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
VGP operates a group-wide Environmental Management System (EMS) that encompasses the full asset lifecycle – from design and construction to operation – integrating the Group’s core environmental, social, and governance commitments, which are generally consistent with IFC PS1. The EMS embeds measures for circular economy, biodiversity preservation, sustainable mobility, energy efficiency, and renewable energy integration, with the overarching goal of achieving carbon neutrality in line with the EU Green Deal and the Science-Based Targets. Technical and performance requirements are defined in VGP’s internal manual that embeds E&S standards and compliance controls across design, procurement, and operations, and is disseminated and reinforced through VGP Academy events to its workers.
E&S objectives are guided by dedicated policies, including but not limited to the Group Environmental Policy, Energy Management and Renewable Energy policies, and standards for sustainable buildings. A suite of social responsibility policies covering Human Rights, Diversity, and H&S, and a Supplier Code of Conduct that extends these expectations throughout the supply chain. Governance is upheld through board-level Environmental, Social and Governance (ESG) oversight, a Corporate Governance Charter, Group Code of Conduct, Anti-Bribery & Anti-Corruption Policy, ESG-linked remuneration, and the Green Finance Framework. All policies and commitments under the EMS are monitored, reported, and subject to continuous improvement.
VGP manages the permitting process for tenants obtaining construction permits prior to the start of construction and, in due time, operational permits, through compliance with applicable national regulations and E&S regulatory permits and requirements during the design, construction, and operational phases. The development and legal team are responsible for obtaining all construction and operational permits, including water supply, sewage connection, electricity, solid waste management, life and fire safety, etc.
Prior to selecting the land for a new development, the company carries out an E&S risk screening involving independent experts to assess aspects such as soil quality, climate risks, noise, traffic, and health and safety. Biodiversity and social risks are addressed through avoidance and mitigation during site selection, prioritizing previously developed or industrial zones and explicitly excluding protected areas, high-value habitats, and locations with residential or community occupation. All VGP land purchases are conducted on a willing-buyer willing-seller basis for pre-zoned industrial or logistics sites, with no involuntary resettlement, economic displacement, or legacy land issues. This approach is supported by legal due diligence to confirm land rights and occupancy, and a formal Land Acquisition Protocol incorporating legal and cadastral verification, stakeholder consultations, and title insurance where needed to determine if sites are legally free of third-party occupation prior to development. All Romanian and Serbian sites are located in previously developed or industrial zones. For the undefined assets under this proposed investment, the company will follow the same E&S risk screening principles to identify, assess and manage E&S risks in relation to the land acquisition. National regulatory Environmental Impact Assessment (EIA) processes provide an additional mechanism for identifying project-related E&S risks and impacts and verifying regulatory compliance. In both Romania and Serbia, such processes are initiated in accordance with local regulatory procedures. In the case of projects developed and under development in these countries, the competent authorities have determined, following the submission of initial screening documentation, that a full EIA study was not required. Findings from the E&S risk screening and regulatory screening documents/ EIAs (as applicable) inform project design, remediation, and E&S management plans, and feed into ongoing monitoring and stakeholder engagement through the EMS.
The Considerate Construction Charter, VGP’s contractually binding internal guidelines, sets standards for all contractors and suppliers regarding environmental quality, sustainable materials, waste reduction, pollution prevention, community relations, and strict H&S compliance. Construction Contractors prepare site-specific E&S management plans for VGP’s approval before work begins, and weekly inspections are carried out by VGP project managers, H&S coordinators, and external consultants. During operations, VGP is responsible for maintaining and managing common areas, shared infrastructure, landscaping, and building systems within its parks. Facility managers oversee preventive and corrective maintenance, building services, and HSE performance to aim for communal spaces to meet VGP’s efficiency, safety, and quality standards, while tenants manage their own equipment and business activities within leased spaces. VGP promotes tenant compliance with its E&S requirements by including green lease clauses — contractual terms requiring sustainable practices like energy data sharing, efficiency improvements, and waste sorting — in lease agreements.
VGP applies a multi-tier ESG governance structure linking Board, corporate, country, and site levels. The Board of Directors, via Audit and Remuneration Committees, has ultimate oversight, integrating ESG into corporate governance and linking performance incentives to ESG KPIs. Executive Management, acting as the Group Sustainability Steering Committee and led by the CEO, sets ESG strategy and monitors delivery against the ESG Strategy Roadmap. A dedicated Group Sustainability Team, reporting directly to the CEO, coordinates policy implementation across regions develops tools and systems, manages sustainability data, and provides training. In each country, Country Management is accountable for local ESG/H&S performance during operations and is supported by ESG correspondents and project-specific Sustainability or HSE Coordinators, who assist in oversight, compliance, and reporting. During construction, site-level EHS Coordinators – from VGP and contractors – oversee daily EHS management, escalating issues through defined reporting lines to corporate level. All H&S roles receive mandatory training. .
VGP integrates emergency preparedness into its EMS and HSE framework through site-specific Emergency Preparedness and Response Plans (EPRPs), preventive inspections, certified fire safety systems, and trained Emergency Response Teams. Plans are developed with tenants and public fire services, addressing hazard scenarios, evacuation procedures, and coordination with external responders, consistent with IFC PS1 and PS4 requirements. Annual drills with tenants and authorities, along with portfolio-wide Life & Fire Safety (LFS) design standards, support strong fire and medical readiness. A reviewed tenant plan confirms VGP’s structured approach, including hazard mapping, inspections, training, and multi-stakeholder coordination; similar processes are applied across the portfolio.
VGP maintains a multilevel monitoring and review system that tracks ESHS performance across construction and operations through annual site reviews, country level consolidated E&S data, and Group oversight. Its KPIs, including emissions, energy, water, waste, biodiversity, OHS, diversity, human rights, and community engagement, are monitored against targets using a suite of tools. Internal audits feed findings and corrective actions into quarterly management reviews and the annual ESG report, while tenants contribute through performance engagement and a compliance hotline. Disclosures are made through the company's annual Corporate Responsibility and Annual Reports, as well as its website, which include dedicated ESG sections. Continuous feedback informs improvements to continuously improve the EMS.
PS 2 – Labor and Working Conditions
The company currently employs 368 full-time employees globally, including Serbia and Romania, where there are 11 direct employees in Serbia (27% female) and 27 (33% females) in Romania. Most employees are on permanent/unlimited contracts, and cover land acquisition and design to construction, energy solutions, tenant engagement, property/asset management, sustainability, compliance and corporate functions. VGP also works with 15-20 contractor companies in both Serbia and Romania who are supporting the construction projects, employing up to 200 workers in each country. In addition, VGP employs specialized third-party companies to support HSE, HR, cleaning and security.
VGP maintains a comprehensive corporate framework of Human Resources (HR) and labor management policies that apply across its operations, underpinned by international labor standards and EU directives. The company’s Diversity Policy, Anti-Discrimination and Harassment Policy, Code of Conduct, and Human Rights Policy collectively promote equal opportunity, non-discrimination, and workplace safety, while strictly prohibiting harassment, bullying, and gender-based violence. The company also prohibits child labor and forced labor and upholds freedom of association.
Corporate-level HR policies and procedures are cascaded to the country level, where VGP is also aligned with national labor legislation on employment contracts, working hours, leave, social insurance, and health and safety. Terms and conditions of employment are specified in written labor contracts and all information relating to the company, the Code of Conduct, and labor and working conditions is provided to workers during the onboarding process. At the country level, the corporate HR team outsources human resource management functions to locally based HR service providers.
VGP has an established complaints management mechanism, called the Compliance Hotline, allowing both workers and external stakeholders to report concerns confidentially or anonymously. The mechanism is outlined in the Code of Conduct and various policies, and offers multiple reporting channels, including email, a telephone line, QR codes at construction sites and an independent external platform accessible to external stakeholders, however, details of the external platform are not currently available on VGP’s contact webpage. All cases are centrally monitored and overseen by the Head of Compliance, with escalation to the CEO for sensitive matters. In 2025, one workplace-related grievance was filed, reviewed, and resolved. Currently, there is no standalone document explaining the grievance management process for both internal and external stakeholders, and there is no dedicated channel or support mechanisms available for the handling of sensitive violence, harassment and discrimination cases.
As part of ESAP, VGP will document a standalone procedure describing the grievance management procedure for internal (direct and contracted workers) and external grievances, overseen by a Grievance Coordinator, also trained to oversee sensitive incidents such as violence, harassment and discrimination, including: a clear documented process from grievance receipt through investigation, resolution, closure, and complainant agreement; defined timelines, roles and responsibilities; established communication protocols; and monitoring and reporting. The procedure will include a dedicated channel for handling sensitive violence, harassment and discrimination cases, in line with a survivor-centered approach, and provide information on and access to appropriate referral pathways for survivors, including psychological, medical, legal and judicial services. VGP will track all grievances in a centralized Grievance Register and induction and periodic training will be provided to internal and external workers to raise awareness of the system. For external stakeholders, a link to the online Compliance Hotline platform will be made accessible on the company website, via the contact page (ESAP #1).
OHS risks from VGP’s own operations are limited. VGP’s Group H&S Policy applies to all employees and contractors and is implemented at country level with support from external qualified HSE specialists from accredited third-party companies, supervised by the Facility Manager. Local teams receive mandatory training in first aid, emergency response and risk control, while contractors must develop project-specific HSE plans aligned with the Policy and the Considerate Construction Charter. Each site has designated EHS Coordinators from VGP or construction contractors, responsible for daily EHS management, ongoing monitoring during construction, engaging with authorities and coordinating with contractors, and reporting to VGP corporate H&S management. Clear roles and responsibilities, weekly safety meetings, integration of preventive measures into work plans, and strict adherence to site-specific protocols (PPE, hazardous materials, fire safety, work at height) ensure robust oversight. Continuous inspections, incident reporting and mandatory worker welfare measures further support effective risk mitigation and safety performance.
The Procurement Department is supported by the Legal and Compliance Team which carries out a risk screening of VPG’s potential suppliers, before selection, including a “Know Your Partner” check and a review of the supplier’s country of operation, to identify potential labor, OHS and human rights risks, and assign a high/medium/low risk rating, with due diligence determined based on the risk rating. All suppliers are also required to commit to the VGP Supplier Code of Conduct. VGP does not source from known high-risk countries or regions, and high-risk categories, such as construction and solar-PV components, undergo enhanced due diligence, including traceability of material origin, confirmation of no sourcing from VGP determined ‘high-risk regions’, certification checks, and termination clauses for non-compliance. This entire process constitutes VGP’s Supply Chain Management System, however, the process is currently not documented. No supplier non-compliance cases have been identified to date in 2024 or 2025.
As part of the ESAP, VGP will document the Supply Chain Management System including the methodology for undertaking a labor, OHS and human rights screening of a primary supplier, reviewing the country risk level, categorizing suppliers high, medium or low risk, and the process for assigning the due diligence effort for its suppliers based on the risk level. As part of the documented procedure, VGP will develop and implement a process for monitoring fifteen (15) primary active suppliers during the contract for potential labor, OHS or human rights risks, and implement a remediation or disassociation procedure in the case of identified cases (ESAP #2).
PS 3 – Resource Efficiency and Pollution Prevention
VGP integrates energy, water, and material efficiency into all developments at the design stage, aligned with its Energy Management and Renewable Energy Policies, the Sustainable Design Framework, and international green building certification requirements. Some of the efficiency practices include high-performance building envelopes (walls, roof, windows, doors, and floors specifically designed and constructed to provide superior levels of energy efficiency), LED lighting, heat pumps, on-site renewable generation, fleet electrification, and sustainable transportation links. Electricity is currently sourced from a combination of on-site solar PV generation and municipal grid supply in Romania, and entirely from the municipal grid in Serbia (though infrastructure is in place for PV panels installation). Water to all assets is supplied by public utilities. Operational performance is monitored and optimized via Building Management Systems (BMS) to implement sustained efficiency and compliance with targets. The company also equips its parks with EV charging infrastructure, while progressively transitioning its vehicle fleet to hybrid or electric models to reduce transport-related environmental impacts.
Pollution prevention during construction is managed through contractor requirements, including the Considerate Construction Charter and Supplier Code of Conduct, which mandate waste sorting, recycling, dust suppression, and stormwater and traffic controls. Group-wide targets reduce air emissions via building design (e.g., replacing natural gas boilers with heat pumps) and low-emission equipment, supported by sustainable mobility initiatives. VGP sites have no industrial-scale combustion, chimneys, or processes generating contaminated air emissions, and comply with local air regulations. GHG emissions are independently monitored and, in 2024, totaled 884 t CO2e/year (total group-wide emissions), remaining well below 25,000 t CO2e/year. In Romania and Serbia, VGP carries out preacquisition screening for asbestos-containing materials (ACMs) and soil or groundwater contamination, remediation in compliance with national regulations, safe removal and traceable disposal of ACMs, and independent verification before construction. Romanian parks, located mainly on previously developed land, have had isolated contamination cases fully remediated, while Serbian projects follow comparable remediation protocols when required. No outstanding legacy pollution issues are reported in either country. VGP utilizes low-impact refrigerants (CO2 and ammonia, rather than Freon gases) and implements strict controls on the storage of hazardous materials. VGP designs storage areas to safety standards, with requirements to the tenants to report VGP any changes for reassessment of the risk. There are no backup diesel-powered generators.
Wastewater is discharged to municipal systems, and waste management practices align with the EU Waste Framework Directive and local regulatory requirements, prioritizing prevention, reuse, and recycling. VGP coordinates with municipalities for waste generated in its parks, while tenants are responsible for managing their own waste, including hazardous streams, through licensed specialist companies. Lease agreements require tenants to comply with applicable waste regulations. VGP oversees waste storage areas and monitors regulatory compliance. r
PS 4: Community Health, Safety and Security
For its new developments, VGP conducts structural safety studies including seismic and flooding risk assessments. The design and construction standards of the buildings follow seismic risk prevention in compliance with applicable local building codes, and VGP’s standards and criteria relating to industrial use, high load-bearing floors, and future-proofing features such as solar-ready roofs, to meet industrial operational requirements and worker safety needs. HSE coordinators oversee construction sites, implementing project-specific safety plans, with compliance verified through regular inspections and senior management review. All new projects undergo third-party audits of international green building certification requirements, and fire safety validation by specialized independent engineers.
VGP follows local regulatory requirements and European Norm (EN) technical standards to ensure consistent fire safety measures across all developments. Standard measures include ceiling-mounted sprinkler systems maintained by VGP, integration of emergency exits into building layouts, and fire scenarios tailored to tenant production processes and materials. For high-risk areas, such as storage rooms containing chemicals classified as dangerous goods, specialized foam-based fire suppression and explosion protection systems are installed based on risk assessments. Fire safety compliance is validated by third-party fire safety engineers at the design, commissioning, and handover stages.
VGP engages licensed private security providers to safeguard property, tenants, and visitors at its parks. In both Romania and Serbia, two to three guards oversee entrances, common areas, and perimeter checks, and receive country-specific training, on emergency response and conflict de-escalation in Romania and, in Serbia, certification and training under the Law on Private Security, including lawful use of force. Incidents must be promptly reported to the police, and the guards are not armed. Contracts mandate adherence to VGP’s Human Rights Policy and Supplier Code of Conduct, promoting respectful and non-intimidating behavior and good community relations. VGP locates its parks primarily within designated industrial areas, with good access to public transport (whenever possible), while avoiding significant residential areas. VGP’s EMS require that traffic risks and impacts be assessed and mitigated as part of both construction and operational phases. During construction, contractors prepare site-specific action plans to manage traffic and noise, with regular monitoring by VGP. During operations, transportation impacts are largely the responsibility of individual tenants. However, facility managers oversee transport-related safety performance and implement corrective actions as necessary, ensuring compliance with local H&S regulations.
