While all Performance Standards are applicable to this investment, IFC’s 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

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

This is a Category B project as per the IFC's Policy on Environment and Social Sustainability (2012). The project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures.

Key E&S risks and impacts associated with this Category B project include: (i) ZZ2’s capacity to identify and manage E&S risks and impacts; (ii) labor & working conditions, including OHS, workers grievance mechanism, child/forced labor, gender based violence and harassment (“GBVH”); and workers accommodation; (iii) contractors’ management and supply chain; (iv) water/energy usage and efficiency, air emissions, solid/hazardous waste and wastewater; (v) life & fire safety systems; (vi) food safety management systems; (vii) emergency response and preparedness; (viii) stakeholder engagement and community health & safety, and (iv) potential adverse impact on biodiversity at farms subject to IFC use of proceeds located within Alliance for Zero Extinction (AZE) areas. They support several Critically Endangered and Endangered and range-restricted plant and animal species.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s 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 implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. ZZ2 has established components of an Environmental and Social Management System (“ESMS”) that are commensurate with the scale of the E&S risks and impacts of its operations.

The operations are certified with Global Good Agricultural Practices (“Global GAP”) and the Sustainability Initiative of South Africa (“SIZA”). Global GAP is an internationally recognized farm assurance standard that sets E&S standards for agricultural production. SIZA is a similar South African program that promotes good E&S practices in agriculture through audits and continuous improvement.

The following are the key components of the ESMS, along with areas for improvement to support alignment with the IFC PS:

Policy
As part of IFC’s investment ZZ2 will develop a standalone overarching E&S Policy that articulates the Company’s commitment to: (i) compliance with applicable laws and regulations; (ii) the IFC PS and relevant EHS Guidelines; (iii) internationally recognized certification schemes; and (iv) continual improvement. The Policy will clearly define E&S roles and responsibilities (including senior management accountability and designated E&S leads at corporate and facility/farm levels), set expectations for contractors and suppliers, and be communicated to staff and external stakeholders (ESAP#1A).

Identification of Risks and Impacts
ZZ2 has developed comprehensive farm-level environmental risk assessments for avocado farms. Each environmental risk is evaluated systematically using a matrix that considers likelihood and consequence to generate a risk rating, which is accompanied by defined mitigation measures and designated responsible persons. The assessments cover a broad spectrum of environmental risks, including flooding and stormwater impacts, waste and agrochemical runoff, habitat clearance, soil erosion, pesticide spray drift to neighboring properties, the spread of plant pests and diseases, and fires. For each identified risk, the assessment specifies mitigation measures, such as buffer zones, erosion control structures, integrated pest management, firebreak maintenance, and spill prevention, and links these to monitoring requirements.

In addition, ZZ2 has completed Hazard Identification and Risk Assessments (HIRA) for Occupational Health and Safety (“OHS”) at a farm level. These are similarly comprehensive, identifying hazards such as electrocution, falls from height, lacerations from tools and machinery, and vehicle-related accidents. The HIRAs assess the likelihood and potential severity of each hazard, assign a risk rating, and outline specific control measures. This integrated approach to EHS risk management is consistent with IFC PS 1 and the EHS Guidelines. Risk mitigation measures are described further in the OHS section of PS 2.

Whether environmental authorizations are needed for the new solar projects or avocado expansions will be decided with the Department of Environmental Affairs prior to project development. ZZ2 has a compliance team and an environmental consultant on retainer who will lead this engagement, ensuring compliance with applicable permitting requirements and in a manner consistent with the requirements of PS1 (para. 7).

As per ESAP#1B, ZZ2 will develop and implement an E&S screening and assessment procedure to ensure that risks and impacts associated with IFC PS and national legislation are systematically identified and managed prior to new projects (i.e. farm expansions, the acquisition of new farms or the development of solar projects).

Management Programs
In alignment with PS1, the Company has developed an Environmental Management Plan (EMP) for its Avocado Division that addresses water resource management, soil conservation, erosion control, agrochemical handling and storage, integrated pest management, energy use and emissions, waste management, invasive alien plant control, and fire prevention and response. For each area, the EMP includes risk assessments, legal compliance references, and an overview of management measures. It establishes environmental targets, assigns responsibilities (with roles for farm managers, agronomists, environmental specialists, and OHS leads), and sets out regular monitoring procedures, where relevant. The EMP also integrates risk registers, incident response protocols, and corrective actions, ensuring alignment with SIZA environmental standards and relevant South African legislation.

In accordance with ESAP#1C, the EMP will be expanded to include risk registers and mitigation measures for the tomato division. The updated EMP will incorporate cross-referencing to risk registers, existing standalone Standard Operating Procedures (SOPs) and management plans. These will all be updated based on new risks identified for the tomato division. A document control procedure will be embedded within the EMP to guarantee that all documents are completed, reviewed periodically, and signed off by senior management. Implementation of the EMP at a farm level will be internally audited at an operations level periodically. A training program will be developed for farm managers and designated personnel responsible for implementation that includes periodic refreshers to ensure continued implementation.

Organizational Capacity and Competency
ZZ2 is well resourced with an ecologist, environmental, OHS, HR, a community liaison officer and compliance specialists in place who have different reporting lines. As per ESAP#2, a senior manager will be designated responsibility for overseeing EHS functions. The senior manager will conduct regular cross functional meetings to coordinate EMP implementation (including with relevant operational teams), monitor emerging risks, and address E&S issues proactively. The designated senior manager will also report to the ZZ2 board on E&S performance.

The Company operates a dedicated training center at Mooketsi. A “train-the-trainer” approach is used. Key farm-based staff receive instruction and cascade this knowledge to workers at the farm level. Training plans and attendance registers are maintained by a dedicated training team based at the center.

Emergency Preparedness and Response
The EMP provides a framework of emergency procedures for farm operations related to fire and chemical spills. A standalone accident and casualty procedure is in place that covers chemical exposure, snake bites, burns and injury from machinery. Detailed emergency procedures are in place for specific packhouses covering roles and responsibilities, routes to hospitals, emergency contacts and specific procedures for fire and medical emergencies.

Periodic fire drills are conducted at operational facilities, with records maintained on performance and lessons learned. Workers receive formal training on emergency response, including firefighting basics, delivered via the training center and reinforced through toolbox talks and on-site demonstrations.

While general emergency procedures and rules are in place across all ZZ2 farms, the company will develop Emergency Response Plans for the individual farms and worker accommodation units subject to IFC use of proceeds. These plans will address site-specific risks and clearly define roles and responsibilities, communication protocols, evacuation procedures, and training requirements (ESAP#1D).

Monitoring and Review
Internal E&S audits are done yearly. Global GAP and SIZA conduct annual external audits for all ZZ2 operations. Corrective measures are tracked and closed out.

ZZ2 has resource monitoring programs in place across its operations. The company tracks consumption of water, fuel, electricity (from grid, diesel generators, and captive solar PV) and agricultural chemicals. Targets are set annually to drive efficiency improvements, supported by detailed data collection and reporting systems. Water is sourced from boreholes, spring-fed and rain-fed dams, and rivers. Borehole water levels and yields are monitored monthly using a digital platform. Surface and groundwater quality is monitored annually, with samples analyzed by accredited laboratories to meet Global G.A.P. standards. Electricity use is tracked through sub-metering, prepaid meters, and a central online application. As per ESAP 1C, monitoring procedures will be added to the EMP.

ZZ2’s agronomist team monitor the application of agricultural chemicals including fertilizers, pesticides, and herbicides. These activities are governed by the company’s Integrated Pest Management (IPM) plan, which assigns clear roles and responsibilities, mandates pest monitoring, and enforces threshold-based interventions.

External Communication and Community Grievance Mechanism
ZZ2 engages with surrounding communities primarily through the HR and Community Liaison functions, focusing on direct recruitment, security-related matters, and responding to community requests for assistance. Community issues are addressed through traditional leaders and the ZZ2 community liaison officer.

As per ESAP#1E, ZZ2 will develop and implement a Stakeholder Engagement Plan in line with IFC PS 1. It will include stakeholder mapping and needs assessment, procedures for responding to community requests for assistance and reporting feedback mechanisms to communities on engagements and interventions. In addition, the Company will establish a formal grievance mechanism for external stakeholders, aligned with IFC PS?1, with multiple access points, procedures for tracking and responding to grievances, and regular reporting to management on grievance trends and resolutions.

PS2: Labor and Working Conditions

ZZ2 employs approximately ~9 300 workers across its operations, with ~1 100 permanent workers at its avocado operations, with an additional ~800 seasonal workers during peak periods for avocado and tomato picking. Approximately half of the workforce is female. Most workers are South African nationals with a smaller percentage of Mozambican and Zimbabwean nationals. ZZ2 has procedures in place to ensure foreign workers have valid work permits in place. Most permanent and seasonal workers are recruited from surrounding villages, with local authorities (village heads) acting as the communication conduit for recruitment needs to villages and provision of candidate lists to ZZ2.

Working Conditions and Management of Worker Relationships
As per ESAP#3A, ZZ2 will formalize its current recruitment procedure. It will outline the process of contacting village heads to advertise available positions, specify general experience requirements, and describe how applications and candidate lists are managed. It will detail how candidates are assessed and selected for interviews and include a grievance mechanism for reporting concerns about unfair hiring practices.

No workers' unions exist, but employees are not prevented from joining unions. As per ESAP#3B, a clause will be added to both permanent and temporary employment contracts affirming that employees have the right to freedom of association and to participate in collective bargaining, consistent with national law and IFC Performance Standard 2.

The Company has Housing, Social, and OHS Committees on each farm, with at least 50% female representation and an HR Clerk. Worker-elected representatives use these committees to address workplace concerns. The housing committee monitors accommodation conditions and reports issues to management; the Social Committee addresses minor work disputes among workers without management; and the OHS Committee focuses on farm health and safety. Meeting records are kept and shared with management and workers. Farm HR Clerks act as a bridge between farm management and the workforce.

HR Policies and Procedures
The Company has robust HR and OHS policies aligned with national labor and OHS regulations.

Permanent and seasonal workers are provided with employment contracts stipulating employment conditions, remuneration, employment rights and available channels for grievances. The renumeration policy is based on national minimum wage, with ZZ2 ensuring all workers earn above minimum wage thresholds including for piece work. Permanent and seasonal workers are provided with details at induction on HR policies, including channels to address grievances.

Terms of Employment
Worker terms of employment, including working hours, disciplinary processes, pay slip deductions, and fit for work requirements, are all clearly stipulated in employment contracts.

All staff are required to complete an annual medical by a third party that includes a basic health assessment and physical examination to ensure they are fit for work. More detailed medicals are conducted for spray operators that are tailored to the agricultural chemicals they are exposed to. There is no screening or discrimination for pregnancy or HIV/Aids.

Non-Discrimination and Equal Opportunity
Sexual Harassment and abuse are specifically prevented by the Company’s workplace rules. In addition, as per ESAP#3C, ZZ2 will develop and implement a dedicated GBVH policy, accompanied by periodic training for all workers. The GBVH policy will define GBVH and guarantee confidential reporting channels, protect individuals from retaliation, and ensure that investigations are confidential. An awareness campaign and training will be conducted on the policy.

Grievance Mechanism
Three Company channels for addressing grievances and complaints are in place 1) a basic, formal grievance mechanism, 2) an internal HR committee, and 3) the Social Committee (as described under “Working Conditions” section above). The internal HR committee reviews cases brought forward from the Housing and Social committees, which require escalation. These cases require formal investigation that may result in disciplinary proceedings. The committee system for addressing worker issues in general is effective.

As per ESAP#3D, ZZ2 will consolidate grievance tracking by keeping a detailed register, including those received through committees and any required follow-up actions. The outcomes of the grievance process or any resulting disciplinary actions will also be recorded.

Accommodation
Worker accommodation is located within farm boundaries. Workers are offered accommodation based on seniority, married couples who work for ZZ2, or workers living far from farms. Workers who live in accommodation receive a 15% deduction from their wages for the provision of accommodation and services and utilities. South African labor law limits accommodation deductions to 10% for individuals and 25% for two sharing. Since ZZ2 also provides water, electricity, gas, and transport, they successfully applied for a dispensation from government allowing for deductions of 15% for one person and 30% for two people sharing.

The general standard of accommodation is adequate. The age, quality and type of accommodation varies between hostel style, to newer purpose-built individual houses and units for couples. Various upgrades have been carried out across all accommodation units including electrification, potable water, wood-fired water boilers, gas-cooking facilities and basic fire management equipment. Upgrades have been driven by Global GAP requirements.

HIRAs have been completed for each accommodation unit. Fire and first-aid trained staff are present at each accommodation location.

Protection of Workforce
All employees are above 18 years old and are required to provide government-issued identification. Migrant workers are all permanent with relevant government issued work and resident permits.

Occupational Health and Safety (“OHS”)
Key OHS risks in farms and packhouses include physical hazards such as collisions, crush injuries, and entrapment from vehicles and machinery, as well as accidents during maintenance or repair activities. Biological hazards include bites and stings. Chemical hazards are associated with the handling, mixing, spraying, and storage of pesticides, herbicides, and fertilizers. Detailed OHS incident reports are maintained, including for incidents involving vehicles, as well as for near misses. No fatalities have been reported since digital record keeping began in 2022. There have been four significant OHS incidents since 2022 on farms subject to IFC use of proceeds. These were related to bee stings, pinch injuries and tractor and trailer roll overs.

ZZ2’s farm level OHS system is coordinated by the Group OHS function and is underpinned by documented Hazard Identification and Risk Assessments (“HIRAs”) for each farm and packhouse, Safe Working Procedures (“SWPs”), company workplace rules and incident reporting procedures. At each individual operation, the farm/operation manager is the safety representative and is responsible for day-to-day implementation of OHS risk management. SWPs detail daily startup checklists, PPE, safe stacking controls, vehicle safety checks, and chemical container controls. Certified contractors are responsible for the safe disposal of chemical containers. The Workplace Rules require adherence to OHS regulations and are enforceable under the disciplinary code. When serious OHS related incidents occur, an incident investigation report is developed, including corrective actions, by the OHS team. Monthly farm-level OHS Committee meetings review system implementation and corrective actions.

Ambient temperatures can reach up to 43°C during summer months in the areas where the farms are located, which presents a risk to worker health. Heat stress risk is identified in the OHS risk assessment and mitigation measures include provision of rest breaks, access to potable water and designated shaded rest areas. As per ESAP#4, ZZ2 will formalize existing heat stress management practices by developing and implementing a heat stress prevention and mitigation procedure to reduce the risk of heat stress for workers, which formalize existing practices. In addition, ZZ2 will provide heat stress prevention and management training to staff to develop awareness and understanding of health risks associated with exposure to heat (ESAP#5).

Vehicle Safety
Operation of vehicles on farms and public roads represents one of the most common health and safety risks for company staff, contractors, and the public, with incident logs indicating a relatively high number of motor vehicle accidents. These risks arise from the extensive use of ZZ2 worker transport buses, trucks, tractors, refueling tankers, and pickup trucks for operational purposes, often in rural environments with poor quality roads.

ZZ2 has a Vehicle Policy and Procedure that governs the safe use of vehicles. The policy mandates that all drivers hold valid licenses and that vehicles are licensed, roadworthy, and maintained in good condition. Driving under the influence of alcohol or drugs is prohibited. Daily vehicle logs must be maintained, and accident reporting procedures are defined. Passenger limits are defined based on vehicle type to ensure safe transport staff. All ZZ2’s trucks are Road Transport Management System certified, a national voluntary certification scheme. Vehicles are equipped with in-vehicle monitoring systems. ZZ2 truck drivers undergo training including Professional Driving Permit’s, psychometric evaluations and testing. Training is also provided for tractor and pick-up vehicle drivers.

As per ESAP #5, ZZ2 will update its driver training program to strengthen competencies in defensive driving, road safety practices, fatigue management, passenger safety requirements, speed and load limits, and accident reporting procedures. The initiative will include an appropriate schedule for refresher courses and ensure delivery by qualified trainers.

Third Parties and Contractors
The Company uses contractors for specialized activities (e.g. security, aerial spraying, pollination and cleaning of PPE). Contractor screening for compliance with labor laws is carried out and recorded. The Company uses labor brokers to supply workers during peak periods. Labor broker service agreements are SIZA compliant and SIZA audits these agreements annually.

A documented construction contractor oversight procedure is in place and implemented by ZZ2’s OHS department. This procedure reflects ZZ2’s structured approach to managing construction activities, ensuring compliance with relevant legislation and internal safety protocols. It will be applied to the solar projects that will be developed with IFC use of proceeds. It outlines the required documentation and EHS responsibilities for both ZZ2 and its contractors. Key provisions include the submission by the contractor of a site-specific baseline risk assessment, a comprehensive health and safety file, identification documents and medical fitness certificates for all workers, and details of appointed health and safety officers and safety representatives. Additional obligations include implementing fall protection plans, securing hot work permits, maintaining material safety data sheets, and adhering to site housekeeping and evacuation protocols.

PS3: Resource Efficiency and Pollution Prevention

Electricity, diesel and water are the main resources utilized by the operations. Key pollution risks relate to agricultural chemicals including handling, storage, application and disposal of used agricultural chemical containers and expired products.

ZZ2 has an Energy Management Policy aimed at improving energy efficiency and reducing greenhouse gas emissions. The policy outlines commitments from senior management, assigns responsibilities, and sets energy reduction targets for packhouses, workshops and farms. Measures include the installation of high efficiency motors and pumps, LED lighting, solar installations, and precision irrigation systems, supported by monitoring and reporting tools.

Greenhouse Gas Emissions
Greenhouse gas (GHG) emissions have been assessed for the assets financed under IFC’s use of proceeds. GHG emissions for the assets to be financed are largely limited to grid electricity, diesel generators, vehicles and agricultural machinery. Estimated operational Scope 1 and Scope 2 emissions attributable to these assets are below the 25,000 tCO2e/year threshold, and therefore annual quantification and reporting under PS3 is not triggered.

Water Usage
Avocado and tomato crops are irrigated with water from boreholes, spring- and rain-fed dams and rivers. Packhouses utilize water from boreholes. Water drawn from each water source is monitored remotely using an online platform to promote efficiency. Drip irrigation is used for both tomatoes and avocadoes. Flow meters are in the process of being installed on pumps at all farms. Remote sensors are used to monitor avocado tree growth and health to ensure optimum application of water, fertilizers, pesticides and other inputs. Soil moisture testing is conducted each week in multiple field locations to test water content to ensure water efficiency. Water use is regulated in South Africa; licenses have been obtained, and usage is continuously monitored and targets set. Water consumption is shared with neighboring farms via Water Use Forums. The farms subject to IFC use of proceeds are in a high rainfall region of South Africa and no historic issues associated with water shortages were reported.

Wastes
Solid waste management follows Global GAP requirements and is managed according to a waste management plan. Organic waste from avocado trees is composted and used in orchards as fertilizer. Solid waste is segregated, and empty chemical/pesticides containers are stored in locked storage areas before being disposed of by licensed contractors who provide ZZ2 with safe disposal certificates. Other forms of hazardous waste, such as hydrocarbons and out of date and residual chemicals are disposed of by certified waste management companies.

Packhouse wastewater is removed to settling dams or reed ponds before being released into the environment. Periodic effluent testing is conducted against Brand Reputation through Compliance Global Standards (BRCGS) Food Safety Standards.

Pesticide Use and Management
ZZ2 relies on chemical products to control fruit pests, disease and weeds. The company has an Integrated Pest Management (“IPM”) plan for avocados and tomatoes, which follows a hierarchy of control and assigns defined roles and responsibilities. The plans prioritize pest prevention measures (including site selection, tolerant rootstocks and canopy management), requires regular pest monitoring with threshold-based intervention, promotes biological controls, and stipulates that only registered products in South Africa for avocadoes and tomatoes may be used. It includes detailed procedures for drift reduction and pollinator protection. It provides details on training for relevant personnel.

In line with recent regulatory requirements, ZZ2 is required to have registered Pesticide Control Operators (“PCOs”) for the handling and application of restricted agricultural remedies. The company is currently in the process of registering its agronomists as PCOs to ensure compliance with these requirements.

To further align with IFC PS 3, the IPM plans will be enhanced to: (i) define no-spray buffer zones for water bodies and settlements; (ii) introduce a standard operating procedure for notifying neighbors when high-risk chemicals are applied close to their properties, (iii) prohibit the purchase, storage, or use of pesticides classified by the World Health Organization as Hazard Classes 1a (extremely hazardous) and 1b (highly hazardous), or listed in Annexes A and B of the Stockholm Convention. In addition, ZZ2 will stop the use of pesticides classed as 1a and 1b and those listed in Annex A and B of the Stockholm Convention (ESAP#6).

Soil Conservation and Management
ZZ2 has a Soil Management Plan for avocados that addresses key thematic areas such as soil health assessments, erosion control, nutrient and organic matter management, irrigation, contamination prevention, monitoring, training, and record keeping. The plan is broadly aligned with the requirements of the IFC EHS Guidelines for Perennial Crop Production.

Hazardous materials management and safety:
The company's chemical storage facilities comply with Global GAP standards. The sites have equipment for managing spillages, and PPE is provided. Diesel tanks are equipped with secondary containment to prevent spills.

Spray operators are provided with showers on farms and have their overalls washed on site. Safety rules address PPE use, exclusion from areas during spraying and hazard awareness.

Food Safety
ZZ2’s crops and packing/processing facilities are certified under Global GAP, which requires them to identify and assess food safety risks in all phases of operations. ZZ2 has a Hygiene, Safety and Emergency Response procedure to ensure safe handling of tomatoes and avocadoes during harvesting, production, and packing. It sets out hygiene protocols for personal cleanliness, handwashing, exclusion of sick workers, wound covering, and prevention of contamination through equipment cleaning.

PS4: Community Health, Safety and Security

Security
To secure assets and produce, the Company relies on unarmed security guards that they employ directly for provision of security services such as access control and routine patrols. The company also retains licensed third-party armed response security providers and liaises with National Police. Third-party security is used in high-risk locations when fruit is on trees presenting a theft risk. Additional security measures include the use of CCTV cameras and fencing. Specific anti-poaching security (unarmed) directly employed by ZZ2 is also deployed across various farms.

ZZ2 will develop a Security Management Plan (ESAP#7). It will be aligned with national regulatory requirements, IFC’s good practice handbook, Use of Security Forces: Assessing and Managing Risks and Impacts (2017), and good international industry practice (e.g. the Voluntary Principles on Security and Human Rights). It will define risks (including contextual risks), security roles and responsibilities (including for private security), establish rules of engagement, outline protocols for coordination with the police, and include a grievance mechanism for members of host communities to report security-related concerns.

As per ESAP#5, a suitably qualified consultant will be appointed to provide internal security staff with training on the Security Management Plan.

Emergency Preparedness and Response
A number of ZZ2 farms are located in potential fire prone zones and the Company has an overarching Fire Management Plan in place. At each farm there is fire-fighting equipment and trained fire-fighting personnel. ZZ2 and its fire-fighting efforts are coordinated as part of a local fire association.

NB: Vehicle safety for staff and stakeholders is described under PS2.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The Project consists of 11 farms/facilities which overlap the following three biomes; Tropical & Subtropical Grasslands, Savannas & Shrublands (Central Bushveld and Limpopo Lowveld Ecoregion) and Montane Grasslands & Shrublands (Highveld Grasslands Ecoregion). The farms have been established for ten plus years and are located on lands that have mostly been modified for agriculture or forestry. They also support some natural habitat (“NH”), especially in montane grassland areas which are not farmed. A limited portion of the land compared to the total farm areas are utilized for agricultural activities.

Two farms out of 11 farms to receive financing by IFC, Olyfberg and Roma, overlap with the Wolkberg-Bewaarkloof Key Biodiversity Area (“KBA”) (100989), which is also considered an Alliance for Zero Extinction (“AZE”) site. It is designated for four highly threatened and range restricted species: Methuen's Dwarf Gecko (Lygodactylus methueni) (Endangered (“EN”)), Afroaster nubimontis (EN), Indigofera rehmannii (EN) and Wolkberg Zulu (Alaena margaritacea) (Critically Endangered (“CR”)). The KBA/AZE supports a wide range of grassland, bushveld and forest vegetation types, two of which are nationally classified as severely threatened, namely Woodbush Granite Grassland (CR) and Tzaneen Sour Bushveld (EN). None of the farms that form part of the re-financing package overlap with any AZEs.

Ecological surveys conducted by nationally-recognized species specialists on the farms overlapping the AZE determined that while the montane grassland areas of the Olyfberg farm were likely to support three of the AZE trigger species (A. nubimontis, I. rehmanni, and Wolkberg Zulu), as well as other priority biodiversity values, these areas will not be disturbed by current or future farming activities. No suitable habitat for Methuen's Dwarf Gecko was identified at any of the surveyed farms. Whilst some potentially suitable habitat for Wolkberg Zulu was located within or close to the proposed agricultural expansion footprints at Olyfberg, the likelihood of the species using these areas was considered low due to the lower altitude and limited availability of foraging habitat. Since remnant natural habitat is largely confined to montane areas which are not accessible for farming purposes, the expansion areas are not expected to impact natural or critical habitat values. The project will be consulting with the AZE secretariat to verify these findings.

Project-related impacts on biodiversity include potential habitat loss and degradation including associated priority biodiversity values, pesticide/herbicide runoff, and introduction and spread of invasive species. To manage some of these biodiversity risks, ZZ2 currently adopt and implement the following certifications: GlobalG.A.P. and the SIZA Environmental Scheme. These require farms to develop BAPs with measures to enhance biodiversity, protect natural habitats and implement pollution control.

The Farm Expansion and Redevelopment Risk Screening Procedures to be developed as part of ESAP#1B, will include procedures for the appropriate identification and assessment of biodiversity risks for any future expansions across all ZZ2 operations. This will include the company’s PS6 compliant biodiversity commitments, including a commitment to avoid expansion of agricultural activities in natural habitats within AZE sites.

ZZ2 will develop and implement a Biodiversity Action Plan (BAP), in consultation with protected area sponsors (ESAP#8). The BAP will:

1) Describe the additional programmes that will be implemented to positively contribute to the conservation of the area given the project overlaps the Wolkberg-Bewaarkloof AZE/KBA .
2) Include a long-term monitoring and evaluation program (BMEP) to ensure on-site biodiversity management actions are effective, as well as ensuring that the additional programmes implemented in the wider Wolkberg-Bewaarkloof AZE/KBA are effective.

PS8: Cultural Heritage

ZZ2 maintains a documented process to protect graves on its properties and facilitate access. In line with IFC PS8, requests to visit graves, erect tombstones, conduct burials, or other activities are submitted via an application form. Visits are then facilitated by management.

ZZ2 engages with surrounding communities primarily through its HR and Community Liaison functions, focusing on recruitment, security-related matters, and responding to community requests for assistance. As per ESAP #1E, ZZ2 will appoint a suitably qualified consultant to develop and implement a SEP aligned with IFC PS 1. The SEP will include stakeholder mapping and needs assessment, procedures for responding to community requests, feedback mechanisms, and regular reporting.

Contact Person: Hendus Janse van Rensburg
Company Name: ZZ2
Email: hendus.jvr@zz2.co.za
Phone: +27 15 395 8974

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	The policy will state commitments to legal compliance, IFC PS, applicable certifications; define E&S roles and responsibilities; set expectations for contractors and be communicated to stakeholders.	07/01/2026
2	ZZ2 will develop and implement a screening procedure to ensure that risks and impacts associated with the IFC PS are systematically identified and managed prior to expanding farming operations or acquiring new farms. It will:- Include an assessment of the need for environmental authorizations, water use licenses (including any updates), and other relevant permits, as well as determining whether ESIAs or Basic Assessments are required.- Detail the requirements for identification and assessment of sensitive biodiversity sites, and the framework for appropriate assessment and management of biodiversity risks. - Include PS6 compliant biodiversity commitments (i.e. a commitment to avoid expansion of agricultural activities in areas of natural habitat within AZE sites).	07/01/2026
3	- Expand the EMP and develop risk registers to cover the tomato division- Include cross-references to existing risk registers, Standard Operating Procedures and management plans. - Include resource use monitoring procedures.- Embed a document control procedure including the requirement for all EMP related documents to be reviewed and approved by senior management. - Establish periodic internal audits at the operations level to assess EMP implementation. - Develop and implement a training program for farm managers and designated personnel on the EMP.	01/01/2027
4	- The ERPs will address site-specific risks and clearly define roles and responsibilities, communication protocols, evacuation procedures, and training requirements aligned with the IFC EHS Guidelines, and the IFC/EBRD Workers’ Accommodation Guidance Note. - A fire safety audit will be undertaken on worker accommodation at farms subject to IFC use of proceeds to support with ERP implementation.	07/01/2026
5	Develop and implement a SEP, including stakeholder mapping, needs assessment, procedures for responding to community requests for assistance and reporting feedback mechanism to communities on engagements and interventions. It will include a GM for external stakeholders, procedures for tracking and responding to grievances, and responsibilities for handling grievances.	07/01/2026
6	- Designate a senior manager to oversee EHS functions.- Conduct regular cross functional meetings to coordinate EMP implementation and monitor and mitigate emerging E&S risks. Meetings will include representation from relevant operational teams. - The senior manager will report EHS performance to the board.	01/01/2027
7	A worker recruitment procedure will be developed formalising existing practices, including liaison with village heads, experience requirements, the application process, assessment criteria and a grievance mechanism.	01/01/2027
8	A clause will be added to both permanent and temporary employment contracts affirming that employees have the right to freedom of association and to participate in collective bargaining, consistent with national law and IFC Performance Standard 2	01/01/2027
9	Develop and implement a dedicated GBVH policy. It will:- Clearly define GBVH and outline prevention measures.- Establish confidential, accessible, and survivor-centered reporting channels.- Guarantee protection against retaliation for complainants and witnesses.- Ensure that all GBVH complaints are subject to confidential, timely, and impartial investigations, with outcomes documented.	04/01/2026
10	ZZ2 will develop a consolidated grievance register, including those received through committees detailing follow-up actions. The outcomes of the grievance process or any resulting disciplinary actions will also be recorded.	01/01/2027
11	Develop and implement a heat stress prevention and mitigation procedure, which documents already existing practices.	01/01/2027
12	- Provide heat stress prevention and management training to farm managers, supervisors and workers (see ESAP#5).- A qualified consultant will train internal security staff on the Security Management Plan (see ESAP#8).- Enhance the driver training program to strengthen competencies in defensive driving, road safety practices, fatigue management, passenger safety requirements, speed and load limits, and accident reporting procedures.	01/01/2027
13	- Phase out the use of pesticide formulations classed 1a and 1b and those listed in Annex A and B of the Stockholm Convention. - Specifically prohibit the purchase, storage or use of pesticide formulations that fall under the WHO’s Recommended Classification of Pesticides by Hazard Classes 1a (extremely hazardous) and 1b (highly hazardous), or Annexes A and B of the Stockholm Convention after the phase out period ends in July 2026.- Define no-spray buffer zones for water bodies and settlements- Introduce a standard operating procedure for notifying neighbors when high-risk chemicals are applied close to their properties	07/01/2026
14	It will be aligned with national regulatory requirements, IFC’s good practice handbook, Use of Security Forces: Assessing and Managing Risks and Impacts (2017), and good international industry practice (e.g. the Voluntary Principles on Security and Human Rights). It will define risks (including contextual risks), security roles and responsibilities (including for private security), establish rules of engagement, outline protocols for coordination with the police, and include a grievance mechanism for members of host communities to report security-related concerns.	01/01/2027
15	ZZ2 will develop and implement a BAP, in consultation with protected area sponsors, and conduct the required associated specialist studies. It will describe the additional programmes that will be implemented to positively contribute to the conservation of the Wolkberg - Bewaarkloof AZE/KBA and a BMEP to ensure biodiversity management actions are effective, including the additional programmes implemented in the wider Wolkberg - Bewaarkloof AZE/KBA are effective.	07/01/2026