verifying that their suppliers have been assessed for environmental and social risks and are eligible to sell to Sudati. Where non-compliance with the Supplier Code and Brazilian law is detected, Sudati will suspend the supplier’s eligibility to sell wood product from any plantations until an investigation is conducted and the non-compliance is corrected within a reasonable time frame. Sudati will commission an annual independent verification of its wood sourcing by experienced forestry professionals. Additionally, Sudati will implement a “Zero conversion of natural habitat” policy as part of the proposed procedures/Code of Conduct for their own production, leased properties and third-party providers, including traders and sawmills.

Stakeholder Engagement, External Communication, and Grievance Mechanism. The MDF plant is located on the outskirts of Otacílio Costa city, less than 1 km away from residential areas. The municipality of Otacilio Costa has 19,201 inhabitants, 91% being in the urban area. In the rural areas, the inhabitants are scattered in farms or small settlements. The disclosure of information is mainly through social networks. Employment opportunities are disclosed through local radio and newspapers. The Company publishes a quarterly magazine aimed primarily at disseminating information for employees about internal training programs, accident prevention, social responsibility activities, and employees who have been awarded prizes or new positions. According to the information provided, no information about the implementation of the MDF unit was communicated and consulted with the surrounding community. The ESIA for the expansion project does not foresee public consultation, as it is a simplified process. Thus, the Company will develop and implement a Stakeholder Engagement Plan (SEP) in line with PS1 requirement. The SEP will be based on robust stakeholder mapping and will include disclosure and dissemination of information for all the stages of the project. A separate Community Grievance Mechanism shall be included in the SEP, aligned with IFC’s PS1 requirements (ESAP#11).

Sudati; João Eduardo Sudati; Vie President; Phone: +55 46 3263 8483 Mobile: +55 46 99118 4273; jsudati@sudati.com.br; 
Rua Manoel Vicente de Oliveira Mello, 1581 - 2º andar Tarumã - 82530-460 - Curitiba - PR - Brasil