While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

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

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key E&S risks and impacts associated with the Project include: (i) the adequacy of GDM’s management and monitoring systems to assess and manage E&S risks and impacts arising from its operations; (ii) management of labor and working conditions, including OHS practices; (iii) emergency preparedness and response; (iv) prevention and management of grievances, including those related to gender-based violence (GBV); (v) environmental management practices, including water and energy use, waste and hazardous chemicals management, and pollution prevention; (vi) management of biosafety and environmental risks associated with R&D activities and field trials; (vii) transport and road safety risks associated with logistics and employee travel; (viii) risks related to the use of security personnel; and (ix) stakeholder engagement activities related to E&S aspects.

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

E&S Management System. GDM’s Environmental, Health and Safety (EHS) Policy provides a framework for safe and healthy working conditions, respect of labor rights and environmental protection, among others. The Company has established a structured management framework for seed R&D and production oversight, anchored in quality control, documented operating procedures, and training and internal audit routines. This framework provides a foundation for managing operational risks and ensuring product quality and regulatory compliance across its activities.

Moving forward, under ESAP #1, GDM will formalize a corporate and unified E&S Management System (ESMS) aligned with PS1 requirements. The ESMS will include, but will not be limited to: (i) enhancement of the EHS Policy to explicitly cover social aspects, including labor and working conditions, community health and safety, human rights, and grievance mechanisms; (ii) documented procedures for identification, screening, assessment and management of E&S risks and impacts, including an updated risk matrix covering operations and third parties (including seed multipliers) and incorporating land-use/biodiversity risks, traffic safety, GBV, sexual exploitation, abuse and harassment (SEAH), and security-related risks; (iii) contractor and third-party management procedures, including minimum E&S requirements for seed multipliers aligned with PS2 and PS6 requirements, risk-based pre-qualification, periodic audits/field verification, corrective action plans, and contractual escalation measures; (iv) emergency preparedness and response procedures updated to address relevant hazards (including combustible dust, hazardous materials, climate-related risks and civil unrest scenarios) and to incorporate periodic drills and lessons learned; (v) stakeholder engagement and grievance mechanism; (vi) E&S training and competency requirements; and (vii) monitoring and reporting arrangements, including KPIs, internal audits/checklists, and periodic management review.

Identification of E&S Risks and Impacts. GDM identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national laws, environmental and labor regulations, and permitting requirements. Material E&S risks identified to date are related to labor and working conditions; OHS; management of pesticides and other hazardous materials; and waste and wastewater management.

Under its ESMS (ESAP #1), GDM will enhance its E&S risk assessment matrix to more systematically address land-use and biodiversity considerations associated with multiplier operations, as well as to identify, assess, and monitor broader social risks, including traffic safety, GBV/SEAH, and security-related risks. The E&S risk assessment will also address physical climate risks, including projected changes in temperature, precipitation, and extreme weather events. The enhanced risk assessment will be reviewed at least annually and will define thresholds and triggers for the implementation of corrective and preventive actions.

Management Programs. GDM has in place several operational programs to manage EHS risks across its operations. The framework is supported by periodic monitoring, operational controls, and formal record-keeping. Existing management programs address air emissions and air quality, noise and vibrations, effluents and groundwater, and waste management, including monitoring of fixed and mobile sources by authorized laboratories, preventive maintenance of equipment, environmental noise measurements, groundwater monitoring where applicable, and compliance with relevant permitting and reporting requirements at the provincial and municipal levels. Under ESAP #1 and following the update of the E&S risk and impacts matrix, GDM will expand and further systematize its management programs, as needed, to address newly identified or emerging E&S risks and to support continuous improvement in E&S performance.

E&S Organization Capacity and Competency. GDM has established an organizational structure responsible for coordinating the implementation of corporate initiatives across its operations. The Company is currently implementing a strategic plan aimed at strengthening this framework through a more structured governance system, including standardized operating procedures, incident management protocols, and company-wide training and communication programs. This framework is supported by operational personnel across multiple sites, including OHS staff and operational safety coordinators, as well as centralized systems such as the occupational health management platform.

In addition, GDM relies on specialized technical teams to oversee aspects associated with seed production, including direct engagement with multipliers through training programs, field audits, eligibility criteria, and monitoring tools. While these arrangements demonstrate a growing level of internal capacity, the current organizational setup needs further strengthening to ensure consistent and systematic E&S oversight across Argentina’s R&D and production footprint. Moving forward, under ESAP #2, GDM will: (i) reinforce its corporate E&S capacity through the formal appointment of a senior E&S Specialist at the corporate level; (ii) strengthen technical assistance to seed multipliers on E&S matters through enhanced field support, targeted training programs, and structured guidance tools; and (iii) formalize E&S monitoring mechanisms to enable a systematic assessment of multipliers and other strategic partners.

Emergency Preparedness and Response. GDM maintains emergency preparedness and response plans at its facilities, supported by trained emergency response brigades and periodic drills conducted in coordination with local emergency services. Lessons learned from drills and incidents are used to improve emergency response procedures.

As part of ESAP #1, GDM will update its emergency preparedness and response framework to incorporate significant risks such as dust explosions, the presence of hazardous materials, incidents of civil unrest, assistance to people with disabilities during evacuations, and climate-related risks, and ensure consistency with GIIP.

Monitoring and Reporting. GDM monitors E&S performance across its operations through a combination of site-level inspections, periodic EHS monitoring, and corporate systems for incident and corrective action management. Operational events, findings from inspections and audits, and corrective/preventive actions are recorded and managed through a digital platform, which provides traceability (assignment of responsibilities, deadlines, and closure evidence) and supports consolidation of information for corporate review. The Company also conducts periodic third-party monitoring where required (e.g., emissions and air quality monitoring by authorized laboratories; workplace monitoring for noise/lighting and other parameters as relevant), and maintains documentation of waste management and disposal through manifests and certificates, enabling verification of compliance and performance trends over time.

Supply Chain Assessment and Management. Seed multipliers operate as independent legal entities licensed by GDM to multiply and commercialize seed under a hybrid intellectual property licensing and distribution model. These entities are not part of GDM’s core supply chain and retain full responsibility for their workforce, subcontractors, and operational management. GDM does not exercise operational control over multiplier activities; however, it retains ownership of genetic material and brand, as well as contractual rights for technical oversight, inspection, and quality assurance across key stages of the seed lifecycle, including sowing, harvesting, conditioning, packaging, and commercialization.

As part of its ESMS (ESAP #1), GDM will apply proportionate, risk-based E&S requirements to seed multipliers. These requirements will focus on legal compliance and minimum E&S expectations aligned with PS2 and PS6 key objectives, including prohibitions on child and forced labor, non-discrimination, basic OHS practices, responsible agrochemical management, waste management, avoidance of conversion of natural or critical habitats, and access to GDM’s grievance mechanisms. Implementation will be supported through a risk-based pre-qualification process, periodic technical and quality audits, corrective action plans where material gaps are identified, and defined contractual escalation mechanisms.

PS2: Labor and Working Conditions

As of November 2025, GDM employs 801 professionals in Argentina, and the workforce is predominantly composed of men (80%) in operational functions (46%). In addition, the Company maintains full-time contracted staff dedicated to specific services such as cleaning, accommodation services, health and safety, and security.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment. GDM’s Code of Ethics and Conduct is aligned with Argentinian legislation and broadly supports PS2 principles by promoting non-discrimination, equal opportunity, respectful treatment, and safe working conditions.

Workers are engaged under written employment contracts that define conditions and terms of employment and are supported through induction and training programs, an employee handbook, and access to internal policies. Working hours and overtime are monitored and comply with applicable legal requirements. Accommodation is provided for temporary and migrant workers in accordance with national labor regulations and PS2 requirements.

As part of its ESMS, and under ESAP #3, GDM will formalize and implement HR processes and procedures covering: (i) selection and recruitment; (ii) compensation, working hours, and benefits; (iii) induction, training, and professional development; (iv) disciplinary and termination processes; and (v) performance evaluation. GDM will also review and update its Code of Conduct to explicitly include provisions on the prevention of SEAH, prohibitions on child and forced labor, and respect for freedom of association across all operations.

The company promotes initiatives related to gender equality and broader diversity and inclusion, as per the Code of Conduct, but senior leadership is yet dominated by men (75%).

Workers’ Organizations. GDM complies with PS2 requirements related to workers’ organizations, freedom of association, and collective bargaining. In line with applicable Argentinean Labor Laws, the company is covered by collective agreements governing terms and conditions of employment for all categories of workers, including permanent, discontinuous permanent, part-time permanent, and temporary employees.

Workers’ Grievance Mechanism. Workers may report Code of Conduct violations and ethical concerns through GDM’s Ethics Line, which offers multiple channels and allows for anonymous submissions. GDM Escucha, GDM Connect and GDM Site Support are the main channels to address grievances related to labor and working conditions. Moving forward, under ESAP #4, GDM will: i) develop and implement survivor-centered procedures for handling SEAH cases within the Ethics Line; and ii) strengthen GDM Escucha to function as a formal Workers’ Grievance Mechanism. This will include the ability to receive and resolve workplace complaints confidentially and anonymously, protect against retaliation, ensure timely, fair, and documented resolution processes, be communicated to all workers/third-party contractors, and be embedded in induction and refresher training. For workplace-related SEAH reports, GDM will apply gender-responsive and survivor-centered approaches, including informed consent, access to appropriate psychosocial support, safeguarding of survivors during investigations, minimum gender representation in investigation and decision-making process, and integrate grievance monitoring into the ESMS using gender-responsive indicators and sex-disaggregated data.

Occupational Health and Safety. GDM’s OHS management system is designed in accordance with applicable Argentinian legal requirements. The Company applies risk matrices based on Safe Work Analysis to identify hazards, assess risks, and define controls and mitigation measures, including personal protective equipment (PPE) requirements and worker training. These risk assessments are reviewed periodically and whenever there are changes in processes, equipment, facilities, or working conditions, in line with regulatory requirements. All facilities have undergone OHS risk assessments consistent with PS2 requirements. OHS oversight is supported by qualified internal personnel and specialized third-party service providers. Safety measures and KPIs, including occupational accidents, are recorded and investigated.

In 2025 GDM recorded and investigated 6 occupational accidents, resulting in a total of 224 lost workdays, in accordance with requirements of the Workers' Compensation Insurance system. No serious accidents or fatalities have occurred in the past three years, and currently near-miss incidents are not systematically reported.

As part of its ESMS (ESAP #1), GDM will update and enhance its EHS Policy and related procedures to align with the World Bank Group (WBG) EHS Guidelines (General EHS Guidelines and EHS Guidelines for Annual Crop Production). This will include enhanced periodic inspections, monitoring, and formal OHS performance reviews. Under the same ESAP action, GDM will also establish a procedure for the reporting, recording, and analysis of all incidents, accidents and near-miss events across all facilities.

Workers Engaged by Third Parties and Supply Chain. GDM requires its third-party suppliers and contractors, through internal procedures and contractual clauses, to comply with applicable national labor, OHS, and environmental laws. While GDM’s current Code of Conduct applies to contractors and suppliers, there is no structured process to ensure that these parties are systematically informed of, or formally acknowledge, its requirements. Under ESAP #5, GDM will strengthen its third-party management framework by: i) updating and implementing the Code of Conduct to explicitly prohibit child and forced labor, including for third-party and suppliers; ii) revising third-party and contractor procurement policies and procedures to address child and forced labor risks and major OHS issues in line with PS2 requirements; (iii) incorporating contractual clauses prohibiting forced and child labor and extending these requirements to lower-tier suppliers; (iii) implementing a communication strategy to inform primary suppliers of applicable labor requirements and related risks; (iv) delivering capacity-building activities, including training and guidance on child and forced labor, OHS, prevention of SEAH and child safeguarding; (v) formalizing a zero-tolerance policy toward SEAH, other forms of GBV, and discrimination.

PS3: Resource Efficiency and Pollution Prevention

Energy. Electricity for all GDM facilities is supplied from the national grid. The Company implements internal measures to reduce electricity consumption, including internal awareness and communication campaigns and the installation of a biomass burner to reduce the use of Liquefied Petroleum Gas (LPG) in grain-drying operations. Between January and November 2025, total electricity consumption amounted to 4,868,106 kWh. This information is tracked and reported to senior management and sponsors. Heating systems are only for hot water, while natural gas is used for cooking purposes. Some facilities have backup diesel generators, with both LPG, natural gas, and generators systems periodically monitored as required by law.

Water. The groundwater wells are equipped with flow meters to monitor and manage water consumption, while promoting rational water use through regular fixture checks and efficient cleaning practices in operational and service areas. GDM does not consume a significant volume of water for R&D activities and the current groundwater consumption is considerably below the permitted thresholds.

Greenhouse Gases (GHG): GDM conducted a GHG inventory in 2023 in accordance with the GHG Protocol and ISO 14064 standards. In that year, GMD’s total carbon footprint amounted to 20,858 tCO2e, comprising 6,772 tCO2e of direct emissions (scope 1); 438 tCO2e of indirect emissions from purchased electricity (scope 2), and 13,648 tCO2e of other indirect emissions (scope 3). GDM has been prioritizing the acquisition of new hybrid vehicles and adopting reduction targets for fuel consumption to lower its GHG emission worldwide.

Air Emissions: Air emissions, including particulate matter (PM10, PM2.5, and settleable), carbon monoxide (CO), sulfur dioxide (SO2), and nitrogen oxides (NO?) are monitored at all processing facilities and at the biomass burner in accordance with applicable national regulations. All sampling and analysis are conducted by certified third-party laboratories. GDM does not operate industrial boilers, and the backup diesel generators are maintained by in-house technical staff through routine maintenance programs following applicable regulations.

Wastewater Management: GDM does not generate liquid industrial effluents in any of its processes and there is no industrial water treatment plant in the company's facilities. Sanitary wastewater is treated in biodigesters before being discharged into the public sewer system or stored in septic tanks and treated as waste.

Solid Waste Management and Hazardous Materials: GDM has an operational waste management procedure aligned with PS3 covering the management of hazardous and non-hazardous waste. Waste segregation, packaging, labeling, transport, storage, and final disposal are carried out in compliance with applicable national regulations. Certified third-party service providers collect the waste on a regular basis, and all waste is treated, recycled, or disposed of by accredited operators or in licensed sanitary landfills. GDM also promotes sustainable packaging practices, including the use of bulk bags made from recycled resin.

Hazardous materials are stored and managed in accordance with Argentinian regulations and are subject to routine monitoring and inspections. Hazardous materials are limited to small volumes of chemicals and diesel for power generation, as most pesticide applications are conducted by third-party service providers. Hazardous materials are stored in well-ventilated areas and handled by trained personnel using appropriate PPE. Moving forward, GDM will develop and implement a consolidated operational procedure for hazardous material management under the ESMS (ESAP #1) applicable to all facilities in Argentina, aligned with WBG General EHS Guidelines and the WBG EHS Guidelines for Annual Crop Production. The procedure will include enhanced monitoring and inspection routines to ensure ongoing compliance with applicable standards.

Pesticide Use and Management: GDM performs pest control activities across its facilities and production areas through certified contractors and trained in-house personnel, in compliance with applicable national EHS laws and regulations. This includes the management of worker exposure to chemical agents, such as organophosphate insecticides and other crop protection products, through maintained exposure records, periodic occupational health monitoring, and preventive measures during handling and application. No cases of pesticide intoxication have been reported in the past three years. Moving forward, under ESAP #6, GDM will develop and implement a formal procedure for pesticide use and management aligned with the requirements of PS3 and the WBG General EHS Guidelines and the WBG EHS Guidelines for Annual Crop Production.

PS4: Community Health, Safety and Security

Infrastructure and Equipment Design and Safety and Emergency Preparedness and Response: GDM integrates Life & Fire Safety (L&FS) management into its corporate EHS system, applying it consistently across all facilities. Building design modifications and expansions are supported by external EHS oversight, including fire load studies and verification of compliance with applicable fire safety requirements. Fire protection and emergency preparedness measures include strategically located portable fire extinguishers maintained by certified providers, emergency signage, evacuation plans, designated emergency roles, and periodic staff training. Daily site inspections verify unobstructed escape routes, accessible extinguishers, operational emergency lighting, and proper housekeeping in risk areas. Records of inspections, maintenance, and corrective actions are maintained, and emergency drills are normally conducted annually, incorporating fire, evacuation, and medical emergency scenarios. GDM also operates under a vehicle safety policy, which includes defensive driving training for staff using its fleet. As part of ESAP #7, GDM will: i) enhance its vehicle safety policy and procedures in accordance with ISO 39001, WBG General EHS Guidelines (Section 3.4 - Traffic Safety) and GIIP on road safety; and ii) provide refresher training to staff and contractors.

Life and Fire Safety (L&FS) and Process Safety: Each facility maintains emergency response and contingency plans, implemented by dedicated emergency response brigades. Flour dust is recognized as a highly combustible material that, when dispersed in the air, can create significant risks of dust explosions and subsequent fires. As part of ESAP #8, GDM will: i) conduct a comprehensive Operational Risk Assessment (ORA) for all major facilities. The findings from these assessments will form the basis for developing a site-specific Combustible Dust Hazard Analysis (DHA) and Dust Management Plan and be applied in all sites. Where risk mitigation is required, facilities will evaluate and implement explosion-proof solutions, which may include explosion-proof lighting fixtures, electrical and control systems, explosion venting panels, and machinery associated with grain milling and transfer (e.g. grain elevators); ii) ensure that all plants are equipped with adequate means of egress and comprehensive fire protection systems (fire pumps, water tanks, fire hydrants, hose reels, and fire alarm coverage throughout all plant areas); and iii) implement all recommendations from the ORA across its production facilities and update each Emergency Preparedness and Response Plan (EPRP).

Security Personnel: GDM relies on third-party companies to provide unarmed security for its major facilities, with training delivered by the providers. Under ESAP #9, GDM will: i) develop and implement a security personnel management procedure in alignment with PS4 requirements and GDM’s revised Code of Conduct; and ii) provide anti-SEAH and Grievance Mechanism refresher training to security personnel.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

Protection and Conservation of Biodiversity: The sites of relevance to PS6 are GDM’s facilities and multiplier farms spread across Argentina, which span the Dry Chaco, Espinal and Humid Pampas ecoregions. They are all located in industrial or well-established agricultural areas, all of which are classified as Modified Habitat. Location screening indicating no risk of recent natural habitat conversion, nor are any located in legally protected areas. Currently, two of GDM’s corn multiplier farms are located within the massive Cuenca del Rio Salado Key Biodiversity Area (KBA). Given upland catchment areas of the KBA are well-established agricultural areas or cities, and there is no expected natural habitat conversion, the Project provides no reason for concern regarding additional impacts to the KBA.

Sustainable Management of Living Natural Resources: GDM’s testing and production farms, either owned or leased, have ASC certification (Agricultura Sustentable Certificada) from the Argentine No-Till Farmers Association (Aapresid), verified by independent audits, and mainly compliant with PS6 requirements. ASC promotes sustainability by evaluating environmental, social, and agricultural practices within a Quality Management System, including compliance with current legislation and applicable international human rights, to ensure transparency and continuous improvement. Aapresid is benchmarking the ASC standard to the Round Table on Responsible Soy (RTRS) standard to enable dual-certification and recognition, opening more markets to producers. By adopting ASC suggestions for dual-certification and maintaining independent verification, the company will comply with PS6 requirements.

Supply Chain: The multiplication of GDM’s soy and wheat seeds is commercialized externally and carried out by independent third parties operating under licensing arrangements. Maintaining its base of multipliers in well-established agricultural areas, the potential risk of natural and critical habitat conversion is expected to be low, nevertheless, and as reflected under ESAP #1, the Company will strengthen its risk-management approach by updating and implementing its Code of Conduct to explicitly prohibit natural habitat conversion, with applicability extended to contractors and relevant third-party suppliers.

GDM’s approach to stakeholder engagement in Argentina focuses on fostering positive environmental, social, and economic impacts through its Social Investment Policy, which emphasizes sustainability, collaboration, and shared value creation. Key areas of focus include education, cultural development, sustainable agriculture, and humanitarian aid, with partnerships prioritized with nonprofit organizations and adherence to ethical, legal, and nondiscrimination standards. Transparency and accountability are supported through clear eligibility criteria, documentation requirements, annual sustainability reporting, and a whistleblower channel. Through its Global Communications and Relationship Strategy, GDM employs targeted communication and relationship-building with stakeholders such as government officials, media, and local communities. As part of ESAP #10, GDM will develop and implement a Stakeholder Engagement Plan tailored to the company’s operations in Argentina, aligned with international stakeholder engagement standards, more structured consultation processes, comprehensive risk assessments, mechanisms for continuous stakeholder feedback, and enhanced grievance resolution systems.

External Communication and Grievance Mechanism: GDM maintains formal channels for receiving complaints, concerns, and reports of policy violations from external stakeholders, including sexual harassment and discrimination. Reports may include breaches of the company’s Policies and Code of Ethics, such as non-compliance with internal standards. Grievances can be submitted through online platforms and telephone. It allows for confidential reporting and provides the option for anonymous submissions. All grievances are investigated confidentially, in line with company procedures, and may lead to sanctions where violations are substantiated. Under ESAP #10, GDM will develop and implement a procedure for receiving, investigating, and resolving Ethical Care Line reports, covering both internal and external stakeholders, and it will include a survivor-centered sexual harassment protocol. GDM will also deliver updated awareness training to all staff and main contractors; provide training for designated case handlers; establish referral pathways to specialized GBV; publicly communicate a zero-tolerance SEAH policy with accessible reporting channels; and integrate gender-responsive KPIs into the ESMS to track effectiveness.

• Company Name: GDM Argentina
• Contact Person: Maria Soledad Echague
• Address: Panama 1221, San Isidro, Buenos Aires
• Email: sechague@gdmseeds.com
• Phone: +54 11 5230-2800

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	GDM will formalize a corporate and unified E&S Management System (ESMS) aligned with PS1 requirements. The ESMS will include, but will not be limited to:(i) enhancement of the EHS Policy to explicitly incorporate biodiversity and social aspects.(ii) documented procedures for identification, screening, assessment, and management of E&S risks and impacts, supported by an enhanced E&S risk assessment matrix covering land use and biodiversity, as well as broader social risks.(iii) expanded and systematized management programs, as needed, to address newly identified E&S risks and impacts.(iv) contractor, seed multiplier, and third-party management procedures, including PS2- and PS6-aligned minimum E&S requirements, risk-based pre-qualification and screening, periodic audits and field verification, corrective action plans, and contractual escalation measures.(v) an updated emergency preparedness and response (EPR) framework addressing significant risks, including periodic drills and incorporation of lessons learned.(vi) stakeholder engagement and grievance mechanisms applicable to employees, seed multipliers, contractors, and relevant third parties.(vii) monitoring and reporting arrangements to track ESMS implementation and performance.(viii) an updated and implemented Code of Conduct prohibiting natural habitat conversion, applicable to contractors and relevant third-party suppliers, and reinforcing prohibitions on child and forced labor, non-discrimination, minimum OHS practices, responsible agrochemical management, waste management, and access to GDM’s grievance mechanisms.(ix) enhanced audit and verification procedures.(x) updated EHS procedures aligned with the World Bank Group (WBG) General EHS Guidelines and the EHS Guidelines for Annual Crop Production.(xi) a hazardous materials management procedure applicable to facilities in Argentina, aligned with the WBG General EHS Guidelines and the EHS Guidelines for Annual Crop Production.	01/30/2028
2	GDM will:(i) reinforce its corporate E&S capacity through the formal appointment of a senior E&S Specialist at the corporate level.(ii) strengthen technical assistance to seed multipliers on E&S matters through enhanced field support, targeted training programs, and structured guidance tools.(iii) formalize E&S monitoring mechanisms to enable a systematic assessment of multipliers and other strategic partners.	01/30/2028
3	GDM will formalize HR processes covering recruitment, working conditions, training, performance management, and disciplinary procedures, and update its Code of Conduct to address SEAH prevention, prohibit child and forced labor, and uphold freedom of association.	01/30/2027
4	GDM will:(i) develop and implement survivor-centered procedures for receiving and handling SEAH cases through the Ethics Line.(ii) strengthen GDM Escucha as a formal workers’ grievance mechanism, ensuring confidential and anonymous reporting, protection against retaliation, timely and documented resolution, clear communication to workers and contractors, integration into training programs, and gender-responsive, survivor-centered handling of workplace-related SEAH cases, with monitoring embedded in the ESMS.	07/31/2027
5	GDM will strengthen its third-party management framework by:(i) updating and implementing the Code of Conduct to prohibit child and forced labor across third parties and suppliers.(ii) revising procurement and contractor management procedures to address child and forced labor and key OHS risks in line with PS2.(iii) incorporating contractual clauses prohibiting child and forced labor and extending these requirements to lower-tier suppliers.(iv) implementing a communication strategy to inform suppliers of applicable labor requirements and associated risks.(v) delivering capacity-building activities, including training and guidance on child and forced labor, OHS, SEAH prevention, and child safeguarding.(vi) formalizing a zero-tolerance policy toward SEAH, other forms of GBV, and discrimination.	01/30/2028
6	GDM will review its internal protocols and consolidate them into a single procedure, applicable to all crops, for pesticide use and management aligned with the requirements of PS3 and the WBG General EHS Guidelines and the WBG EHS Guidelines for Annual Crop Production.	07/31/2027
7	GDM will:i) enhance its vehicle safety policy and procedures in accordance with ISO 39001, WBG General EHS Guidelines (Section 3.4 - Traffic Safety) and GIIP on road safety.ii) provide refresher training to staff and contractors.	07/31/2027
8	GDM will:(i) conduct Operational Risk Assessments (ORAs) for major facilities to inform site-specific Combustible Dust Hazard Analyses and Dust Management Plans.(ii) ensure all plants have adequate means of egress and comprehensive fire protection systems.(iii) implement ORA recommendations and explosion mitigation measures as needed across facilities, and update Emergency Preparedness and Response Plans accordingly.	07/30/2028
9	GDM will:i) develop and implement a security personnel management procedure in alignment with PS4 requirements and GDM’s revised Code of Conduct.ii) provide anti-SEAH and Grievance Mechanism refresher training to security personnel.	09/29/2027
10	GDM will:(i) develop and implement a Stakeholder Engagement Plan tailored to the company’s operations in Argentina.(ii) establish procedures for receiving, investigating, and resolving Ethical Care Line reports for internal and external stakeholders, including a survivor-centered SEAH protocol, awareness and case-handler training, referral pathways, public communication of a zero-tolerance policy, and gender-responsive KPIs integrated into the ESMS.	07/31/2027