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
Environmental and Social Policies, Risk Assessment, Management System, Monitoring and Reporting. OCI TRS have developed policies on Environment, Occupational, Health and Safety (OHS), and human resources (HR). The company complies with the national regulatory process for the E&S risks and impacts identification and assessment, including Environmental Impact Assessments (EIA) for all existing or under construction facilities. The EIA for the current OCI TRS’s plant covered a total manufacturing capacity of 68,000 tpa Polycrystalline Silicon with product purity up to eleven 9s. With the addition of OTSM, the total capacity will still remain under 68,000 tpa, hence a fresh EIA was not required. The EIAs have covered industry-specific SHE and social impacts. These included quantitative risk assessment (QRAs) for each manufacturing facility. However, key gaps against IFC PSs and applicable WBG EHS Guidelines include additional required process safety assessment/study (e.g., LOPA and SIL), and Process Safety Management Plan, key gaps of landfill siting and design. In addition to regulatory EIA processes, the companies have conducted detailed facility-level EHS hazard identification and risk assessment analyses. At the facility level, OCI TRS has developed a series of standard operating procedures (SOP) related to environmental, human resources (HR), chemical management; safety, health and environment (SHE); emergency preparedness and response (EPR); life and fire/explosion safety (L&FS) management. Although the company has not developed a set of key performance indicators (KPI) and targets for the EHS aspects, it has implemented a structured and standardized approach to monitor and measure EHS performance, supplemented by internal and external assessment/audit, and management review. The SOPs are updated continually to ensure compliance with national EHS and labor regulations, certification of management systems; and to reflect changing operational and risk contexts, and experience from implementation in day-to-day operations. This approach will be similarly applied to the new OTSM. As part of this investment, OCI TRS will (i) update its E&S policies, including the Supplier Code of Conduct (ref. ESAP#7), with commitment to aligning its E&S performance with IFC PS and relevant WBG EHS Guidelines (ESAP#1); (ii) establish a set of EHS KPI and targets to monitor performance and improvement (ESAP#2); and (iii) upgrade their existing ESMS to address all the gaps and shortcomings identified throughout this review to align their procedures and performance with IFC PS and relevant WBG EHS Guidelines (ESAP#3), including in particular, updated HAZOP and Layer of Protection Analysis (LOPA) assessments and Safety Integrity Level (SIL) Classification study (ref. ESAP#16); upgraded Hazardous Materials Management Plan (ref. ESAP#17); and gap analysis of current landfill siting and design and management and engineering measures (ref. ESAP#18). OTSM will draw upon the updated ESMS from OCI TRS, adapt, adopt and implement an IFC PS-compliant ESMS for its respective construction and operation (ESAP#4).
Organizational Capacity and Competency. The company’s SHE department is responsible for management of the environment and OHS, ensuring compliance with national and internal regulations and promoting a safe working environment. The SHE Department comprises of one SHE Manager, one environment and one OHS staff dedicated to SHE management. Further, SHE department is supported by a range of functionally specialized departments/sections. The Special Affairs Department is responsible for stakeholder engagement activities. The Environmental Management Plan clearly defines the roles and responsibilities of each company’s member. During operation, the company maintains certified professional for specific operations. Roles and responsibilities of contractors, subcontractors, environmental consultants and laboratories are also defined. OCI TRS defines SHE training requirements, based on which, annual training plan is developed, including a completion tracking matrix and daily toolbox talks. The company has formally established dedicated Medical Units at site, comprising of one doctor, one assistant medical officer (AMO), one occupational health nurse, eight clinical staff dedicated to medical services and one ambulance, supported by International-SOS. However, the site is situated approximately 70km from the closest hospital in Bintulu. OCI TRS will assign an E&S representative, whose responsibility will be overall E&S leadership to upgrade and enforcement of the ESMS in accordance with IFC PS requirements, WBG EHS Guidelines. OTSM will establish a SHE team with sufficient resources and capacity commensurate with the risk of its operation. (ESAP#5).
Emergency Preparedness and Response. OCI TRS has developed a detailed and comprehensive Emergency Preparedness and Response (EPR) plan. The sites are also equipped with detectors and alarm system for hydrogen, chlorine, and hydrogen chloride (HCl). The EPR includes specific plans for fire and explosions, spillages, gas leaks, injury and illness related accidents, and emergencies related to confined space entry, working-at-height, hot works, toxic chemical release and plant shutdown. However, the EPR does not include any natural disasters (floods, heavy rain/ bad weather, haze/ air pollution). OCI TRS conducts quarterly internal fire drills and desk-top exercises with the local Fire Department joining once a year. In addition, the company conducts hazardous materials/gas leak drills and confined space rescue. The EPR teams have been established and supported by multiple functional units. An Emergency Response Plan for major accidents was also prepared as part of the Control of Industrial Major Accident Hazards (CIMAH) report. As part of this investment, OCI TRS will update its Emergency Response Plan to include natural disasters, climate-related events and communicable diseases and provide training and drills for all possible emergencies. OTSM will draw upon the updated EPR from OCI TRS, adapt, adopt and implement an IFC PS-compliant EPR for its respective construction and operation (ESAP#6)
Supply Chain. OCI TRS and OTSM source key materials (e.g., Metallurgical Silicon powder) and services for its major product lines mainly from local based vendors and non-Chinese foreign suppliers. All suppliers and contractors are required to sign the Supplier Code of Conduct (SCoC), including the prohibition of forced/child labor. However, the SCoC does not include the provision to prohibit significant conversion of natural and/or critical habitats. The company will (i) update the SCoC regarding IFC PS6 requirements on supply chain; and (ii) strengthen the supplier screening and evaluation process for labor and working conditions, prohibition of child labor and forced labor, OHS and prohibition of significant conversion of natural and/or critical habitats (ESAP#7).
PS2: Labor and Working Conditions
As of November 2025, the OCI TRS employed 1,103 direct employees of which 83% are men and 17% are women, and 2,026 contractor workers. The largest groups of contractor workers come from Indonesia, Nepal, and Myanmar, among others. For the OTSM construction site, construction is being undertaken by EPC contractors with a total of 240 workers, mostly coming from Bangladesh, Indonesia, and India. After production commences, OTSM will have a total workforce of 480 employees, including 280 contracted workers.
Human Resources Policies and Procedures. OCI TRS has developed HR policy and procedures as per national law requirements and generally in line with IFC PS2. The Employee Handbook, which is distributed to all employees upon onboarding, covers aspects such as appointment, probation, performance appraisals, termination, work hours, leave entitlements, compensation and benefits (including salary, medical benefits, allowances, and statutory contributions), workplace conduct, and adherence to safety protocols. As per ESAP#8, OCI TRS will revise its Employee Handbook to explicitly include: (i) prohibition of child labor and forced labor; (ii) provisions on working hours, including paid rest breaks and a clear prohibition on deducting rest periods from total working hours or overtime calculations, and overtime limits, specifying that overtime is voluntary, and employees have the right to refuse overtime; (iii) workers have the right to freedom of association and collective bargaining as per national law; and (iv) retrenchment procedures will be aligned with IFC PS2 requirements. OTSM will draw on the updated HR policies and procedures developed by OCI TRS to establish its own HR policies and procedures that comply with IFC PS2 requirements for its respective operations.
Working Conditions and Terms of Employment. OCI TRS applies differentiated working hour arrangements for administrative and operational personnel, with standard office schedules and extended shift-based operations for production lines. Production shifts include both daytime and nighttime rotations under a structured 12-hour shift model, with scheduled rest breaks embedded in each shift. Overtime work is capped and compensated at premiums according to the national regulations. Remuneration meets statutory minimum wage requirements, and employees are eligible for supplementary allowances related to shift work, location, and competency level.
Workers’ Organization. At the time of appraisal, OCI TRS did not have a Trade Union. Going forward, OCI TRS and OTSM will update its HR policy and procedure to include freedom of association and right to collective bargaining and will advertise it internally to ensure that all employees are fully aware that they can feel comfortable forming or joining a workers’ organization of their choosing (ref. ESAP#8).
Non-discrimination and Equal Opportunity. In accordance with OCI TRS’s Human Rights Management Regulation, discrimination in any form is prohibited in recruitment, training, performance evaluation, compensation, benefits, promotions, and all other employment conditions. These corporate-level requirements are incorporated into the Employee Handbook.
Gender-Based Violence and Harassment. In accordance with OCI TRS’s Workplace Harassment Prevention Procedure, the company enforces a zero-tolerance policy for harassment and retaliation. To further align with IFC PS2, OCI TRS and OTSM will strengthen the existing harassment prevention policies and procedures to include (i) a clear definition and explanation of gender-based violence (GBV) in the workplace and GBV Code of Conduct; (ii) updating grievance handling process to allow for multiple entry points, including anonymous complaints, and provide alternative support for complainants; (iii) conducting training on the updated GBV and sexual harassment policies; and (iv) incorporation of GBV in contractor management plans. (ESAP#9)
Grievance Mechanism. OCI TRS has implemented a worker grievance mechanism (WGM) to handle complaints. Workers are accouraged to report grievances to their immediate supervisors, and if the issues remain unresolved, it can be escalated to higher levels of management/ a grievance committee. As per ESAP#10, OCI TRS and OTSM will strengthen the existing WGM policies and procedures to incorporate (i) a clear definition of non-retaliation and identity protection; (ii) multiple intake points to enable anonymous complaints to be raised and addressed; (iii) a clear resolution timeline and escalation process that aligns with the severity of grievance issues; (iv) a clear process for appeals; (v) a commitment to extend access to the grievance mechanism to third-party workers if necessary; (vi) a commitment that access to other judicial or administrative remedies remains unobstructed once a grievance is filed; and (vii) a clear definition of transparency by keeping workers informed about the steps taken, decisions made, and the rationale behind them.
Workers Engaged by Third Parties. As of November 2025, OCI TRS engages 2,026 third-party workers, consisting of 1,651 men and 375 women, through 45 contractors to support ongoing plant operations. These workers are involved in a wide range of responsibilities, including skilled technical work, packaging and production activities, security services, and other operational activities. Of these, 494 are migrant workers. They are provided with regular employment contracts with renumeration at or above the statutory minimum wage. For the construction of the OTSM plant, third-party contractors also source migrant labor from Bangladesh, Indonesia, India, and other countries. These workers are accommodated in Bintulu and nearby areas. The screening of contractors falls under the Supply Chain and Vendor Management System, with procurement team conducting annual monitoring to ensure compliance with various aspects. Additionally, contractors are required to sign the SCoC. OCI TRS and OTSM will strengthen its contractor management system (CMS) to ensure full alignment with IFC PS2 and national labor laws. This will include: (i) integrating PS2 obligations into all contractor and subcontractor contracts; (ii) enhancing contractor audit tools to cover forced labor, recruitment and use of agent practices, leave practices, GBV, and worker accommodation; (iii) developing a training and advocacy program to build contractor awareness of PS2 and SCoC requirements; and (iv) improving the capacity of the relevant teams responsible for overseeing contractor performance. The CMS will be developed to define EHSS requirements, selection and monitoring processes, contractor worker grievance mechanisms, and worker accommodation standards in line with IFC and EBRD’s Guidance Note on Worker’s Accommodation: Processes and Standards for third party workers. (ESAP#11)
OCI TRS and OTSM will ensure that no migrant worker engaged through contractors or subcontractors is required to pay recruitment or placement fees or related costs, wages are not withheld when workers go on leave/end of contract and that all workers retain full and unrestricted access to their passports and personal identity documents at all times. As part of their CMS, the companies will (i) revise contractor management procedures and contract clauses to explicitly prohibit the charging of recruitment fees, wage withholding during leave, and the retention of workers’ passports or identity documents by contractors, subcontractors, recruitment agencies, or their sub-agents; (ii) require all contractors to adopt a zero-fee recruitment policy, no wage-withholding policy and a no-passport-retention policy, with secure voluntary storage options where workers retain full control; (iii) conduct due diligence and periodic monitoring of contractors’ recruitment, wage retention, and document-handling practices to verify compliance; (iv) conduct a review of overtime calculations to demonstrate compliance with national laws; and (v) communicate these requirements to all contractors and workers in languages they understand. (ESAP#12)
Occupational Health and Safety. OCI TRS revised its Safety Management System (SMS) manual in August 2025, aligning it with ISO 45001 standards. The SMS is reinforced by a set of Occupational Health & Safety (OHS) operating procedures to ensure effective implementation. In addition, a General Safety Management System has been established to cover all employees, visitors, and contractors. As part of site entry requirements, contractors are required to attend an OHS briefing before commencing work. OCI TRS has completed all the risk assessments as required under the Malaysian legal requirements and IFC PS’. Chemical Health Risk Assessment (CHRA) was completed in May 2020 and is currently undergoing a revision. All assessments associated with the CHRA have also been completed by OCI TRS such as chemical exposure monitoring and local exhaust ventilation assessment. Noise Risk Assessment and Audiometry for all affected employees were completed. Where cases were noted to have noise-induced hearing loss (NIHL), they have been referred to the occupational doctor for further investigation to determine if the NIHL is work-related. OCI TRS have also completed the Hazard Identification, Risk Assessment and Rick Control (HIRARC) exercise for all processes on site. Trainings related to CHRA (once every two years) and noise (annually) is also in order. OCI TRS have also developed a Permit-to-Work (PtW) procedure and have specific PtW format/ reporting for confined space entry, working-at height, hot work, lockout-tagout, lifting, excavation, etc. A risk assessment, Pre Task Analysis accompany all PtWs. OCI TRS have also prepared a Control of Industrial Major Accident Hazards (CIMAH) report that includes a quantitative risk assessment study and an emergency response plan. The report has been submitted (and accepted according to the site personnel) to the Malaysian Department of Occupational Safety & Health. OCI TRS will conduct an Environmental, Health and Safety (EHS) Compliance Audit and a Process Safety Management (PSM) Audit (by an external/ independent consultant) to demonstrate that the site is in compliance with all local legal requirements and IFC PS & relevant WBG EHS Guidelines. Subject to the results of the PSM audit, the company will develop and implement a Process Safety Management Plan, following GIIP (e.g., OSHA Process Safety Management Standard) (ESAP#13). The audit reports will also determine if repeated audit is required on an annual basis.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas Emissions. The operating facilities of OCI TRS utilize grid-supplied electricity from Sarawak Energy Berhad (SEB) as the main energy sources. The annual electricity consumption from OCI TRS was approximately 1,893 GWh in 2024. Annual electricity consumption is will be remain the same with max power allocation of 295MW as OTSM is contracted via separate power purchase agreement. An existing coal-fired boiler is only used for emergency outage/contingency. OCI TRS sources water from Sarawak Water Sdn. Bhd. with annual water consumption of around 5,516,000m3 in 2024. The same sources of power and water supplies are expected for OTSM. The Company has not set annual energy and water use reduction targets. Several mechanisms and initiatives have been considered, including wastewater reuse or installing a natural gas fired boiler. Going forward, the company will (i) set annual energy and water use reduction targets based on energy audits and annual performance report; and (ii) benchmark resource use efficiency indicators against industry-specific GIIP referenced in applicable WBG EHS Guidelines. (ref. ESAP#2)
OCI TRS has developed and implemented a Greenhouse Gases (GHG) inventory system and collected data annually. The Company recently conducted GHG emission estimates covering Scope 1 and Scope 2 from 2022 to 2024. The results were over 500,000 tons CO2eq per year. Scope 2 GHG emissions significantly contributed to OCI TRS’s overall GHG emissions due to a relatively large proportion of electricity required for polysilicon production. Going forward, the company will (i) continuously improve its GHG emissions management practices with clear action plans and strategies; (ii) quantify its direct emissions from the facilities owned or controlled within the physical project boundary (Scope 1) and indirect emissions associated with the off-site production of energy used by the project (Scope 2); and (iii) report GHG emissions annually. Quantification of GHG emissions will be conducted annually, using internationally recognized methodologies. (ESAP#14)
Air Emissions. There are multiple air emission points, emission treatment systems, and monitoring locations involved in the operation of OCI TRS. Emission data from the continuous emissions monitoring system showed the alignment with the WBG EHS Guidelines for small boilers. Results for Hydrogen Chloride (HCl), Phenol and Chlorine (Cl2) monitoring were compliant with both national emission standards and limits from applicable WBG EHS Guidelines for Large Volume Inorganic Compounds Manufacturing and Coal Tar Distillation. Ambient air quality and noise level monitoring also indicated compliance with national standards and relevant WBG EHS Guidelines.
Wastewater. The existing facilities of OCI TRS are designed to ensure separation of domestic and industrial wastewater and stormwater streams and their treatment systems. All the domestic sewage from the plant is currently channeled to the centralized sewage treatment of the Samalaju Industrial Park via underground sewer lines. Currently, industrial wastewater generated from OCI TRS facilities is around 3,144 m3/day. With the OTSM plant in operation, the forecasted total wastewater generated will be around 3,840 m3/day, which is within the current maximum design capacity of the facility’s wastewater treatment plants (WWTPs) of around 7,000 m3/day. Key sources of industrial wastewater are from two Chlorosilane distillation streams, ten scrubbers of stack gas emission treatment systems, and coal-fired boiler (e.g., boiler blowdown, mechanical equipment drains, water treatment plant back washes, etc.). Industrial wastewater from all facilities is treated at two on-site WWTPs before being discharged to the sea through a submarine outfall. The key industrial wastewater treatment processes include neutralization, moving bed activated carbon treatment, coagulation and sedimentation, final pH adjustment, and keeping in guard basin before discharge to the sea through 500m outfall pipeline. Currently, OCI TRS has not explored technical options for wastewater recycling and water conservation. The company commissions qualified third party technicians to conduct monitoring of effluent quality. Recent wastewater monitoring results from OCI TRS were compliant with applicable national standards. However, Adsorbable Organic Halogens (AOX) were not monitored, and the monitoring results of Total Suspended Solids (TSS) did not meet the applicable the WBG EHS Guidelines effluent limits for Chlor-alkali /Hydrochloric Acid Plant. Marine water quality, internal and external groundwater and leachate monitoring results were also compliant with the national standards. Going forward, OCI TRS will (i) additionally monitor AOX in effluent; and (ii) conduct a review of the current WWTPs to develop a technical plan to meet the applicable national and the WBG EHS Guidelines, whichever more stringent, and to determine associated Capital Expenditure (CAPEX)/ Operational Expenditure (OPEX). In addition, OCI TRS and OTSM will prepare a Water/Wastewater Management Plan for operation, exploring technical options for wastewater recycling and water conservation aligned with the WBG General EHS Guidelines and the IFC PSs. (ESAP#15).
Process Safety and Hazardous Materials Management. The products of CA plants (caustic soda, chlorine and hydrogen gases, and hydrochloric acid) are currently readily used for Polycrystalline Silicon production process or sold in the domestic market to customers in Sarawak, including the nearby OCIKumho. Sodium hypochlorite is exported to Brunei under an offtake arrangement. For this reason, no significant storages for hydrogen and chlorine are required. However, there are temporary storage for liquid chlorine, silicon tetrachloride and trichlorosilane. QRAs and Hazard and Operability Study (HAZOP) have been prepared. High-level QRAs for Polycrystalline Silicon and CA plants were prepared and updated. The latest QRAs were prepared in accordance with best practice, using industry recognized sources of data for failure frequencies, ignition probabilities and applying UK HSE risk tolerability criteria, etc. Consequence modelling has been performed taking into account meteorological conditions applicable to the site, adopting reasonable vulnerability criteria based on best practice, and using industry standard software for modelling. All fire/explosion and toxic effects have been considered. However, the QRAs and 2025 CIMAH report are limited to only hydrogen, chlorine, trichlorosilane and dichlorosilane and did not address onsite risks. There are, however, process safety hazards which may arise from other chemicals or byproducts. Typically for polysilicon plants, this may include, but not limited to, silane (SiH4), silicon tetrachloride (SiCl4), hydrogen chloride, cleaning chemicals (such as hydrofluoric acid, nitric acid, sulfuric acid), and others (if used). The chemical hazards to onsite personnel were covered Chemical Health Risk Assessment (CHRA). Due to the recent fatal accident in 2024 and explosion incident in 2025, the company will (i) update the QRAs to cover onsite risk from all chemicals (including hydrogen, chlorine, trichlorosilane and dichlorosilane); (ii) update the QRAs every 3 years and CHRAs every 5 years or prior to any significant plant modification; and (iii) update HAZOP and conduct Layer of Protection Analysis (LOPA) assessments and Safety Integrity Level (SIL) Classification study. Mitigations should be implemented according to the systematic process safety analysis (HIRADC & HAZOP). (ESAP#16)
The other main hazardous materials stored onsite are limited volumes of HF and HNO3 for etching process, sulfuric acid (H2SO4) and caustic soda solution (NaOH) for wastewater neutralization. A Hazardous Chemical Management Procedure has been prepared and implemented. However, it is of high level and does not meet the requirements of WBG EHS Guidelines. Going forward, the Company will upgrade a Hazardous Materials Management Plan, including hazardous materials transfer and transportation, aligned with the WBG EHS Guidelines. (ESAP#17)
Solid and Hazardous Waste Management. All chlorosilanes (SiH2Cl2, SiHCl3, and SiCl4) are recovered and reused throughout the Polycrystalline Silicon production process. Solid wastes generated during the plant operation are mostly domestic solid waste from the office and also packaging material for the products. These domestic solid wastes are collected by local authority-appointed collectors and disposed of to the licensed landfill in Bintulu. Key scheduled wastes generated from the plant operation include (i) alkaline sludge from the WWTP for Polycrystalline Silicon Plant; (ii) carbonate sludge from Brine filter press for CA Plant; and (iii) fly ash and bottom ash from coal-fired boiler. Chemical composition and Toxicity Characteristic Leaching Procedure (TCLP) tests for those wastes have been conducted. All scheduled wastes from OCI TRS are not ignitable and the results allows the company to manage scheduled wastes at on-site facilities. OCI TRS has obtained approval from the Department of Environment for the construction and operation of landfills for industrial sludge and boiler ash. The landfill is sited on an area of approximately 17.05 ha, within the 186.3 ha land plot of OCI TRS. Site selection focused on four main criteria, including (i) availability of land; (ii) distance from the nearest human receptor; (iii) travelling distance; and (iv) land terrain (preferably flat). The landfill cells are designed to have liner system, systems for leachate collection and treatment, cover systems, storm water and surface water management, an environmental monitoring system. However, the onsite landfill is only for scheduled wastes from OCI TRS. OTSM will outsource disposal general and scheduled/hazardous wastes to licensed waste collector and external landfills. OCI TRS will conduct a full gap analysis of current landfill siting and design against the WBG EHS Guidelines for Waste Management Facilities and referenced Good International Industry Practices (GIIPs). Where gaps are identified, the company will propose additional management and engineering measures aligned with the WBG EHS Guidelines and to protect the landfill from naturally occurring events and conditions, such as hydro-geologically isolated from the shallow groundwater and ocean, coastal erosion, storm surge and tropical storms with consideration of global warming risks. (ESAP#18)
PS4: Community Health, Safety & Security
Community Health and Safety. The polysilicon manufacturing plant is constructed within the Samalaju Industrial Park area, characterized by industrial land use and with no residential settlements. The nearby Samalaju Industrial Port will be the main logistic hub for goods movements to and from the plants. The nearest residential settlements are located approximately 15km from the OCI TRS and OTSM plants. The company direct workforce and contractor workforce are accommodated in rented houses/buildings in residential areas of Bintulu and surrounding areas.
Traffic Safety. The Company employs bus drivers responsible for daily worker transportation. All drivers are required to receive defensive driving training covering safe driving practices, speed management, hazard awareness, vehicle safety and emergency response.
Security Personnel. 36 unarmed security personnel, including one Chief Security Officer, three supervisors, two female clerks and 30 guards, are hired for the construction and operation of the polysilicon manufacturing plants and follow the Security Control Guidelines and Duties Guidelines that defining roles, responsibilities and organizational structure of security personnel at the factory, and focuses on managing entry, exit, and activities within the factory to protect intellectual property, maintain order and safety. As per ESAP#19, OCI TRS and OTSM will review and update its Security Plan to be aligned with IFC’s Good Practice Handbook on the Use of Security Forces; Assessing and Managing Risks and Impacts The plan should be based on a security risk assessment and include (i) an overview of internal and external risks identified in the security risk assessment; (ii) mechanisms to screen and audit private security firms and guards; (iii) required training for security forces including use of force, human rights, and prevention of GBVH; (iv) definition of engagement mechanisms and coordination with public security forces when needed, and (v) procedures for reporting, responding and documenting security incidents. The community grievance mechanism will be available to members of the community or employees to express concerns about the security arrangements and acts of security personnel.
