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:
Policy and Management System
EVM has an overarching Corporate Environmental, Social and Governance (ESG) Policy, defining the Company’s principles and procedures to align EVM’s strategic decisions and operational activities with ESG objectives, including the UN Global Pact principles, such as human rights, labor, environment, anti-corruption, conscious consumption, diversity, equity and inclusion (DEI), among others, aligned with PS1 provisions.
The company has established an E&S management system (ESMS) focusing on identifying and managing E&S risks and impacts in line with national law, with relevant E&S procedures and management programs in place. The company has been granted the required approvals by environmental authorities. EVM will augment its ESMS procedures per the requirements of IFC PS and WBG EHS General Guidelines primarily focusing on: (i) E&S management and monitoring; (ii) supply chain related to Original Equipment Manufacturers (OEMs); (iii) emergency preparedness and response; (iv) batteries management plan; (v) waste management plan and; vi) stakeholder engagement and grievance mechanisms. These requirements are addressed in detail in ESAP action items 1 to 6, which are explained in further detail below.
Identification of 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. In accordance with Brazilian regulations, EVM’s operations are exempt from environmental licensing; however, the Company as part of its ESMS has developed an ESG due diligence procedure to systematically identify and assess E&S risks and impacts and develop mitigation measures from its operations. In addition, the Company has developed an evaluation matrix and has identified E&S impacts and aspects in its operations.
Management & Monitoring programs
EVM controls risks and impacts in accordance with applicable local and national regulatory requirements and has high level policies in place but does not have detailed management procedures that outline the E&S mitigations and performance requirements expected in its operations. Moreover, EVM has several ESG commitments, including legal requirements, GHG and ESG reports, certifications and memberships, which are reviewed by the Company’s senior management. In turn, the Sponsor’s ESG support team provides advice to the Company’s Board of Directors and Executive Board on all the topics included in the ESG policy. Going forward, as part of ESAP item #1, EVM will develop a corporate-level E&S management and monitoring plan in the form of documented procedures, practices, or plans, that describe the mitigation measures necessary to address EVM’s identified E&S risks and impacts and monitoring the performance and compliance of the ESMS, establishing and monitoring KPIs and performance targets for E&S aspects, as well as internal and external audits to verify compliance with applicable legal requirements and requirement of IFC PS and WBG EHS Guidelines.
Organizational Capacity
At EVM, E&S aspects are managed across two independent corporate structures, including the Environmental, Social and Governance (ESG) and Human Resources (HR) departments. The ESG department periodically reports E&S performance directly to the Chief Financial Officer (CFO), while HR reports to the Chief Executive Officer (CEO). This ESG structure ensures a robust and well-rounded approach to managing E&S aspects, fostering accountability and strategic alignment at the highest levels of the organization.
Emergency preparedness and response
EVM has developed an Emergency Preparedness Plan per national law, focusing only on office buildings. As per ESAP #2, the Company will develop an Emergency Preparedness and Response Plan (EPRP) for the construction of EVs charging infrastructure to address any foreseeable accidental and emergency scenarios associated with the construction and operation of such infrastructure.
PS2: Labor and Working Condition:
At the end of 2024, EVM employed 36 individuals, of which 33% are female. Women occupy 47% of the Company’s leadership positions.
Human Resources (HR) Policies and Procedures
The Company has a suite of HR policies as well as a Code of Conduct and Ethics which are aligned with local regulations and consistent with PS2 requirements, covering labor and working conditions, including prohibiting child and forced labor, non-discrimination, human rights and diversity, promoting equal opportunity and respecting freedom of association. Employees are provided with contracts describing labor and working conditions, and through the induction program are informed of the corporate policies and the Code of Conduct and Ethics. Contractual agreements with contractors require compliance with the Company’s Code of Conduct. EVM’s Code of Conduct and Ethics and the Harassment and Discrimination Policy include rules regarding discrimination, equal opportunity, and the promotion of diversity. These procedures are aligned with PS2.
EVM has a standard contract for personnel, all of which comply with Brazilian legislation and regulations for minimum age, working hours, shift times, overtime payment, rights to privacy, and benefit requirements, in line with PS2 requirements. The Company also supports employees’ professional and personal development through several policies and programs. The Company provide adequate washrooms, drinking water, kitchens and dining facilities for staff. EVM provides food and transport vouchers, extended maternity leave beyond the legal minimum, dental and health plans and life insurance.
The Company has in place collective agreements (2024/2025) with several workers’ unions around the country, allowing the free association of workers, in alignment with PS2 provisions.
Workers Grievance Mechanism
EVM has a confidential complaints channel operated by a specialized and independent third party. The channel is open to all staff, contractors, and stakeholders in general (canalconfidencial.com.br/evolutionmobility/). The channel is available 24 hours via a dedicated website and has a feature to raise anonymous complaints. The sponsor’s ethics commission and shareholders representatives are responsible for the administration of the channel and processes the investigation as per a publicly available whistleblowing procedure. The channel, how to use it and how grievances are managed are communicated to workers during the E&S onboarding, the training on the Code of Conduct, and is available in the Company’s intranet.
Occupational health and safety
Occupational Health and Safety (OHS) risks for the Project are mainly related to EVs maintenance, batteries disposal, and ancillary infrastructure construction. EVM manages OHS risks in line with local and national regulations and permits. As part of ESAP #1, the Company will identify and manage OHS risks and impacts specific to the warehouses where EVs maintenance, batteries management and storage, and construction activities will take place and will monitor OHS performance.
Supply Chain
EVM sources EVs directly from Original Equipment Manufacturers (OEMs). In most cases, OEMs have systems in place to manage risks in the supply chain as it is often a requirement from customers for global players in the auto industry. As per ESAP item #3 the Company will evaluate OEMs’ standards and key components of their supply chain management systems and properly document the findings as part of the due diligence process. EVM will share its vendors’ code of conduct with the OEMs to clearly set expectations regarding standards applied in the supply chain. The obligation for OEMs to be aligned with EVM’s code will be reflected in contractual clauses and legal representations from OEMs. Assessing the alignment or equivalency of OEMs’ systems with EVM’s corporate code will be part of EVM’s ongoing E&S compliance monitoring activities.
PS3: Resource Efficiency and Pollution Prevention:
The Project will reduce the carbon footprint of EVM’s clients by increasing the available fleet of EVs for lease. Pollution risks associated with Company’s activities are mainly related to EVs half-life maintenance, occasional repairs, battery disposal and EVs end-of-life disposal. These activities will be undertaken by EVs dealerships and independent specialized workshops, in compliance with applicable regulatory requirements. These suppliers have a set of management instructions and a hazard identification procedure for waste handling and disposal through licensed waste management companies, which are responsible for the collection, transportation, treatment and final disposal of hazardous waste. EVM performs annual environmental audits to verify compliance with all regulatory requirements and EVM’s E&S sustainability policy.
Going forward, the Company is required to develop a battery management plan to ensure responsible and environmentally sound handling of end-of-life batteries, prioritizing their reuse, repurpose, or recycling to extract valuable materials and minimize waste per national law. Hence, as part of ESAP #1, EVM will develop and implement a battery management program as an update of the waste management plan in line with national law, and requirements of IFC PS3. The objectives of this program will be integrated in the contract with OEMs (ESAP #1).
PS4: Community Health, Safety and Security:
Regarding the protection of clients and communities, as part of ESAP item #4, EVM will develop corporate fire safety and accessibility guidelines to be implemented by the company and provided to customers to minimize fire hazards at EV charging stations. The location of the charging stations will prioritize safety and accessibility, including avoiding areas near buildings, critical infrastructure, or flammable materials, and ensuring easy access for use, maintenance, and emergency responders. Outdoor locations, situated at a distance from buildings, will be used by EVM, while enclosed locations like parking garages or basements will require additional fire safety measures. The guidelines will specify the use of: (i) charging devices certified by a nationally recognized testing laboratory, (ii) appropriate “Level” or type for the EV chargers, (iii) handling the amperage of the charging device, (iv) installing a residual current device with the charging unit, (v) ensuring the EV charging station outlet prevents rainwater from entering, making it safe to charge the EV in wet conditions, (vi) life and fire safety requirements per national building and fire safety codes.
Operation of EVs is out of the scope of the Company's leasing contracts, however, EVM will as per ESAP #5, develop a Road Safety Procedure for its commercial officers that use EVM’s fleet for business commuting across the city, in accordance with ISO 39001, WBG General EHS Guidelines (Section 3.4 - Traffic Safety), and Good Practice standards for Road Safety. This procedure will assess GBVH risks in resting (if applies), adequate signage such as speed limit signs, mechanisms for managing the driver’s fatigue, and safe driving protocols that prohibit cell phone use while driving, highlight dangerous intersections.
