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 2012 Policy on Environmental and Social Sustainability. The proposed project will have limited adverse E&S impacts and addressed through mitigation measures defined in the attached Environmental and Social Action Plan (ESAP), and good international industry practices (GIIP). Key E&S issues and risks are: (a) company's management and monitoring systems to manage E&S risks and impacts from its operations; (b) consistent management of labor and working conditions including compliance and Occupational Health and Safety (OHS) policies and practices, prevention of sexual harassment and Gender Based Violence and Harassment (GBVH) in its operations; (c) resource efficiency, ballast water management and spill control & waste management; (d) compliance with International safety and security risk management codes including emergency preparedness and response; (e) management of any impacts on sensitive coastal and marine environment; and (f) stakeholder engagement and grievance mechanism, including in relation to crew interaction with communities.

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.

PS 1: Assessment and Management of Environmental and Social Risks and Impacts
ASLL has developed a Company Procedure Manual (CPM) which includes the Safety Management System (SMS), fleet instruction manual, shipboard & shore-based contingency manuals, cargo securing manual, garbage management manual, standard forms and checklists etc. The classification societies undertake regular audits of the company’s vessels and certifies their adherence to the classification requirements. The company has also developed an Environmental and Social Management System (ESMS) that is in partial compliance with IFC Performance Standard (PS) requirements. Further, ASLL is in the process of developing an Integrated Management System (IMS) framework in line with the International Safety Management (ISM) requirements, IFC PSs, Good International Industry Practice (GIIP) as reflected in the applicable and relevant parts of the WBG General Guidelines & WBG EHS Guidelines for Shipping which will comprehensively cover all business operations.
Policy: ASLL has a corporate ESMS policy that is required to be updated to be consistent with IFC PS requirements. The policy once approved will be formally extended to contractors or third-party service providers, and will have provision for periodic review, feedback, continuous improvement and indicate responsibility for its execution. The policy will be further disclosed and disseminated amongst the seafarers and employees.
Identification of Risks and Impacts: ASLL has partially identified and manages EHS risks and impacts associated with its onboard vessel operations through task-based risk assessments to ensure vessels’ compliance with applicable national E&S requirements, various international conventions, standards and codes of International Maritime Organization (IMO), International Ship and Port Facility Security (ISPS) & Marine Pollution (MARPOL). The company has an existing safety management system (SMS) as part of the CPM in compliance with the ISM Code of IMO. The company is also preparing to obtain International Organization for Standardization (ISO) 9001, 14001, 45001 & 50001 certifications. The company maintains a legal register and maintains records of all mandatory certificates for the ocean-going ships. All the ocean-going vessels are classified by recognized multinational maritime classification society confirming the ship’s safety management compliance with ISM Code. However, the company currently does not fully have a formal procedure for comprehensive E&S risk identification and assessment.
Management Program: ASLL currently has established documented E&S, safety and pollution prevention related programs, procedures & plans which are in alignment with statutory and maritime regulatory frameworks including International Convention for the Safety of Life at Sea (SOLAS), MARPOL and ISM requirements. The CPM of ASLL primarily meets the requirements of International Maritime Organization (IMO). However, the current programs are more compliant focused, and gaps in monitoring and review of various plans involving third parties were identified posing statutory risks. As part of ESAP#1, the Corporate ESMS for vessel operation will be updated in line with IFC PSs, WBG General EHS Guidelines, WBG EHS Guidelines for Shipping, relevant GIIP, and incorporating ISM codes & manual, MARPOL and IMO requirements for consistent application across vessel operations (including the procurement and decommissioning of vessels). The updated ESMS among others will include: (i) updated ESMS policy; (ii) formal procedures for comprehensive E&S risk identification, assessment and management related to vessel operations, procurement, decommissioning and recycling of vessels (based on recognized international standards such as the Hong Kong Convention); (iii) documented EHS operational manuals, SOPs, practices, and plans; (iv) adequate EHS staffing with clarity of roles and responsibility for ESMS implementation; training and capacity building of EHS and other staff; (v) emergency preparedness and response, including life & fire safety management plan; (vi) stakeholder engagement and community grievance mechanism; and (vii) reporting, monitoring, and management review. The updated ESMS will cover all employees, seafarers, contractors/third-party service providers and suppliers, with. Third parties engaged by the companies will be contractually obliged (E&S clauses included in procurement and service contracts) to prepare and implement the various EHS management plans and procedures including compliance with applicable regulations, industry codes relevant to ship types (MARPOL) and international standards.
The E&S risk assessment will include all the low, medium & high-risk activities including but not limited to community health and safety, biodiversity, and supply chain-related risks involved in its fleet operations at sea, anchorage and ports and supply chain. The E&S risk assessment will especially include design, infrastructure, machinery and equipment risk assessments covering E&S mitigation and management measures and controls including emergency shutdowns, power systems, and other fail-safe features, with clear delegation of duties, periodic audits and management reviews. The updated ESMS will cover all employees, seafarers, contractors/third-party service providers and suppliers, with E&S clauses included in procurement and service contracts to ensure consistent standards are maintained and the companies will ensure that the same is properly disseminated amongst all relevant stakeholders, including the seafarers and employees. The company undertook a third-party E&S review of ASLL operations in 2025, and corrective actions were identified. As part of ESAP#2, the companies will implement Corrective Action Plan (CAP) as an outcome of third-party E&S review commissioned for ASLL shipping operations.
EHS Organizational Capacity/Competency: The corporate team of ARL has an ESG & Sustainability Department at the corporate level which is led by ESG & Sustainability Lead, which currently does not have full oversight and responsibility for E&S performance of ocean-going vessels. ASLL has technical team but does not have any E&S resources currently to oversee E&S issues. All vessels of ASLL are supported by designated Environmental Control Officer (ECO), Chief Officer, Safety Officer (Chief Engineer) and the Master/captain who are responsible for implementing E&S and safety policies ensuring compliance with IMO/ISM requirements.
As per ESAP#3, the companies will ensure adequate EHS staffing, a dedicated EHS focal point at ASLL level with adequate qualifications and experience (preferably erstwhile Environmental Control Officer (ECO). EHS staffs to ensure effective ESMS implementation, periodic update of the CPM, ESMS and IMS, address corrective actions identified through internal and external audits, including training to direct and third-party workers. In addition, ASLL will include a climate risk focal point at the corporate level with adequate qualifications and experience.
ASLL provides on board and online training modules besides providing safety courses (mandatory prior to joining the ship) for the seafarers through recognized institutes. The seafarers are also required to obtain IMO course certificates. The ESMS update (refer ESAP#1), will include a structured EHS capacity building program for staff and crew including (a) Training need assessment in line with the roles and responsibility; (b) training effectiveness review; (c) ongoing update of training requirement in line with internal and external audit findings.
Emergency Preparedness and Response: ASLL has developed emergency preparedness and response mechanisms including contingency manual, shipboard security plan, fleet instruction manual, shipboard oil pollution emergency plan, SMS and CPM aligned with SOLAS, MARPOL, ISM Code etc. covering emergency scenarios such as fire, oil/chemical spill, collision, medical emergency and natural hazards. Vessel-specific hazard identification and risk ranking in line with IMO guidelines and ISM Code requirements are done for all cargoes. Annual emergency mock drills are conducted on the ships and onboard training conducted regularly and records maintained. However, there are no procedures for the port and communities to report concerns or receive information about any incidents like oil/cargo leaks or collisions that may have environmental impacts or disclose the same.
As per ESAP#4, the companies will develop corporate level Emergency Preparedness and Response Framework (EPRF) at ASLL level in line with IFC PS requirements, applicable national regulations, industry codes relevant to ship types (MARPOL) and will include climate-related events (e.g. cyclones, storms), building upon existing practices with special attention to in addition to provision for increased frequency of mock drills, emergency specific mitigation and clean-up measures, response equipment, disclosure of incident updates with stakeholders, periodical engagement with stakeholders and affected community on safety measures, communication protocols, a training matrix for contingency roles and post-incident learning checklists. Update the vessel specific Emergency Preparedness and Response Plan (EPRP) in line with the corporate EPRF.
Reporting & Monitoring and Review: The CPM of ASLL has described the various procedures and responsibilities of daily and periodic monitoring of various activities. The company currently conducts half-yearly reviews onboard vessels, led by the Master (Captain of the ship), monthly safety committee reviews and annual reviews by the management team. It also regularly undertakes internal and external audits primarily focused on statutory requirements and technical/safety compliances. Standalone E&S reviews are currently not conducted and there are gaps in systematic tracking and evaluation of environmental & social key performance indicators related to GHG emissions, reductions in fuel and energy consumption, quantity of water consumed, air emissions, noise and vibration, waste & sludge generation and disposal to shore facilities, recycling of packaging materials, reductions in electricity, paper consumption, spill drills, crew trained in chemical handling, and response times community engagement, labor practices, grievances etc. Structured and regular management reviews of E&S performances are also currently lacking. As per ESAP#5, the companies will Develop and operationalize SOP for data collection, tracking and evaluation of E&S KPIs related to various parameters such as GHG emissions, reductions in fuel and energy consumption, water consumption, air emissions, noise and vibration, sewage, waste & sludge generation and disposal to shore facilities, hazardous waste, recycling of packaging materials, reductions in electricity, paper consumption, community engagement, labor practices, grievances, OHS records, all forms of violence and harassment including Gender Based Violence and Harassment (GBVH), maintenance and certification of machinery and equipment, Biodiversity performance (e.g ballast water management), Emergency response time, training records etc. This will ensure trend analysis of the KPIs in line with CLASS certification requirement, IFC PS, WBG EHS guidelines, and GIIP.
The SOP to include responsibilities for undertaking regular monitoring & execution; conduct periodic standalone E&S reviews and audits; systematic tracking of KPIs; required training for KPI monitoring, tracking and reporting on indicators; undertake regular reporting and ensure structured and regular management reviews of E&S performances.
PS2: Labor and Working Conditions
ASLL currently employs 46 direct staff at its offices in Dhaka, Chattogram, Dubai and Singapore who look after chartering, manning and monitoring of vessel operations etc. ASLL also employs ~578 direct employees in the 42 lighter vessels and another 12 direct employees as support staff for operation and maintenance for lighter vessels. Each of the ultramax vessels has around 24-25 crew (also known as sailors/seafarer/seamen) and 12-13 officers. The officers and the seamen employed in the ocean-going vessels are recruited through an external manning agency. The contracts for the sailors are for 6-9 months while those of officers are for 4-6 months. All the staff members including the seafarers are local citizens of Bangladesh and the company has not employed any international personnel. Additionally, about 70 third party workers are engaged by ASLL for onshore housekeeping, security and vessel maintenance.
Human Resource Policies and Procedures: ARL has an HR policy at the corporate level followed by all the group companies and is communicated to all staff through intranet. There are no specific HR policies or manual covering all employees of ASLL. The CPM, crew management policy and the employee handbooks for ocean-going and coastal vessels of ASLL covers the terms and conditions of employment, working hours and Overtime (OT) provisions, wages, benefits, compensation, performance assessment and promotion criteria, collective bargaining, worker rights and protections under national labor laws and prevention of sexual harassment and Gender Based Violence (GBV), which aligns mostly with Maritime Labor Convention (MLC) 2006, International Labor Organization (ILO), and national labour requirements. As part of ESAP#6, the company will update the existing HR manual, in line with local regulations and IFC PS 2 requirements and will include: additional relevant provisions of applicable labor laws & IMO requirements; standalone non-discrimination and equal opportunity policy; explicit provisions on harassment prevention, GBVH, gender appropriate facilities and practices, and freedom of association; long-term disability coverage and retirement planning; updated employee complaints/grievance mechanism and including access to third party workers; performance appraisal; retrenchment; management of contractors/service providers, contractor/service provider compliance with statutory labor requirements. The updated HR manual will be communicated to the employees through employee portal (and other means as feasible) and will provide training on working conditions and terms of employment as part of employee induction and refresher training from time to time.
Working Conditions and Terms of Employment: ASSL issues appointment letters to all its staff, while its manning agent issues the letters to the contractual seafarers and officers at ships, which specifies wages and payments, working hours, rest periods and leaves, benefits, insurance portability, disability and loss of life coverage, travel and repatriation, disciplinary procedures etc. and is in compliance to with International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) and Maritime Labour Convention (MLC), 2006 requirements. The terms and condition of employment for the seafarers is guided by the collective bargaining agreement (CBA) with the Bangladesh Seafarers’ Union while the third-party worker’s terms of employment are guided by the contract agreement between the company and the contractors which are in line with the local regulations.
Workers’ Organizations: ASLL does not have any explicit provisions in its manuals on freedom of association and will therefore update its HR manual (ESAP#6). The manning agent of ASLL has entered into a CBA with the Bangladesh Seafarers’ Union that is effective till 30th September 2027. The CBA covers duration of employment, wages, overtime and special work allowances, high risk area allowances, holidays and leaves, hours of work and rest periods, disciplinary procedure, overseas travel, repatriation, disability and loss of life coverage, medical fitness, uniforms, gratuity etc.
Non-discrimination and Equal Opportunity, and protection of workforce: ASLL does not employ any underage worker, prohibition of hiring underage workers below 18 years of age is defined in company’s SOPs, Manuals and agreements with Manning agency. Standard employment terms & conditions, CPM and CBA ensure that all clauses do not permit any forced or involuntary employment. The company will update its HR manual under ESAP#6 to include non-discrimination and equal opportunity policy aligned with IFC PS2, covering recruitment, promotions, wages, and workplace conduct.
Accommodation on Vessels: The CPM covers the provisions related to accommodation and recreational facilities provided on board the vessels. The ship master is responsible for ensuring that the accommodation areas are clean, well-ventilated and in good condition; welfare conditions are satisfactory; and duly reporting any deficiencies. Access to ship-to-shore telephone services is made available to the crew members at reasonable charges. Accommodation is provided on shared basis with only the senior most staff (master, chief engineer etc.) allotted private cabins.
Grievance Mechanism: Akij has recently in October 2025 developed an ERP-based internal Grievance Mechanism (GM) under its Stakeholder Engagement Plan (SEP), which provides multiple access (verbal, written, email and phone) besides escalation matrix and options for anonymous and confidential reporting. The CPM also defines the grievance procedure for all officers and seafarers in the vessels. Every joining seafarer is provided with a copy of the grievance procedure (along with grievance form), which is kept by them all throughout the contract and is filled and shared by the crew, if required. Seafarers can raise any issues with the Chief officer and master without any fear of retaliation and escalate to head office if not solved within 7 days. The sailors and officers can also reach out to DG shipping in case of any pending grievances. As part of ESAP#6, the companies will update and implement the grievance mechanism and maintain records and regularly report to stakeholders.
Occupational, Health and Safety (OHS): ASLL’s vessels have obtained certifications related to ship security, safety management, Maritime Labour Convention (MLC), ship safety equipment, ship safety construction etc. The vessels maintain records and documentation related to MLC compliance, H&S inspection, safety officer’s inspection, SOLAS, safety committee meetings, pre-embarkation health declaration, training, Personal Protective Equipment (PPE) usage, water quality monitoring, voyage planning and passage planning. The SMS addresses all elements related to OHS and ensures compliance with SOLAS, ISM Code and ILO OHS standards and. Operational safety trainings and drills are well documented. All seafarers must complete seven safety training courses, including those sponsored by ASLL at third-party recognized institutes, in addition to the required seven to eight IMO safety courses before joining. Online and onboard training on mental health is provided to the seafarers. All the officers are required to undertake first aid training, while the Master & Chief Officer is required to undertake 5 days of first aid training followed by reevaluation and refresher training every 5 years. The Second Officer is designated as the medical officer on board. All the crew members are required to undergo pre-employment medical checkups. In case of medical emergencies, the in-house doctor provides online medical advice to the Medical Officer (on board) and in severe cases medical evacuation is done through the registered shipping agents. Health insurance including accident coverage and medical support is provided in compliance with national regulations.
The Chief Officer decides on the quantities of various hazardous items carried and stored in the vessel based on the ship specific checklists. The in-house technical & engineering team, supported by certified contractors, are responsible for maintenance and safety compliance of the vessels. Near misses, incidents/accidents, injuries, first aid, fatalities are recorded & reported, Root cause Analysis conducted by the Master and the Chief Engineer and preventive and corrective actions are undertaken. As part of ESAP#1 companies will ensure that the SMS and CPM is updated related to OHS in compliance with national law/standards, IFC PSs requirements, and applicable and relevant section of the WBG General EHS Guidelines and WBG EHS Guidelines for Shipping along with SOLAS, ISM Code and ILO OHS. The updated SMS will include provision for OHS training related to behavior-based safety, fatigue management aligning with international best practices.
Third Party workers: ARL has developed a Supplier Code of Conduct. However, the implementation is minimal with limited informal oversight. ASLL currently has a limited contractor oversight which is primarily managed by the corporate team. As part of ESAP#6 the companies will update and implement the existing contractor management system to include labor and working conditions and cover manpower service providers and service-based contractors. The updated contractor management system will have provision for monitoring, regularly supervise and report on contractor compliance to ensure that contractors comply with applicable labor laws, including working conditions and OHS related risks, payment of wages and grievance mechanisms (companies’ GM to be accessible to third-party workers, in absence of 3rd parties GM) and IFC PS 2 requirements. Corrective action should be agreed with the vendors/suppliers/contractors and implemented in a timebound manner and suppliers to be audited at least bi-annually.
PS 3: Resources Efficiency and Pollution Prevention
Resource Efficiency: The ocean-going vessels are run on Very low sulfur fuel oil (VLSFO), while there are plans to use biofuel post 2027-28 for which the engines will need to be retrofitted. ASLL has in place vessel-level systems that address fuel efficiency and operational carbon intensity. In addition, ASLL maintains approved vessel specific Ship Energy Efficiency Management Plan (SEEMP) and ship-level fuel efficiency is managed in line with IMO requirements. Some of the measures being implemented include voyage planning, optimized ship handling, slow steaming, weather routing, optimum trim and ballast, use of autopilot, propeller cleaning, periodic hull maintenance, improved cargo handling, engine maintenance etc. As per ESAP#5, the company will provide measurable targets or KPIs to improve resource efficiency and monitor and maintain records of the measurable environmental objectives for ocean faring vessels.
GHG Emissions: The absolute (project) GHG emissions associated with the operation of the vessels is estimated at 104,943 tCO2e per year. This represents a net GHG emissions reduction of 5,833 tCO2e per year compared to the baseline emissions. The project vessels comply with relevant IMO requirements related to air emissions, have international air pollution prevention certificates, use low or very low sulfur fuel, use CO2 fire extinguishers (instead of ozone-depleting substances) and have measures in place to minimize spills and dust generation during loading and unloading of cargo.
Pollution prevention: ASLL’s CPM has detailed procedures that complies MARPOL Annex VI related to sulfur content cap of 0.50% m/m, NOx Technical Code limits for Tier I, II and III engines etc. The emission sources are monitored through engine logbooks, fuel consumption records, carbon intensity rating (CII) and periodic inspections. Classification Society inspects and issues international air and oil pollution prevention certificates in line with MARPOL Annex VI requirements. Records and certificates related to bilge water, wastes, sludge and ballast water are maintained. Tributylene & Cybutryne free antifouling paints as per IMO guidelines are applied on a 2–3-year cycle and certificates of paints are maintained as these are audited by the classification societies. Noise and vibration monitoring are not conducted and thus records of crew exposure assessments, equipment testing, or corrective actions related to excessive noise or vibration are not maintained. The companies will provide measurable targets or KPIs (refer ESAP#5) related to air emissions, noise and vibration and periodically review & report the same.
Wastes: ASLL has developed a garbage management plan that defines the procedures for collection, segregation, handling, storage, transport & disposal for various types of hazardous and non-hazardous wastes in compliance with MARPOL Annex V. ASLL also has a Ballast Water Management Plan (BWMP) developed for its vessels, in line with IMO regulations and details the procedures for ballast water exchange at sea, sediment removal, designated sampling points, and reporting requirements. The vessels have in place procedures, equipment and facilities (Sewage treatment plant and incinerators) that meet IMO requirements related to ballast water management; garbage management; sewage treatment and disposal; sludge management and anti-fouling system. ASLL’s vessels generate both hazardous and non-hazardous waste from vessel operations including food waste, ballast water sediments, domestic waste, medical waste, animal waste, incinerator ash, e-waste, operational waste, packaging materials etc. which are disposed of to onshore contractors. Sludge and different waste are segregated and kept in the hold onboard using labeled containers for hazardous and non-hazardous waste, and records maintained for monitoring and audit purposes. The port authorities randomly check documents related to sludge and waste. The plans also outline steps to reduce garbage including recycling and avoiding single-use plastics. The ESMS will further define KPIs related to waste, sludge and ballast water generation and disposal. As per the ESAP#7, the updated ESMS will include company-wide SOPs for bilge, sludge and sewage management beyond vessel-level documentation, ensure that all vessels have valid hazardous materials, garbage, bilge, sludge, oil pollution prevention, ballast water management and antifouling paint certificates and records maintained centrally as required by applicable IFC PS, applicable national regulations and industry codes relevant to ship types (MARPOL). The SOPs shall also include procedures to verify and document how onshore contractors treat or dispose of all waste streams using chain of custody forms to be signed/stamped at the final disposal/treatment facility. SOP should include maintaining an Inventory of Hazardous Materials (IHM) throughout vessel operating life in line with Hong Kong Convention.
Hazardous materials management: ASLL has provision to maintain inventory of hazardous materials carried in the vessels and ensures adequate safety including relevant material safety data sheet (MSDS). The hazardous materials carried on the vessels meet the requirements of International Maritime Solid Bulk Cargoes Code (IMSBC) and International Maritime Dangerous Goods (IMDG) Code of the IMO. CPM includes procedures for tracking hazardous waste in line with the Hong Kong Convention and European Union (EU) Ship Recycling Regulation and requires documentation to be maintained for removal and disposal of hazardous materials at end-of-life. Third party assessments are carried out prior to transport of hazardous goods besides certifications from the shipper. The vessels generally carry Very Low Sulphur Fuel Oil (VLSFO) along with ~2000 liters of paints for daily maintenance, chemicals for cleaning cement and other cargoes. No asbestos materials are allowed on board as cargo. KPIs for centralized management monitoring (refer ESAP#5), will include data related to spill drills, crew trained in chemical handling, and response times which will be monitored, reviewed and reported periodically.
PS 4: Community Health, Safety, and Security
Infrastructure and Equipment Design and Safety: ASLL’s SMS includes a Planned Maintenance System for machinery (including cranes and hydraulic platforms) and pollution control equipment, indicating routine technical oversight. The ocean-going vessels are overhauled through third party twice in 5 years as per IMO requirements with the intervening duration not exceeding 36 months. The vessels also have certified and trained seafarers/ officers responsible for routine maintenance of the vessel while on sea. In case of emergency or major repairs, the repair work/ maintenance is done in the port or on outer anchorage at Chattogram by engaging third party workers. The project companies will update its existing SMS (refer ESAP#1) related to risk controls for third parties engaged in all its operations. As part of ESMS implementation (refer ESAP#1), the companies will document systematic design, infrastructure and equipment risk assessments covering emergency shutdowns, power systems, and other fail-safe features, with clear delegation of duties, undertake periodic audits and management reviews in alignment with IFC PSs, GIIP, ISM, IMO and International Association of Classification Societies (IACS) Unified Requirements.
Life and Fire Safety (L&FS): ASLL maintains various safety certificates for the vessels including safety radio, safety equipment, safety construction, lifesaving & firefighting appliances etc. and conducts formal safety assessments for the vessels annually as per IMO guidelines. However, documentations related to third-party inspection records and verification records for the fixed fire detection (smoke, heat, or flame), and alarm system including manual call points, control panels, and alarm functionality were not available. The project companies will as part of ESAP#8, integrate testing, inspection, and verification of L&FS into the SMS, assigning responsibilities and including review at management level.
Community Exposure to Disease: All seafarers engaged in ASLL’s vessels undergo a pre-embarkation medical examination at clinics/medical practitioners approved by Director General (DG), Department of Shipping, Government of Bangladesh and a medical logbook is kept on board. Details of any injury or sickness and treatment given are entered into the medical logbook. Quarantine department from the ports checks the vessels at the outer anchorage and ensures that there are no diseases on board before quarantine clearance certificate is issued before the vessel is allowed to enter the port. In case of any communicable disease outbreak, the project vessels are required to follow the IMO’s guidelines including quarantine procedures and instructions of the harbor master’s prior to entering the ports. The training provision (refer ESAP#1) for the crew members will include awareness on communicable disease and prevention measures.
Security Personnel: Approved Ship Security Plan (SSP) and security procedures as per ISPS code are present for ASLL’s vessels, based on which valid International Ship Security Certificate (ISSC) is obtained. The class auditors duly audit the compliance and effectiveness of shipboard security arrangements including access control and other measures to combat human trafficking, smuggling, and stowaways by strengthening. Presently ASLL’s vessels are not sailing in high-risk areas and thus armed security personnels are not engaged on board the vessels. In case of sailing through high-risk areas, armed personnel through authorized third-party contractors are deployed in the vessels post approval from DG, Department of Shipping, Government of Bangladesh. ASLL has a stowaway search checklist in line with the IMS requirements. However, there is no reference to engaging with the stowaways and refugees while on board and ensuring that health and welfare is assured. As part of ESAP#9, the companies will update the CPM to deal with stowaways and refugees. The project companies will integrate security-related issues into the company’s grievance mechanism for both internal and external stakeholders (refer ESAP#6&11) with confidential reporting channels (such as a hotline or online form) for incidents involving security personnel. Trainings of the crew to be undertaken by the project companies (refer ESAP #1) will include human rights, proportional use of force, and incident reporting requirements.
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity: The vessels in international waters ply in IMO defined routes and the passage plans are filed by the captain once at sea. ASLL’s bulk carriers may follow different international routes based on demand and may thus pass through or near several Important Marine Mammal Areas (IMMA) in the Indian Ocean, Bay of Bengal, coastal Sri Lanka and the Malacca–Singapore Straits which hosts diverse marine habitats and protected areas. Parts of Bay of Bengal and Sundarbans are recognized as biodiversity-sensitive that require protection by bodies such as International Union for Conservation of Nature (IUCN) & South Asia Co-operative Environment Program (SACEP). These routes are though not currently designated by IMO as Particularly Sensitive Sea Areas (PSSA).
As per ESAP#10, ASLL will also develop a biodiversity management procedure to manage risks to marine mammals and biodiversity. The procedure will include: (a) development of navigation procedures, including mitigation and avoidance measures for project vessels passing near biodiversity-sensitive and IMMA areas including a combination of: i) adherence to the relevant legal obligations and guidelines; ii) identify sensitive ecosystems, migratory routes, and protected areas relevant to fleet operations; iii) develop permanent, seasonal and voluntary routing measures for areas to be avoided and port approach routes; iv) short term and dynamic routing measures implemented near the biodiversity rich areas where the vessels shall be encouraged to either avoid these areas to the extent feasible or reduce speeds to 10 knots or less while transiting through them; and pollution prevention measures, including invasive species management (b) annual refresher/new trainings of all crew members by professional marine mammal professional association for monitoring and reporting sightings of marine mammals; (c) presence of at least two trained crew members on the bridge while passing through biodiversity rich areas; d) provision of infra-red and reticulated binoculars in the project vessels; (e) reporting mechanisms in case of any collisions or observations of protected marine species; (f) annual monitoring of effectiveness.

ASLL has already undertaken a mapping exercise of its stakeholders and has developed a stakeholder engagement plan (SEP). ASLL’s website is the primary medium of engaging with its external stakeholders. The main stakeholders include the vessel charterers/clients, the worker representatives/union, manning agent, port authorities, Department of Shipping and other government authorities, suppliers & contractors for bunker, food, maintenance etc., insurance companies, classification society, importers/exporters using services and communities besides the employees. However, the SEP is yet to be fully implemented. As part of ESAP#11, the companies will implement the stakeholder engagement plan (SEP) and the external GM aligned to the IFC PS requirements, including (i) disclosure and dissemination of information to relevant stakeholders including communities on GM; (ii) extend the GM to its contractors and third parties, if they do not have their own process and (iii) tracking and reporting to stakeholders such as authorities, unions etc. The company will maintain records of stakeholder engagement and grievances.

Any queries and/or comments about the project may be directed to:
Company
Akij Shipping Line Limited
Point of Contact Mr. Md Rahajul Amin
Title ESG & Sustainability Lead
Telephone Number +880 1717221616
Email sustainability.lead@akijresource.com
Mailing Address Akij House, 198 Bir Uttam, Mir Shawkat Sarak, Gulshan Link Road, Tejgaon, Dhaka-1208.
Website www. akijresource.com

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Update the Corporate ESMS in line with IFC PSs, WBG EHS Guidelines including Guidelines for Shipping, relevant GIIP, incorporating ISM codes & manual, MARPOL and IMO requirements for consistent application across vessel operations (including the procurement and decommissioning of vessels). The updated ESMS among others will include: (i) updated ESMS policy; (ii) formal procedures for comprehensive E&S risk identification, assessment and management related to procurement, vessel operations, decommissioning and recycling of vessels (based on recognized international standards such as the Hong Kong Convention); (iii) documented EHS operational manuals, SOPs, practices, and plans; (iv) adequate EHS staffing with clarity of roles and responsibility; training and capacity building of EHS and other staff; (v) emergency preparedness and response, life & fire safety management plan; (vi) stakeholder engagement and community grievance mechanism; and (vii) reporting, monitoring, and management review. Third parties engaged by the companies contractors/third-party service providers and suppliers will be contractually obliged (E&S clauses included in procurement and service contracts) to prepare and implement the various EHS management plans and procedures including compliance with applicable regulations, industry codes relevant to ship types (MARPOL) and international standards. The E&S risk assessment to include design, infrastructure, machinery and equipment risk assessments covering E&S mitigation and management measures and controls including emergency shutdowns, power systems, and other fail-safe features, with clear delegation of duties, periodic audits and management reviews. ESMS update to include a structured EHS capacity building program for staff and crew including (a) Training need assessment in line with the roles and responsibility; (b) training effectiveness review; and (c) ongoing update of training requirement in line with internal and external audit findings.	06/30/2027
2	Implement the Corrective Action Plan (CAP) as an outcome of third-party E&S review commissioned for ASLL shipping operations.	06/30/2027
3	Ensure adequate EHS staffing, including a dedicated EHS focal point at ASLL level with adequate qualifications and experience (preferably erstwhile Environmental Control Officer (ECO). EHS staffs to ensure effective ESMS implementation, periodic update of the CPM, ESMS and IMS, address corrective actions identified through internal and external audits, including training to direct and third-party workers. In addition, ASLL will include a climate risk focal point at the corporate level with adequate qualifications and experience.	10/30/2026
4	Develop corporate level Emergency Preparedness and Response Framework (EPRF) in line with IFC PS requirements, applicable national regulations, industry codes relevant to ship types (MARPOL) and will include climate-related events (e.g. cyclones, storms), building upon existing practices with special attention to in addition to provision for increased frequency of mock drills, emergency specific mitigation and clean-up measures, response equipment, disclosure of incident updates with stakeholders, periodical engagement with stakeholders and affected community on safety measures, communication protocols, a training matrix for contingency roles and post-incident learning checklists. Update the vessel specific Emergency Preparedness and Response Plan (EPRP) in line with the corporate EPRF.	06/30/2027
5	Develop and operationalize SOP for data collection, tracking and evaluation of E&S KPIs related to various parameters such as GHG emissions, reductions in fuel and energy consumption, water consumption, air emissions, noise and vibration, sewage, waste & sludge generation and disposal to shore facilities, hazardous waste, recycling of packaging materials, reductions in electricity, paper consumption, community engagement, labor practices, grievances, OHS records, all forms of violence and harassment including Gender Based Violence and Harassment (GBVH), maintenance and certification of machinery and equipment, Biodiversity performance (e.g ballast water management), Emergency response time, training records etc. This will ensure trend analysis of the KPIs in line with CLASS certification requirement, IFC PS, WBG EHS guidelines, and GIIP. The SOP to include responsibilities for undertaking regular monitoring & execution; conduct periodic standalone E&S reviews and audits; systematic tracking of KPIs; required training for KPI monitoring, tracking and reporting on indicators; undertake regular reporting and ensure structured and regular management reviews of E&S performances.	06/30/2027
6	Update the existing HR manual, in line with IFC PS 2 requirements including: additional compliance with applicable labor laws & IMO requirements; standalone non-discrimination and equal opportunity policy; explicit provisions on harassment prevention, Gender Based Violence and Harassment (GBVH), gender appropriate facilities and practices, and freedom of association; long-term disability coverage and retirement planning (as applicable); updated employee complaints/grievance mechanism including access to third party workers; performance appraisal; retrenchment; management of contractors/service providers and their compliance with statutory labor requirements. The updated HR manual will be communicated to the employees through employee portal (and other means as feasible) and provide training on working conditions and terms of employment as part of employee induction and refresher training from time to time.	01/31/2027
7	Develop corporate level SOPs for bilge, sludge and sewage management beyond vessel-level documentation, ensure that all vessels have valid hazardous materials, garbage, bilge, sludge, oil pollution prevention, ballast water management and antifouling paint certificates and records maintained centrally as required by applicable IFC PS, applicable national regulations and industry codes relevant to ship types (MARPOL). The SOPs shall also include procedures to verify and document how onshore contractors treat or dispose of all waste streams using chain of custody forms to be signed/stamped at the final disposal/treatment facility. SOP should include maintaining an Inventory of Hazardous Materials (IHM) throughout vessel operating life in line with Hong Kong Convention.	06/30/2027
8	Develop and/ or update SOP for Life and Fire Safety (L&FS) as part of the SMS including testing, inspection, and verification of fire systems, with clear roles and responsibility.	06/30/2027
9	Update the CPM with specific provisions related to stowaway and refugee management including engagement while on board, and assurance of their health and welfare.	06/30/2027
10	Develop a biodiversity management procedure to manage risks to marine mammals and biodiversity. The procedure will include: (a) development of navigation procedures, including mitigation and avoidance measures for project vessels passing near biodiversity-sensitive and IMMA areas including a combination of: i) adherence to the relevant legal obligations and guidelines; ii) identify sensitive ecosystems, migratory routes, and protected areas relevant to fleet operations; iii) develop permanent, seasonal and voluntary routing measures for areas to be avoided and port approach routes; iv) short term and dynamic routing measures implemented near the biodiversity rich areas where the vessels shall be encouraged to either avoid these areas to the extent feasible or reduce speeds to 10 knots or less while transiting through them; and pollution prevention measures, including invasive species management (b) annual refresher/new trainings of all crew members by professional marine mammal professional association for monitoring and reporting sightings of marine mammals; (c) presence of at least two trained crew members on the bridge while passing through biodiversity rich areas; d) provision of infra-red and reticulated binoculars in the project vessels; (e) reporting mechanisms in case of any collisions or observations of protected marine species; (f) annual monitoring of effectiveness.	06/30/2027
11	Implement the stakeholder engagement plan (SEP) and the external GM aligned to the IFC PS requirements, including (i) disclosure and dissemination of information to relevant stakeholders including communities on GM; (ii) extend the GM to its contractors and third parties; and (iii) tracking and reporting to stakeholders such as authorities, unions etc. The company will maintain records of stakeholder engagement and grievances.	01/31/2027