This is a Category A project under IFC’s Policy on Environmental and Social Sustainability (2012), due to the potential for significant adverse environmental and social (E&S) risks and impacts that are diverse, sensitive, and potentially irreversible. Key risks include: (i) the company's management and monitoring systems to assess and manage E&S risks and impacts from the construction and operation of the facilities covered under the project; (ii) worker influx and associated pressures on community health, safety, and public services; (iii) potential impacts on biodiversity and legally protected or priority conservation areas; (iv) sustainability of water use and potential effects on ecosystem services; (v) road safety and community risks related to wood transport logistics; (vi) risks of GBV and SEAH; (vii) monitoring and management of air emissions, waste and wastewater and hazardous materials; (viii) land acquisition and potential physical and economic displacement; and (ix) management of labor and working conditions and occupational health and safety (OHS) policies and practices, particularly among contractors and subcontractors, (x) emergency planning and response.

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

E&S Policies. Arauco’s sustainability strategy is built on five core pillars: renewable products, climate and biodiversity action, local development, people-centered practices, and strong governance. At the corporate level, Arauco has adopted a suite of sustainability and responsibility policies that have elements consistent with the principles of IFC PS.  The Code of Ethics emphasizes integrity, anti-corruption, and legal compliance, while the Human Rights and Diversity, Equity and Inclusion (DEI) policies promote non-discrimination, labor rights, and inclusive workplaces. Environmental stewardship is central to the Biodiversity, Climate Change, and OHS policies, which commit to avoiding, mitigating, and restoring biodiversity impacts through integrated landscape planning and FSC-aligned practices, and highlight ecosystem protection, GHG reduction, and safe working conditions. The Procurement Policy embeds environmental social and governance (ESG) criteria into supplier selection and oversight, fostering responsible sourcing and local development.

E&S Management System (ESMS). The current project ESMS includes elements aligned with the requirements of IFC PS1 and focuses on the pulp mill construction-phase EHS management. A fully integrated ESMS covering all project components (i.e., pulp mill, forestry operations, and associated facilities) needs to be developed. Key gaps include: (i) lack of integration between forestry and processing operations; (ii) limited coverage of social risks such as workforce influx, gender-based violence (GBV), child safeguarding, and community health and safety; (iii) complete a Stakeholder Engagement Plan and a robust grievance mechanism; (iv) risk-based E&S monitoring for forestry operations to be enhanced (v) E&S risks and impact identification procedure aligned only with the national law. Hence, the Company will develop and implement an integrated, risk-based ESMS commensurate with the project E&S risks and impacts, aligned with the requirements of IFC PSs, WBG General EHS Guidelines (2007), WBG EHS Guidelines for Pulp and Paper Mills (2007) and WBG EHS Guidelines for Forestry Harvesting Operations (2007). The ESMS will include policy, risk and impact identification, gender-responsive management programs, stakeholder engagement, emergency preparedness, indicators informed by sex-disaggregated data, and monitoring and review. A formal ESMS documentation for construction and operations will provide evidence of implementation, outlining procedures, responsibilities, and linkages across all project components (ESAP#1).

Identification of E&S Risks and Impacts. Arauco, as part of its ESMS, has established initial processes to identify E&S risks and impacts, including a corporate risk management procedure and risk registers covering both pulp mills and forestry operations. As part of ESAP #1, the Company will augment its procedure for identification of E&S risks and impacts per requirements of IFC PSs. The Company conducts risk and impact identification in alignment with applicable Brazilian legal and regulatory requirements. For the pulp mill construction, the assessment is primarily based on the approved EIA-Rima per national law. Most construction-related permits for the pulp mill are in place, while key permits for associated facilities (i.e., the railway, transmission line, and port terminal) are pending, under review, or expected to be submitted once final design and site selection process are confirmed. Although the Company has initiated the process of identifying E&S risks and impacts, the approach does not yet integrate key aspects related to the project's construction and operations. Also, an integrated risk identification process encompassing all project components has not yet been developed (refer to E&S Management System section).

E&S risks and impacts associated with forestry activities are identified through a dedicated process documented in a preliminary Environmental Aspects and Impacts Survey (known as LAIA in Portuguese), which are generally aligned with the requirements of PSs. The LAIA is under revision and will be integrated into a unified E&S matrix covering both mill and forestry operations. Defined plans for cumulative impact assessment, long-term water resources and community health initiatives, including ecosystem services and road safety, and biodiversity management are yet to be established. These will be addressed by ESAP#4, 15 and 23-26 below.

To align with PS1, Arauco will augment its E&S risk assessment by addressing unassessed risks and expanding the scope to include the railway, transmission line, port, road, and eucalyptus plantation activities, as well as social risks linked to construction and operations. Key actions include: (i) conducting an Ecosystem Services Risk Assessment to evaluate community dependence on water resources (refer to ESAP#15); (ii) complete the E&S Risk Assessment of the plantations aligned with PS1 requirements as part of the ESMS (ESAP#2); and (iii) conducting a GBV Risk Assessment alongside a costed GBV and Child Protection Action Plan (ESAP#3), which will identify key risks and propose mitigation measures across project phases to prevent GBV, respond with better services and stronger referral pathways, while engaging stakeholders and raising awareness through targeted campaigns and youth-focused prevention programs. A monitoring and evaluation framework will foster accountability throughout the life cycle of the project.

E&S Management Programs. Arauco has developed Environmental Management and Monitoring Plans (EMPs) that outline the Company’s approach for managing environmental impacts during the construction of the pulp mill. EMPs comply with regulatory requirements under Brazil’s environmental licensing framework and comprise 24 Basic Environmental Programs (PBAs) mandated by the installation license (LI). EMPs for the railway branch and the T-Line construction are currently under review by the State Environmental Agency (IMASUL). The Company will develop specific EMPs for these components following the approval and issuance of their respective LIs.

To align with IFC PSs (notably PS1, PS2, and PS4), the Company will (i) augment the project’s construction-phase EMPs by developing and implementing social management programs per requirements of PSs, including but not limited to an influx management plan, contractor E&S oversight mechanisms, social management plans, GBV and Child Protection Action Plan, and a stakeholder engagement plan; (ii) develop and implement dedicated E&S management and monitoring programs for forestry operations, addressing specific social and gender risks; and (iii) develop and implement specific E&S management and monitoring programs for the construction and operation of the port terminal (ESAP#4).

E&S Organization Capacity/Competency. Arauco has established a solid EHS organizational structure, covering both pulp mill and forestry. The EHS team is experienced and adequately staffed, with professionals from Arauco and its EPC contractors. The ESG Director reports directly to the CEO of the Project, ensuring independence from operational areas. The forestry EHS team is also well structured, led by a highly qualified director, and continues to scale up its capacity. Management departments reflect a clear division of responsibilities, and the staff demonstrates strong in-house operational capability.

Given the scale and complexity of the Project’s social risks and impacts, there is a need to strengthen the capacity of the social team by increasing the number of team members and skills set. A more robust social organizational structure is needed, with clearly defined roles, responsibilities, and authority to identify and manage E&S risks and impacts, and significant community-related and GBV risks. To align with PS1, Arauco will, as part of EHS organizational structure, enhance the social team’s organizational capacity by defining a team with adequate resources and skills sets, including a review of roles to establish an integrated oversight of both construction and forestry operations, including GBV-related risks, and implement appropriate mitigations measures as needed (ESAP#5).

Emergency Preparedness and Response (EPR). Emergency Response Plans (PAEs) for the mill’s construction were developed per national law and are being implemented by EPC contractors under the supervision of Arauco’s emergency leadership. Each contractor is responsible for preparing a site -specific PAE tailored to the specific risk scenarios associated with their activities. These plans clearly define responsibilities, roles, and functions. All contractors’ PAEs are aligned and integrated with the overarching PAE for the Project, following established guidelines, action hierarchies, and communication protocols. Emergency scenarios addressed in these plans are based on identified environmental aspects, hazards, and risks, and include responses to accidents, near misses, medical emergencies, fires, explosions, natural disasters, and acts of vandalism. Response teams consist of medical personnel, rescue drivers, and site firefighters, and are supported by on-site emergency resources such as ambulances, fire response vehicles, and equipment containers.

EPR - Forest Fires. Forestry operations are also supported by a dedicated Emergency Response Plan prepared per national law. This plan outlines procedures and resource allocation to protect employees and third parties in the event of emergencies. It addresses a wide range of potential risks, including large-scale forest fires, structural fires, natural disasters, and severe accidents. The plan includes an Emergency Response Framework and a Crisis Management Committee, categorizes emergencies by severity, and assigns responsibilities to trained responders (Socorristas) and brigade members (Brigadistas). The Company, as part of the project, will install 19 fire towers equipped with high-resolution cameras by Mid-2025 and replace its system with the Fire Hawk system. Firefighting capacity will be enhanced by including aircraft, helicopters, mobile brigades, and specialized equipment, following best practices from Arauco Chile’s fire management framework (see PS4 section for more details related to community health, safety, and LFS risks to its infrastructure). ERPs for the construction and operations of the railway branch, T-Line, and port terminal will be guided by site-specific ERPs to be developed prior to construction per national law and requirements of IFC PSs.

Monitoring and Reporting. Environmental and labor monitoring during the construction of the pulp mill is being conducted in accordance with construction phase EMPs. Arauco has retained a qualified and specialized third-party specialized company to implement the monitoring program (see PS2 section - Workers Engaged by Third Parties for more details). The Company follows a structured planning process that facilitates effective oversight of all EPC contractors and their subcontractors, with a strong focus on routine inspections and systematic documentation of non-conformities. Inspections are scheduled in advance and adjusted based on identified risk levels. Areas with higher environmental risks are subject to more frequent monitoring, while lower-risk areas or those with consistently good performance are monitored less frequently. Monitoring of social risks and impacts on communities will be integrated in the ESMS (ESAP #1) in alignment with the findings of the assessments required under ESAPs#3, 12 and 19. Environmental and social monitoring for the construction of the railway branch, T-Line, and port terminal will be guided by site-specific EMPs to be developed prior to construction.

Environmental monitoring of forestry activities is currently limited to FSC and legal compliance. As the impacts associated with forestry operations are not addressed under the existing EMPs, the current system lacks comprehensive and systematic coverage of environmental risks, and social aspects have yet to be incorporated, (refer to E&S Management Programs section). Going forward, as a part of ESAP#1, the Company will: (i) develop and implement a dedicated forestry E&S monitoring system to assess the effectiveness of forestry management E&S programs, and (ii) develop and implement a social monitoring system to oversee key social aspects of the project’s forestry operations.

Supply Chain Assessment and Management. No third-party wood is currently being sourced. Arauco plans to gradually supplement its wood supply with material that is either fully FSC/PEFC Forest Management (FM) certified or, at a minimum, FSC Controlled Wood (CW) certified. The CW verification system is still under development and has not yet been implemented (see PS6 supply chain section for more details).

Cumulative impacts. The EIA-Rima prepared for the pulp mill includes considerations on cumulative impacts in accordance with criteria established by the European Commission in 2001. This assessment features the development of an Integrated Environmental Assessment Matrix to evaluate cumulative and synergistic impacts of existing and planned developments within the Paraná River basin segment located in the state of Mato Grosso do Sul. To update the assessment and align the methodology with good international industry practices, including the selection of Valued Environmental and Social Components (VECs), the Project is currently revising the cumulative impact assessment with support from an external consultancy. As per ESAP#4, the Project will incorporate the recommendations from the updated Cumulative Impact Assessment (CIA) into its E&S management plans for the pulp mill and forestry operations. In addition, the Project commits to participating in potential sectoral or regional working groups focused on adaptive management of cumulative impact identified by a CIA.

PS2: Labor and Working Conditions 

As of March 2025, the mill construction had 4,257 active workers of EPC and EPC manager contractors and subcontractors, out of which 5 percent are women. The current estimated peak workforce of app. 13,626 workers is projected for September 2026. Construction is scheduled to be completed in the second semester of 2027. Once operational, the mill will employ app. 942 workers in the mill, with 173 of these being contractors.  Forestry operations for silviculture employed 2,156 workers, comprising 1,457 direct workers (16 percent of women) and 699 through contractors (9 percent of women). Approximately, an additional 1,200 workers are expected to be hired in 2027 for harvest-related activities. Once forestry operations stabilize in 2029, the Project will employ approximately 4,479 forestry workers for silviculture, harvesting and transportation, around 70% will be Arauco’s direct employees and 30% will be workers of forestry contractors.

Human Resources Policies & Procedures. Arauco’s corporate policies, including the Code of Ethics, Integrity Program, and Human Rights Policy, are legally binding for contractors and subcontractors, as outlined in legal agreements. The Human Rights Policy includes provisions for freedom of association, prohibition of child and forced labor, safe and secure workplaces, and diversity, dignity and prohibition of discrimination. The Code of Ethics, which is a corporate document applicable to all branches globally, has been found by IFC to lack explicit measures to enforce zero tolerance for SEAH, violence, and harmful behaviors, and does not clearly state its applicability to third parties. Arauco will develop a Project Code of Conduct to explicitly include contractors and third parties, strengthen commitments to non-discrimination and SEAH prevention, in accordance with the Code of Ethics, Arauco's corporate document applicable to all branches globally. This will be accompanied by sustained awareness-raising and capacity-building initiatives, and consistent reinforcement by Arauco’s senior leadership, mandatory onboarding and refresher trainings about protection from SEAH for all staff and contractors, including senior leadership, and adoption of KPIs to monitor enforcement (ESAP#6).

Working Conditions and Terms of Employment. All workers, whether directly employed by Arauco or by the EPCs and subcontractors, are hired directly without intermediaries. Terms of employment for direct employees and contracted workers are established as per national labor laws and collective agreements with unions and comply with PS2. Monitoring of working conditions such as the verification of contracts, payment of social security benefits and monthly salaries, recording of working hours and overtime is in place and covers both direct employees (monitored by internal auditing team) and contracted workers (monitored by an external service provider). As per ESAP#10, Arauco will assign an independent consultant to conduct a labor audit of the working conditions and terms of employment for all project components, per national law and the requirements of PS2. This audit will assess pulp mill construction activities and forestry operations.

As of March 2025, the construction workforce reached 4,257, while available workers’ accommodation (run by Arauco and third-parties) covered 2,400 beds, of which 2,255 were occupied. The remaining 2,002 workers were housed in hotels or rented residences in Inocência. Currently, 535 beds are available for women, with the possibility of expanding to 1,000 beds depending on demand. In anticipation of the peak construction period in September 2026, Arauco is evaluating strategies to secure workers’ accommodation, including the potential expansion of existing facilities as applicable and increased coordination with local lodging providers.

Arauco supervises both direct and indirect workers’ accommodation for the construction workforce through a third-party service provider, while oversight of forestry-related accommodation is managed directly by Arauco’s staff. In addition, the company arranges accommodation for administrative staff, in hotels and residences in the region.

The accommodation strategy for the peak workforce has yet to be defined in alignment with IFC PS2/PS4 and the IFC/EBRD Guidance Note on Workers’ Accommodation, including the planning and documentation of essential services such as sanitary, laundry and leisure facilities, maintenance standards, life and fire safety aspects and records management. Going forward, Arauco will (i) develop and implement a Workforce Accommodation Management Plan (WAMP) , aligned with IFC PS2/PS4 and the IFC/EBRD Guideline on workers’ accommodation (2009), including the definition of sufficient accommodation facilities consistent with the workforce expansion and specific arrangements for women, to ensure that all accommodations – both directly and third-party managed—meet the standards for infrastructure, services, maintenance, documentation, and worker well-being during both construction and operation phases. As part of the WAMP, Arauco will develop life and fire safety procedures defining design of the accommodation facilities with passive and active fire safety systems in line with the national building and fire safety codes, technical requirements for fire safety monitoring, alarms, evacuation routes and fire safety trainings; (ii) conduct an audit of construction workers’ accommodations against national regulations and IFC/EBRD guidelines on workers’ accommodation (2009) requirements, and develop and implement a corrective action plan, as needed, to address identified gaps (ESAP#7).

All employees, contractors, and subcontractors undergo onboarding training covering administrative procedures, workplace safety, environmental protection, and occupational health, with refresher sessions delivered in line with applicable legislation. While Arauco’s designated training provider delivers these courses, each EPC contractor is responsible for managing their workforce and associated behaviors. Structured training on sexually transmitted infections, substance abuse, and sexual exploitation, abuse, and harassment (SEAH), as well as integration with the Code of Conduct and broader awareness campaigns, are yet to be established. Also, no system is currently in place to monitor the effectiveness of onboarding training. As a part of ESAP#6, to align with PS2 and PS4 requirements, the Company will enhance contractor management and training programs to include mandatory modules on the Code of Conduct, with particular focus on preventing SEAH against women and children in both urban and rural communities. These efforts will be reinforced by periodic awareness campaigns promoting a culture of zero tolerance for all forms of misconduct or violence, targeting employees, contractors, and subcontractors.

Workers Organization. Arauco’s policy on Human Rights emphasizes the right of employees to freely form and join a union without fear of retaliation. The human capital management standards for contractors and subcontractors engaged in the Project require alignment with relevant unions, adherence to existing collective agreements, and negotiation of a unified collective agreement. Key provisions include structured labor relations processes, a dedicated channel for worker concerns, and strict compliance with union requirements. Salary and benefits must conform to union agreements, with mandatory worker training on collective rights. Regular review of collective agreements is required to ensure continued relevance and compliance. Conditions of employment for forestry and construction workers are established by collective bargaining agreements (CBAs) that have been signed with respective trade unions.

Non-discrimination and Equal Opportunity. Female employment in the Project construction stands at 5.4 percent, while in the forestry operations 16 percent of employees and 9 percent of contractors are women. Management attributes the shortfall to labor market segmentation and a lack of skilled women workers but needs to undertake proactive recruitment efforts to address the gender gap. As per ESAP#8 Arauco will implement an Equal Opportunity Plan aligned with its Diversity and Inclusion Policy, with a focus on incentivizing greater female and local youth participation through active recruitment, contractor incentives, and procurement targets. The plan will also address risks for apprentices under 18, ensuring compliance with national law.

Worker’s Grievance Mechanism. The Project workers' grievance mechanism (Canal do Trabalhador - Ouvidoria de Obra) enables employees, contractors and subcontractors to submit complaints via a QR code, the website, toll-free phone, email, or in-person reporting, with options for anonymity and whistleblower protection, and ensures information confidentiality. However, it lacks non-digital channels for those without access to technology, detailed investigation protocols, and specialized procedures for handling SEAH reports. Hence, Arauco will augment its workers’ grievance mechanism in line with the requirements of IFC PS2 by introducing non-digital channels (e.g., complaint boxes), direct project-level contacts, non-retaliation, and a robust SEAH response system with trained personnel, victims-centered procedures, psychosocial support to victims, and minimum representation of women in investigation and decision-making bodies. Monitoring will be improved through structured categories, sex-disaggregated data, and periodic assessments. The mechanism will adopt clear procedures for grievance registration, escalation, resolution, and systemic issue identification, with secure data management. Communication channels will be widely disseminated across accommodations and work fronts of all project components (ESAP#9).

Protecting the Workforce. Arauco, under its Human Rights Policy, has provisions against the use of child and forced labor. Violations of workers’ rights have been previously recorded in Brazil in the forestry sector due to poor living conditions of sub-contracted workers. Mitigation framework of this risk is discussed in the Workers Engaged by Third Parties below.

Occupational Health & Safety (OHS). OHS programs are divided among the pulp mill site construction and forestry operations. Transportation of wood from the forestry areas to the mill is covered under PS4 section below. The Project has developed a comprehensive EHS manual for pulp mill construction, integrating corporate procedures to define responsibilities, manage risks, and guide operational activities. It includes a detailed OHS risk matrix, specific protocols for high-risk tasks (e.g., work at heights, excavation, mobile equipment), and systems for inspections, audits, and KPI monitoring to ensure compliance and continuous improvement. As per ESAP#1, the Company will augment its ESMS to cover the construction of the T-Line and the railway line. Additionally, as the pulp mill construction transitions into operational, Arauco will develop and implement an operational EHS program per national law, EIA-Rima, corporate ESMS (ESAP #1(i)), WBG General EHS Guidelines (2007), and WBG EHS Guidelines for Pulp and Paper Mills (2007). This program will be aligned with the Company’s corporate EHS framework currently applied in forestry operations and will include, but not limited to, (a) hazard identification and risk assessments, including transportation risks related to the regular daily transport of workers from their accommodations to work fronts; (b) procedures for routine and non-routine operations; (c) emergency preparedness and response; (iv) training programs for staff and contractors; and (d) monitoring and continual improvement mechanisms, (f) monitoring and management of air emissions, waste and wastewater and hazardous materials.

Arauco has implemented an OHS management program for forestry operations, aligned with its corporate standards and applicable to employees and contractors. The program emphasizes key safety rules, leadership engagement, and prevention of high-potential incidents. It includes risk mapping and mitigation, inspections, promotion of safety culture, recognition initiatives, and analysis of safety data and incidents. Given the nature, scale, and potential risks associated with the planned wood supply operations, as per ESAP#1 the Company will develop and implement a forestry safety program per requirements of PSs, WBG General EHS Guidelines (2007) and WBG EHS Guidelines for Forestry Harvesting Operations (2007) that includes: (i) identification and assessment of potential hazards (such as physical hazards, noise and vibration, fire, chemical hazards) to workers and affected communities, including life-threatening risks; and (ii) targeted training for harvesting personnel and wood transport drivers to ensure safe operating practices.

Workers Engaged by Third Parties. The project’s contractor and subcontractors’ workforce are governed by Arauco’s human capital management standards, which outline policies for employment conditions, workforce administration, and compliance with labor laws. These standards are legally binding and require alignment with regulatory, operational, and labor requirements, promoting consistent governance and accountability across all third-party entities operating within the project's scope.

The plant is being built on an EPC model, with Valmet overseeing the main process areas, and AFRY managing key BOP components. AFRY is the EPC manager and oversees the performance of the main EPC contractor. Contract clauses include key E&S provisions, such as OHS, legal compliance, and environmental monitoring, and are generally aligned with IFC PS.

Forestry activities, including planting, management, harvesting, and transport, are overseen by Arauco Brazil’s team based in Mato Grosso do Sul state. The Project has already secured 237,000 hectares out of the 400,000 hectares required for operations. The Company will: (i) conduct a labor audit to assess working conditions and terms of employment of contracted workers engaged by third-parties against the requirements set forth in PS1/PS2; and (ii) review the labor monitoring practices of the external service provider, including how non-compliances are reported and enforced (ESAP#10).

To mitigate negative impacts of demobilization on contracted workers and receiving communities, Arauco will prepare a demobilization plan including: (i) a monitoring mechanism to ensure payment of severance package to demobilized workers; (ii) provisions to support demobilized workers (e.g., help with resume, providing information on employment opportunities, documentation of work/training in the Project, etc.); (iii) communication of demobilization timeline to workers, local authorities and local businesses; (iv) proactive programs to ensure re-entry of non-local workers to their place of origin; and (v) monitoring of workers’ liabilities in hosting communities such as unpaid bills and damage compensation (ESAP#11).

PS3: Resource Efficiency and Pollution Prevention 

Energy. The Project will produce bleached eucalyptus kraft pulp and is designed in accordance with Best Available Techniques (“BAT”) standards, including those outlined in the European Union BAT (2001) and World Bank Group’s (WBG) EHS Guidelines for Pulp and Paper Mills (2007). Engineering design is still under development, and will integrate high-efficiency, low-impact technologies. The mill is expected to achieve a high level of efficiency, minimizing wood and chemical use and reducing energy consumption. It includes efficient recovery boilers, extensive vent gas collection systems, energy optimization features such as variable frequency drives, and a heat recovery system. The expected power consumption of 570–706 kWh/ADt fall within benchmarks of WBGEHS Guidelines for Pulp and Paper Mils (2007).

Water. During operations, the mill will withdraw water from the Sucuriú River and 92% of the extracted water will be after on-site wastewater treatment plant returned to the river. As per EIA, specific water consumption per unit of production is currently estimated between 21.2 and 29 m³/ADt, which is within the range of international good practice and WBGEHS Guidelines for Pulp and Paper Mils (2007). The mill’s water consumption rate represents less than 1% of the 7Q10 low flow of the Sucuriú River.

Eucalyptus plantations are not irrigated. Newly planted seedlings receive limited watering using tanker trucks (approximately 4 liters per plant) during planting and may be watered up to four times afterward to support establishment. No ongoing irrigation is conducted once the plantation is established. Arauco has obtained the required water abstraction authorizations from IMASUL, and water use is reported regularly to the authorities. Groundwater level monitoring data in the region has not been updated since 2010. As a part of ESAP#15, Arauco will install a network of piezometers within the plantation areas to enable continuous monitoring of quality and quantity groundwater s and support adaptive management in sustainable water resource use in the project area of influence.

Air Emissions. The main air emission sources from the pulp mill in operation will be the recovery and biomass boilers and two lime kilns, all equipped with high-efficiency combustion and control systems aligned with EU BAT. As per the EIA biomass boilers air emissions will comply with the air emission guidelines of WBG General EHS guidelines (2007). Ambient air quality dispersion modeling using AERMOD and results indicate that air emissions will not result in ground-level concentrations of PM10, PM2.5, SO2, NO2, and CO that reach or exceed relevant national ambient air quality standards. As part of the plant operational EMP and its monitoring procedure, the company will establish real-time air emission monitoring, emissions controls, and emergency response protocols. A continuously ambient air quality monitoring system also will be in place before commissioning.

During construction of the pulp mill, air emissions primarily consist of dust from earth-moving and exhaust fumes from heavy machinery. Dust suppression is being implemented using water trucks, and equipment condition—especially regarding emissions—is verified before being allowed on site. Construction-phase emissions are addressed through specific plans in the Environmental Management Plan (“EMP”).

Greenhouse gas emissions. The Project is expected to sequester significant CO2e annually through natural regeneration in set aside areas and eucalyptus plantations on degraded lands, with continuous replanting on a 7-year rotation and potential for voluntary carbon credits. A significant proportion of the carbon sequestered in the trees will remain in the roots, contributing to long-term soil carbon storage. In addition, carbon in set aside areas will continue to grow. It is estimated that the pulp mill will generate approximately 488.6 MW of renewable energy from biomass, exporting approximately 197.9 MW to the grid—avoiding an estimated approximately 217,736 tons of CO2e annually. It is expected that an additional approximately 55.8 MW will be sold to chemical plants, avoiding another approximately 61,393 tons of CO2e, and that the use of wood for energy will reduce by more than 90% the need for fossil fuels, further reducing emissions. The mill will also compost all organic waste which can be applied to the plantations and reduce future fertilizer use. GHG emissions from forestry and pulp operations are expected to be largely offset by carbon removals (soil carbon and set aside areas) and the renewable energy exported.

Noise: In addition to the noise monitoring conducted during the initial EIA-Rima, an ambient noise monitoring program has been established by Arauco as required by the environmental license. Monitoring will be conducted on a quarterly basis at six designated locations surrounding the site. The program follows the Brazilian standard NBR 10151:2020, and baseline data collected in 2022 showed that background noise levels were generally compliant with applicable standards. The mill is located approximately 50 km from Inocência, and no major population centers exist within proximity to the plant site. As per EIA Noise impacts are expected to be minimal during operations. Nonetheless, the Project will maintain ongoing monitoring and corrective measures, if necessary, in line with its operational EMP.

Wastewater Management. Process effluents from the pulp mill will be treated in an on-site wastewater treatment plant (WWTP) designed with primary and secondary treatment in a biofilm activated sludge system (“BAS”). The WWTP effluent quality is expected to comply with WBG’s EHS Guidelines for Pulp and Paper (2007), Table 1a (kraft bleached pulp), as well as with EU BAT (2001) standards. Real-time effluent quality monitoring systems will be integrated into the WWTP process to monitor effluent quality and allow for timely operational adjustments. The effluent will be discharged into the Sucuriu River through a multi-port diffuser system designed to ensure efficient mixing and dilution, achieving an adequate dilution ratio during low flow conditions. Sanitary wastewater generated by workers’ accommodation will be collected in septic systems. The septic tanks will be designed and installed in accordance with national regulations and will be well maintained and regularly cleaned by licensed and specialized contractors to allow its effective operation

Solid Waste Management. The pulp mill’s construction site currently follows a Waste Management Plan (WMP) prepared per national law and incorporates certain elements of PS3. Waste infrastructure for construction is in place and includes an external storage area, secondary containment structures, and an internal drainage system. Some upgrades are needed to separate drainage systems for incompatible waste and to direct them to the appropriate containment units.

Once operational, the pulp mill is expected to generate approximately 610,050 tons of residues per year (e.g., dregs, grits, lime sludge, ash). Projected residues are well below EU BAT (2001) benchmarks, as Arauco is designing the process as a zero solid waste facility and does not plan to send residues to a landfill. To achieve that, Arauco will implement a Waste Treatment Center (WTC) to manage all industrial waste generated at the pulp mill plant. According to current ESMS and procedures, the primary output will be an organic soil conditioner intended for use in Arauco’s own forestry operations, with the potential for surplus products to be made available commercially.

Non-hazardous waste such as glass, metals, paper, organic material, and tires will be segregated and recycled. Hazardous waste, including spent oil, empty chemical containers, and used batteries, will be disposed of by authorized contractors. Although the Operational Waste Management Plan has not yet been finalized, the Project’s waste strategy aligns with the best available techniques.

Hazardous Materials. Current hazardous materials handling practices at the construction site are generally aligned with good international practice. A Hazardous Materials Management Plan (“HMMP”) as part of construction EMP, is in place and is largely consistent with the requirements of PS3. The plan includes procedures for safe handling, storage, and transport of hazardous materials. For the operational phase, a Hazardous Materials Management Plan, as part of the operational EMP will be prepared and implemented prior to plant commissioning.

In forestry operations, hazardous materials (e.g., pesticides, fertilizers, fuel, and lubricants) are managed through operational procedures rather than under a comprehensive HMMP. These procedures focus on specific aspects such as chemical transport and pesticide application, but do not yet cover the full lifecycle of hazardous materials from acquisition to final disposal.

Pesticide Use and Management. Arauco has implemented an Integrated Pest Management (IPM) program aligned with good international practices, ensuring safe and responsible agrochemical use in its forestry operations. The program prohibits WHO Class 1a/1b and banned pesticides, with controls in place at procurement. Only FSC-approved products are used, and field inspections confirm proper storage and labeling. The main pest threat is the leaf-cutting ant, managed through manual and mechanized methods using liquid or bait treatments, applied from pre-planting through the early years of the tree cycle based on pest activity.

PS4: Community Health, Safety and Security 

Project inducted migration. The accelerated construction and worker influx has intensified social risks and impacts in Inocência including increased pressure on public services, rising rental prices, and concerns related to SEAH. While the Socio-Environmental Strategic Plan (PES) developed by Arauco, in collaboration with local and regional policymakers, provides a medium-term framework to address social infrastructure gaps in the municipality, it does not completely  mitigate these risks and impacts. Arauco will conduct an Influx Risk Assessment and Situation Analysis to develop and implement a Labor Influx Management Plan. This will include assessing the impacts of worker influx on local services (healthcare, housing, social services, public security), identifying capacity gaps, and implementing short-term mitigation measures such as, but not limited to, temporary personnel, additional lodging, partnerships, and training. The plan will analyze in-migration dynamics, environmental, social and gender-related risks, assess institutional capacity, and map stakeholders for coordinated responses. Strategic measures will be defined to manage labor influx in alignment with the Project timeline. Findings will be consolidated into a comprehensive plan detailing mitigation measure, roles, timelines, budget, monitoring frameworks, and KPIs (ESAP#12).

Infrastructure and Equipment Design and Safety. Arauco has planned several infrastructure improvements to mitigate community health and safety risks and support regional development aligned with PS4. These include road upgrades, a private road to divert wood transport from public routes, and a railway connection to reduce truck reliance. Additional measures include a forest fire detection and response system and support for expanding local health infrastructure, particularly in Inocência.

Road safety. Arauco has conducted detailed road assessments to evaluate capacity and safety requirements for community roads used during construction and future wood transport. Planned upgrades include paving unpaved roads, adding passing lanes, and constructing a viaduct at the mill entrance to reduce traffic hazards. The wood transport system will rely on bi-, tri-, and hexa-train trucks. To minimize community exposure, a dedicated internal road and two bridges are planned, although land acquisition and permitting remain pending. While infrastructure planning aligns with PS4, an assessment of road safety risks for affected communities, including an assessment of GBV hot spots on the routes, has yet to be completed. Arauco will develop and implement a Road Traffic Safety Risk Assessment and Road Traffic Management Plan in accordance with WBG General EHS Guidelines (Section 3.4 - Traffic Safety), and Good Practice standards for Road Safety, covering public and private routes and incorporating mitigation and monitoring measures as applicable. This will include, but not limited to, procedures for routine and non-routine operations, including transportation risks related to the regular daily transport of workers from their accommodations to work fronts (ESAP#13).

Life and Fire Safety (LFS): The pulp mill design complies with national building and fire safety codes. The pulp mill construction site is equipped with two ambulances (one basic life support and one ICU), a rapid response vehicle, and a water truck for fire emergencies. Four emergency containers with response equipment are strategically positioned across the site. These measures are integrated into Arauco’s corporate ERP management system, which includes defined roles, procedures, and regular emergency drills.

Forestry operations are supported by an Emergency Response Plan and a fire detection and combat system, expected to be fully operational by mid-2025. The system includes 19 monitoring towers with high-resolution cameras, meteorological stations, mobile command units, and aerial and ground firefighting resources, including 97 trained firefighters. This system is part of Arauco’s structured emergency response framework at both corporate and operational levels. To align with PS 1 and 4, Arauco will enhance its forest fire detection and response system by incorporating community participation in emergency preparedness exercises (e.g., simulations and drills). The updated plan will define communication protocols with neighboring communities and establish joint preparedness initiatives with local stakeholders (ESAP#14).

Management of Ecosystem Services. Arauco has implemented a water quality monitoring plan and initiated baseline sampling, with monthly collections conducted between May 2024 and January 2025. The hydrological watershed monitoring program is currently under review and has not yet been implemented. Potential impacts of forest management on surface water bodies in eucalyptus plantation areas have not been assessed, and groundwater level monitoring in forestry zones remains pending. To align with PS4, Arauco will develop Ecosystem Services Risk Assessment for all project related operational areas, focusing on water resource dependence for communities, including surface and underground water quantity and quality (mills operations, soil preparation, etc.) and potential impacts on surface and groundwater availability. Outcomes of Ecosystem Services Risk Assessment will be reflected in the operational EMPs of the pulp mill and forestry operations, as needed (ESAP#15).

Security Personnel. Arauco’s assets, including the construction site, worker accommodations, and forestry facilities, are secured by contracted security services. A trained security firm with experience in housing camps has been engaged to support the Project and contractor accommodations. The use of firearms and force is strictly prohibited, and any incident must be referred to local police authorities. All personnel, including contractors, are bound by Arauco’s Code of Ethics, which promotes respect for community relations. The Company will conduct a Security Risk Assessment and will develop a Security Management Plan aligned with IFC PS4 and WBG Good Practice Handbook on Use of Security Forces to ensure all security providers are contractually bound to PS4 principles, receive training on human rights, SEAH prevention, grievance redress, and compliance monitoring (ESAP#16).

PS 5: Land Acquisition and Involuntary Resettlement

The Project is in the state of Mato Grosso do Sul, in an area that is predominantly composed of large properties used for livestock farming and eucalyptus plantations. Farms typically have a few houses for permanent workers and their families, along with temporary housing for seasonal labor during planting and harvesting.

When fully established, the total gross land area associated with the forestry plantation and set-aside requirements for environmental conservation, roads, and related infrastructure is expected to be app. 500,000 ha. The land is not contiguous and consists of a mosaic of land parcels spread out over a large area. The total land area for the pulp mill is 681.47 ha as a single block. All the Project (pulp mill and forestry operations) land is being acquired or being object of land usufruct rights (direitos reais de usufruto, in Portuguese language) or land surface rights (direitos reais de superficie) through willing-buyer willing seller transactions with private landowners.

The acquisition of four urban properties for the pulp mill was completed in 2024 prior to the start of construction. With respect to the forestry operations, between 2009 and 2025, Arauco completed the acquisition/ leasing (usufruto in Portuguese) of 138 properties (associated with 237,000 ha of land). Private owners voluntarily agreed to negotiate their land, land usufruct rights or land surface rights and assets, and there was no threat of expropriation. Land transactions were based on fair market values determined by independent appraisals conducted by specialized firms and all agreements were negotiated directly with landowners with no intermediaries or agents used.  All acquired or object of usufruct rights and/or land surface rights plots were delivered to the project free of any dependencies or encumbrances, were deemed free of legal claims or land disputes and have had the transfer of land titles completed.

The transmission line requires the establishment of a 50-meter-wide right-of-way (RoW) along its 91.3 km length, representing around 426.4 ha of land. A Public Utility Decree has been established for the acquisition of the RoW transmission line in December 2024. Following an alternative analysis, the selected alignment has avoided both physical and economic displacement of households. In total, 40 privately owned properties have been identified as affected, out of which 36 had been acquired at the time of the appraisal. The remaining 4 properties are under negotiation. The acquisition of the transmission line RoW is being undertaken using negotiated settlements with recourse to expropriation as allowed under Brazilian legislation if needed. Compensation for the RoW is based on market valuations conducted by a specialized firm.

The railway line route is expected to cover approximately 47 km, with an 80-meter-wide RoW corridor, representing around 376 ha of land. In total, 38 privately owned properties have been identified as affected. A specialized firm has conducted preliminary valuations of these properties and to date, two properties have been acquired; for the rest, negotiations with owners are on-going. The acquisition of the railway corridor RoW is being undertaken using negotiated settlements with recourse to expropriation as allowed under Brazilian legislation if needed. A Public Utility Decree will be established for the RoW on 32. As per ESAP#17, the land valuation assessments will be updated to account for all assets and crops impacted by the RoW and provide compensation for lost assets at full replacement cost, consistent with PS5 requirements. In case of physical and/or economic displacement, Arauco will develop a Resettlement and Livelihood Restoration Plan (refer to ESAP #19).

To manage usufruct or surface rights’ land acquisition, Arauco has developed the Procedure for Contracting New Rural Properties, which outlines a structured approach for identifying, assessing (legal, technical, regulatory, environmental, and physical feasibility), valuing, negotiating, and formalizing land usufruct and surface rights’ agreements for rural land.  However, the current procedure does not include the collection of socioeconomic baseline data on land users or an assessment of their tenure arrangements and relationship with landowners. These gaps limit the ability to identify and mitigate any potential risks of physical and/or economic displacement, as required under PS5.

As per ESAP#18, Arauco will revise and expand its Procedure for Contracting Rural Properties to ensure its applicability across all Project components in line with PS5. The updated procedure will include: (i) guidance on expropriation processes specific to linear infrastructure; (ii) a clear methodology for land and asset valuation; (iii) measures to prevent adverse impacts on Indigenous Peoples and traditional communities in the event these are identified as part of the land usufruct or surface’acquisition for the forestry activities and other project components; (iv) provisions to avoid physical and economic displacement wherever possible; (v) requirements to conduct socioeconomic baseline surveys and assess land tenure arrangements; (vi) procedures for identifying individuals and groups affected by physical and/or economic displacement other than the owners of the properties; (vii) protocols for meaningful consultation and culturally appropriate, accessible grievance mechanisms; and (viii) definition of roles and responsibilities. The updated procedure will be applicable to ongoing and future land   usufruct or surface rights’ acquisition related to the Project and its Associated Facilities.

As per ESAP#19, Arauco will develop a Resettlement and Livelihood Restoration Framework (RLRF), consistent with PS5, outlining general principles that will be followed in case of physical and economic displacement associated with the Sucuriu Project. The RLRF will define the need for a Resettlement and Livelihood Restoration Plan to manage impacts associated with ongoing and future “usufruct” or surface rights’ land acquisition. In addition, Arauco will enhance and disclose its grievance mechanism to allow people affected by land negotiations (including tenants, caretakers, sharecroppers, informal users) to share any concerns or grievances associated with past, ongoing and future “usufruct” or surface rights’ land acquisition. A Social Assistance Program to manage any ongoing residual impacts to these people will be implemented if applicable.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources 

Protection and Conservation of Habitats. The Project is located in the Cerrado ecoregion, hosting high levels of endemic flora and fauna. The Project aims to manage app. 400,000 ha of eucalyptus plantations by 2031, out of a total land base of ~500,000 ha, including mandatory set asides (20% of Legal Reserves required in this region plus Areas of Permanent Preservation). There are no internationally recognized areas within the Project woodshed (i.e., ~150 km radius from the mill site), although there are several overlapping Legally Protected Areas, mainly Environmental Protection Areas - APA (IUCN Category V).

Arauco’s Biodiversity and Ecosystem Services policy commits to compliance with FSC® principles and criteria and local environmental regulations. The Project aims to FSC-certify all production, thus committing to a July 2020 deforestation cutoff date. Any legacy issue related to mandatory set asides, such as Legal Reserves and Areas of Permanent Preservation, as well as other environmental liabilities (e.g. soil erosion) are identified for remediation and/or compensation, as required by law. Also per FSC criteria, Arauco has already set aside 500.75 hectares of Natural Habitat in addition to 2,757 ha from other mandatory set asides as a High Conservation Value Area (HCVA Fazenda Lobo). The Company will supplement its screening procedures aimed at vegetation mapping and characterization to ensure alignment with IFC PS6 definitions of Natural Habitat, to be applicable in the selection of new plantation areas (ESAP#20).

The proposed mill, approximately a third of the T-Line, the new railroad segment and some of Arauco’s plantations overlap the APA Municipal da Sub-bacia do Rio Sucuriú, as well as other four neighboring municipal APAs, in which forestry operations are permitted. Arauco will engage with administrative authorities of Legally Protected Areas to develop additional conservation actions aimed at supporting biodiversity conservation in those areas (refer to ESAP#23).

Arauco’s biodiversity baseline (i.e. EIA-Rima and other biodiversity monitoring) has identified several priority biodiversity values associated with the Project area, including the Globally Critically Endangered (CR) Killifish Melanorivulus egens; the Globally and Nationally Endangered (EN) Crowned Solitary Eagle (Buteogallus coronatus), the scarabeid beetle Dichotomius eucranioides, and the Killifish Melanorivulus scalaris; the Globally EN and Nationally CR Electric fish Tembeassu marauna; the Globally EN and Nationally Vulnerable (VU) Marsh Seedeater (Sporophila palustris); as well as other four Globally VU species of mammals, four of birds and one of reptile. A preliminary assessment indicated the Marsh Seedeater, D. eucranioides, M. egens, M. scalaris and T. marauna as likely Critical Habitat values for the project area. Arauco will complete a Critical Habitat assessment based on engagement with relevant experts and primary data collection, as relevant (ESAP#21). No direct adverse impact from habitat conversion or degradation is expected on these species, as remnant Natural Habitat for terrestrial species will be set-aside for protection, and wetlands and other freshwater habitat for the aquatic species are among mandatory set asides per Brazil’s legislation.

Arauco’s woodshed contains mostly Modified Habitats, consisting of established pastures dominated by exotic grasses. Remnant Natural Habitat in the rural landscape consists mostly of mandatory set asides required per Brazil’s Forest Code. A preliminary assessment of Natural Habitat per PS6 definitions identified that No Net Loss would also apply for 2,896.43 hectares lost since 2020 to Project operations, of which ~47% (1,368.42 ha) correspond to initial stages of Cerrado regeneration over pasturelands.

Per ESAP#22, as part of the Project’s Environmental and Social Management Plan (ESMP), Arauco will hire competent professionals to develop a Biodiversity Management Plan, to encompass all biodiversity-related actions during both the construction and operation stages of the Project, including (i) the development of mitigation and monitoring plan to facilitate fauna crossings in the gallery forest of the Sucuriu river, with emphasis on primates; (ii) identify fauna roadkill hotspots and develop of a comprehensive strategy to mitigate roadkill incidents; (iii) adoption of a raptor safe design for the 230 kV transmission line to prevent bird electrocutions, and installation of flapper bird flight diverters to prevent bird collisions; and (iv) a Biodiversity Monitoring Program to verify effectiveness of mitigation measures. Arauco will adapt its management practices based on the monitoring results.

Arauco will hire competent professionals to develop a Biodiversity Action Plan (BAP), acceptable to IFC (ESAP#23). The BAP will include (i) the development of a strategy for achieving No Net Loss and Net Gain, including priority biodiversity values, (ii) loss and gain calculations and proposed offsets; (iii) an offset program based on the principles of equivalence (like-for-like or better), additionality and permanence, as well as monitoring requirements to ensure its effectiveness; and (iv) additional conservation actions aimed at supporting biodiversity conservation objectives of the Legally Protected Areas situated in the project’s areas of influence. Arauco will engage with administrative authorities of such Legally Protected Areas to identify pertinent actions.

Ecosystem Services. FSC® certification requires the maintenance or improvement of attributes of High Conservation Value (HCV) areas. HCV are identified based on E&S criteria, including the provision of critical ecosystem services (e.g., watershed protection, soil erosion control) (HCV4), and areas that are fundamental to meet the basic needs of local communities (e.g., subsistence, health, water, nutrition) (HCV5), or of cultural significance (HCV6). As part of the FSC® certification process, the Company will (i) continue to identify priority ecosystem services (e.g., water use) and assess impacts and dependencies; and (ii) finalize the implementation of a paired watershed hydrological monitoring program, contemplating groundwater and surface water measurements. This work will be further strengthened by the Ecosystem Services Risk Assessment requested in ESAP#15. Arauco will adapt management plans based on monitoring results.

Sustainable Management of Living Natural Resources. Arauco’s Sucuriú plantations will adhere to responsible forest management covered by FSC® certification standards. To date 60,904 hectares (~53%) out of the current Sucuriú forest managed land base (115,000 ha) is FSC certified, with a plan to ramp up to full FSC FM certification by 2028. All new usufruct or surface rights’ land acquisition areas are planned to be certified one year after planting.

Supply Chain. The Sucuriú forestry land base currently counts with 40,400 hectares (17% of net effective plantation area) owned by Arauco. Landholding growth is attained through land usufruct or surface rights’ acquisition under Arauco management, currently totaling 180,800 hectares (76% of net effective area), in addition to long term wood supply arrangements with forest funds Falcao / BTG-Pactual, providing 15,600 hectares (7% net effective area), and DRS/STCP providing 400 hectares (net effective). The Project will, over time, supplement its wood supplies through third-party sources. The project’s CW verification system is under construction, though no third-party wood is being supplied to date. Arauco counts on ample team experience and corporate support to build an adequate and FSC-certifiable CW system. Per ESAP#24, Arauco will enhance its FSC certifiable third party Controlled Wood Verification System to include PS6 requirements aimed at preventing significant conversion of natural and critical habitats. The system will align with FSC, PS 2 and 6 requirements, including: (i) documented due diligence procedures; (ii) traceability mechanisms; and (iii) controls to avoid sourcing from unacceptable or high-risk areas.

Arauco has undertaken information-sharing and consultation initiatives regarding the Project, including legally required public hearings as part of the Environmental and Social Impact Assessments (ESIAs) for the mill and transmission line were presented. In December 2023 and June 2024, the Company held open meetings with the community, local authorities, and the City Council of Inocência to report on Project progress, gather feedback, and present strategic planning and mitigation initiatives. Additional efforts include targeted consultations with directly affected communities ("Escutas com a Comunidade") and broader biannual public meetings ("Encontros Abertos"), as well as outreach to communities surrounding the forestry operations (“Bom Vizinho”). While these activities contribute to information dissemination, they are not embedded in a formal Stakeholder Engagement Plan linked to Project risks and impacts and there is no established mechanism for providing feedback to participants.

As per ESAP#25, Arauco will develop a Stakeholder Engagement Plan (SEP) for all Project components per requirements of PS1. The SEP will include the following elements: (i) Company’s description; engagement principles, objectives and criteria; (ii) local regulations and international requirements; (iii) description of key social and environmental risks and impacts; (iv) summary of previous engagement activities; (v) identification, analysis and prioritization of stakeholders, focusing on those directly affected and identifying any vulnerable individuals or groups; (vi) engagement program describing activities that will be conducted by Arauco during construction ; (vii) description of Arauco's grievance mechanisms and description of how Arauco will monitor contractors’ grievance mechanisms; (viii) timeline, resources, and responsibilities. The SEP should also include cross references to other relevant management plans implemented by the Company to manage E&S risks and impacts. The ESG Director will ensure proper implementation of the SEP as well as management and expansion of the Community liaison team as needed throughout the construction and operation phases of the Project. The Company will update the SEP for the operations phase.

Community Grievance Mechanism. Arauco currently manages community grievances through corporate channels (website, toll-free number, WhatsApp), the "Bom Vizinho" program (neighbor visits), in-person interactions with forestry and visitor teams, and the Casa Arauco kiosk in Inocência. Grievances are recorded in the portal ‘Painel de Gestão’ and handled per corporate procedures (Procedimento de Denúncias) and the Code of Ethics. As per ESAP#26 Arauco will enhance the community grievance mechanism to include: (i) a grievance handling procedure consistent with IFC PS1; (ii) disclosure of the mechanism to all identified stakeholders; (ii) additional channels that allow for submission by those without access to technology (e.g. suggestion boxes at central locations like municipal offices); (iii) analysis of systemic issues; (iv) feedback mechanism to communities; (v) guidelines for resolution, response and coordination with operations; (vi) specific procedures to handle SEAH reports with a survivor-centered approach, designed to avoid revictimization, support survivors and refer them to specialized GBV and/or child protection services duly mapped in the Project area; (vii) a collegiate instance for grievances investigations and decision-making requiring a minimum representation of women; (viii) training staff for consistent implementation of the grievance mechanism, including specific training to handle SEAH-related reports; and (ix) periodic monitoring of the grievance mechanism with defined KPIs. The grievance mechanism per PS1 will be extended to those affected by land acquisition (refer to ESAP#19).

Contact Person: Theófilo Militão, Marcelo Reyes, Betania Vilas Boas

Company Name: Arauco Celulose do Brasil

Address: Av. Alfredo Egidio de Souza Aranha, 100

Email:  teophilo.pereira@arauco.com; marcelo.reyes@arauco.com, betania.boas@arauco.com