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.

ESMS. The Company has an Integrated Management System (IMS) governed by Acelen Renewables’s Quality, Health, Environment and Safety (QHSE) Corporate Policy, which outlines the Company’s commitment to legal compliance, risk management, and prevention of community impacts. The IMS is commensurate with the Project’s expected E&S risks and impacts and includes 17 guidelines and supporting management procedures aligned with the principles of ISO 14001:2015, and ISO 45001:2018 standards. Process safety aspects are covered across several IMS guidelines including Critical Safety Elements, Risk Identification and Analysis, Mechanical Integrity, Emergency Management, Operating Procedures, Management of Change and Safe Work Practices. The IMS includes a specific guideline for the construction phase which establishes EHS requirements for managing contractors and controlling EHS risks during project execution, including selection criteria, training and performance monitoring. The construction guidelines will be supplemented with a construction management plan and associated operational procedures.
Identification of risks and impacts. Acelen Industrial’s IMS includes a guideline for systematic E&S risk assessment and hazard identification across project phases, with risks assessed qualitatively and quantitatively, categorized through a risk matrix and prioritized following the mitigation hierarchy.

The Company conducted a climate change risk screening that identified physical risks such as extreme heat, extreme rainfall, water stress, and coastal flooding, \. These risks are being considered in the Project’s design.

For the Project, Acelen Industrial developed a Medium Impact Assessment (MIA) per national law in August 2024 to obtain an environmental license for the biorefinery construction, which was published on June 19, 2025. In August 2025, Acelen Industrial requested to expand the plant's processing capacity to up to 20,000 barrels per day, and the Environmental Impact Study (EIA/RIMA) was submitted in September 2025, in accordance with national legislation. In regards to the Pipeline and maritime terminal environmental licensing, in May 2025, Transpetro initiated the Amendment License process, which was issued in September 2025. The documents submitted in the licensing proceeding provide a baseline of socio-environmental conditions and describe the main impacts on the physical, biotic and social environment, as well as mitigation measures. Furthermore, the gas pipeline and the D-line were excluded from the studies carried out within the licensing proceedings, since the final routing and detailed engineering information was not defined at the time of the assessment.

As per ESAP #1, Acelen Industrial will prepare, per requirements of IFC PSs and relevant WBG EHS guidelines, a supplemental ESIA covering the HEFA plant and Pipeline and an ESIA for the distribution line (D-line) and gas pipeline, addressing potential risks related to land acquisition, biodiversity, indigenous peoples, and cultural heritage. Acelen Industrial will ensure, to the extent possible, that the final design of all Associated Facilities is developed in accordance with IFC’s mitigation hierarchy, prioritizing the avoidance of adverse impacts, including physical or economic displacement and significant impacts on biodiversity and ecosystem services. The ESIAs will include: (i) preparation of a social baseline based on primary and secondary information; (ii) an updated analysis of potential social risks and impacts —including Gender Based Violence (GBV) / Sexual Exploitation, Abuse, and Harassment (SEAH) risks; (iii) if necessary, review of the Project's area of influence; (iv) targeted surveys for priority biodiversity values, engaging experts and collecting primary data as required; (v) an updated air dispersion model; and (vi) the development of corresponding mitigants and control measures for the identified impacts.
In addition, the Company will prepare a Cumulative Impact Assessment (CIA), aligned with IFC’s Good Practice Handbook: Cumulative Impact Assessment and Management (https://documents.worldbank.org/en/publication/documents-reports/documentdetail/787161468178468723), covering the existing refinery, the planned biorefinery, all Associated Facilities, the terminal, and any other existing operations and industries in the area.

Given the gendered nature of the workforce, with higher proportion of male contractor workers, the Company will, as part of ESAP #2 develop and implement a Gender-Based Violence and Harassment (GBVH) Prevention Plan. The Plan will be informed by the results of the socioeconomic baseline and social impact assessment to be developed as part of the ESIAs and include targeted mitigation measures, capacity-building for staff and contractors, awareness initiatives, and monitoring mechanisms.

Acelen Industrial conducted a Quantitative Risk Assessment (QRA) for the biorefinery and the new renewable fuel pipelines following State Environmental Council requirements (CEPRAM for its Portuguese acronym) which are broadly aligned with international standards such as UK HSE. The QRAs were performed to systematically evaluate the major accident scenarios related to loss of containment of hazardous substances. The study for the plant concluded that potential impacts are confined to the project site, with no unacceptable risks to surrounding communities. The QRA for the pipelines confirmed that the inclusion of the pipeline transporting finished products does not significantly increase or change the risk profile and that risks to neighboring stakeholders remain within acceptable limits. Individual risks fall within the ‘as low as reasonably practicable’ (ALARP) category as per UK HSE standards, indicating that while tolerable, further mitigation measures are needed to reduce risks. Complementing the QRA, Acelen Industrial has conducted a Hazard and Operability (HAZOP) study covering process units. The study identified certain operational activities as presenting unacceptable risk, such as furnace explosions, separator overpressure, and failures in marine transfer systems.

As per ESAP #3, Acelen Industrial will update the QRA for the renewable fuels’ pipelines using detailed engineering data and including potential risks to sensitive receptors in the analysis, such as hospitals and schools located near the pipeline corridor. The updated QRA will include an assessment of potential risks derived from existing pipelines and simultaneous operations. Acelen will seek to implement additional measures — such as leak detection and repair (LDAR) systems, sectional isolation, routine asset inspection and maintenance, emergency response planning, and site access and control —to keep risks within ALARP boundaries. In addition, Acelen Industrial will conduct other process safety studies relevant to the safe design, construction, and operation of the plant and related facilities, including a revised HAZOP study; Layers of Protection Analysis LOPA will be performed if required by the HAZOP results, and SIL assessment will be conducted if required based on the LOPA. Identification of Safety Critical Elements (SCE) and development of their Performance Standards; Hazardous Area Classification study; Occupied Buildings Risk Assessment (OBRA); and, Escape and Evacuation Risk Assessment (EERA), among others.

Organizational capacity. Through Acelen Renewables, the Company has a robust organizational structure to manage E&S processes. Oversight is provided by the CEO and four C-Level members covering Institutional Relations and ESG, Human Resources and Social Responsibility, Legal and Governance, and New Businesses, which includes the biorefinery. Dedicated management roles include an ESG and Crisis Management Manager, a Human Resources Director, a Social Responsibility Manager, a Governance, Risk, and Compliance Director, and a Health, Safety, and Environment (HSE) Manager. Managers are supported by specialized staff such as ESG analysts, social responsibility analysts, internal audit and compliance specialists, health professionals, licensing and environmental coordinators, and safety experts.
Emergency Preparedness and Response Plan. As part of its IMS, Acelen Industrial has established an emergency preparedness and response guideline per national law that requires all facilities to develop an emergency preparedness and response plan (EPRP), including procedures for communication, evacuation, and coordination with external agencies, supported by regular training and drills for employees and contractors. For the construction phase of the Project, Acelen Industrial will request each contractor to prepare a specific EPRP in line with the Company’s IMS requirements. For the operational phase, Acelen Industrial has prepared an EPRP that covers identification of credible emergency scenarios, response procedures, equipment and resources, assignment of responsibilities, communication with affected communities, and periodic training and simulation exercises. The biorefinery will be designed, constructed and installed in accordance with national building codes and Good International Industry Practice (GIIP) and will include sensors for toxic substances, smoke and fire detectors as well as alarm systems.

Management and monitoring programs. Acelen Industrial has a monitoring procedure based on legal requirements, covering social, environmental, and occupational health and safety aspects. As part of the IMS, the Company will establish Key Performance Indicators (KPIs) and apply monitoring tools such as internal audits, visual inspections and checklists throughout the Project’s lifecycle. In addition, Acelen Industrial hires specialized EHS management companies to oversee contractor activities. These companies provide support in areas such as document control, regular ESHS inspections, and audits.
Contractor management. During the construction phase, Acelen Industrial will engage third parties, including civil, infrastructure, and electromechanical teams sourced primarily from EPC firms. Acelen Industrial IMS includes specific guidelines to manage the EHS performance of contractors during construction activities. Contracts stipulate fines for violations related to health, safety, labor, social security, and/or environmental obligations. As per ESAP #4, Acelen Industrial will develop a Contractor Management and Assurance Plan (CMAP) for both construction and operations describing the controls and monitoring protocols to ensure all E&S risks and impacts are adequately managed from mobilization and early works, through construction, commissioning and operations.

Supply chain. Acelen Industrial’s feedstock supply chain will meet regulatory and market requirements for sustainability and traceability. All relevant feedstock suppliers must hold certifications such as ISCC EU and ISCC CORSIA and provide eligibility documents demonstrating compliance with EPA(RFS) and CARB (LCFS) requirements. The company has secured feedstock contracts (UCO and SBO) with certified suppliers for 90% of the plant capacity. An internal traceability tool is being developed to centralize and manage documentation that evidences compliance with deforestation control requirements, while interim procedures will address non-deforestation standards until the tool is fully operational. As per ESAP #5, Acelen will develop and implement a Supply Chain Management System aligned with PS2 and PS6 requirements, through the following activities: (i) develop a supplier mapping and risk assessment process, (ii) implement Standard Operating Procedures (SOPs) to identify and manage risks in the supply chain, and (iii) commission third-party audits, conducted exclusively by authorized certification bodies, to monitor high-risk suppliers. The supplier mapping and risk assessment will cover all segments of the supply chain to identify high-risk suppliers. The SOPs will include: (i) a procurement policy and supplier code of conduct addressing child and forced labor, significant safety issues and conversion of natural habitat; (ii) contractual clauses prohibiting forced labor and child labor, conversion of natural habitat and compliance with the code of conduct, extending this obligation to lower-tier suppliers. The third-party labor audits will be conducted on a representative sample of suppliers in line with PS requirements, with corrective actions implemented as needed.

PS 2 – Labor and Working Conditions

Working conditions and management of worker relationships. Acelen Renewables had 304 employees at the time of the appraisal, with over 37% of positions being held by women. Acelen Industrial´s will hire most of the workforce in 2026. It is envisioned that Acelen Industrial will have 38 direct employees for the construction period and 220 direct employees for operations. Around 3.600 contracted workers will be hired during the peak of construction activities.

No accommodations for workers will be built as part of the Project. During construction activities, workers will be lodged off-site in nearby hotels and rental properties. Accommodation for workers is not envisioned for the operational phase either. As part of the CMAP, Acelen Industrial will include provisions to assess and manage accommodations in accordance with Brazilian Regulatory Standard NR-24 and with IFC/EBRD Guidance Note. During construction, potable water for human consumption will be supplied in gallons at the worksite. For the operational phase, potable water will be provided through a dedicated treatment and distribution system.

HR practices are documented in a series of policies and procedures which cover recruitment and selection, compensation, benefits, leave, termination processes, insurance and others. Employment contracts follow the Brazilian labor law (CLT) and include both fixed-term and indefinite-term arrangements, apprentices and interns. In addition, Acelen Renewables maintains a formal relationship with labor unions through a Collective Bargaining Agreement (Acordo Coletivo de Trabalho – ACT) and Acelen Industrial will sign new ACTs once construction activities begin in 2026. Working conditions are aligned with national labor regulations and consistent with PS2.

As per ESAP #6, Acelen Industrial will develop and implement a Local Hiring Management Plan aligned with IFC PS2 requirements. The plan will include workforce analysis, recruitment strategy prioritizing local communities, equal opportunity measures, training programs, and monitoring KPIs. In addition, the plan will be implemented in coordination with the Contractor Management and Assurance Plan to ensure that all contractors and subcontractors follow the Company’s local hiring commitments.

Non-discrimination and equal opportunity. Acelen Renewables has a Code of Ethics and Conduct (Codigo de Ética e Conduta - COEC) that prohibits all forms of harassment, bullying, abuse of authority and discrimination based on gender, race, ethnicity, religion, sexual orientation or disability.

Grievance Mechanism. Acelen Renewables provides an ethics channel accessible via the Company’s website (www.canaldeetica.com.br/acelen), email (acelen@canaldeetica.com.br), and phone (0800 377 80007), and anonymous complaints are permitted. This channel is managed by an independent third party and enables individuals to report behaviors considered in violation of the COEC or applicable laws. The Ethics Committee investigates all reports. Acelen Renewables has documented the Rules of Procedure, outlining the structure, responsibilities, and processes of the Audit, Risk & Compliance Committees, as well as a separate document detailing grievance investigation steps. However, these documents do not require women’s representation on the Committee – an important measure to prevent biases and address gender-specific concerns.

As per ESAP #7, the Company will update its grievance mechanism procedure to outlines available channels to submit grievances unrelated to violations to the COEC, roles and responsibilities for treating and responding to grievances, timelines for taking action and a system to log, track and report grievances and their status. This procedure will include a non-retaliation commitment towards any workers that have chosen to file complaints and Acelen Industrial will implement internal awareness campaigns to ensure that the procedure is well understood by its employees and ensure that the internal reporting channel is trusted. Further, Acelen Industrial will develop a survivor-centered procedure for managing sexual harassment complaints that will provide safe and accessible reporting channels (including anonymous options), ensure survivor protection, prohibit retaliation, offer specialized support services for survivors (e.g., medical services, counseling, legal assistance, job reassignment, etc.), and require timely investigation and resolution.

Protecting the Work Force. The COEC explicitly prohibits child labor, forced labor, and any form of human rights violations, extending these expectations to all third-party contractors and suppliers. Further, Acelen Renewables and Acelen Industrial only hire individuals over the age of 18, including young apprentices.

Occupational health and safety. The Project’s main occupational health and safety (OHS) risks are associated with the presence of hazardous substances, including potential exposure during site remediation, construction, and operational activities. Key risks include fire and explosion hazards, particularly in fuel handling areas. During remediation activities, workers may be exposed to inhalation of contaminant vapors, dermal contact with contaminated soil and accidental soil ingestion. During construction, workers may be exposed to extreme weather conditions, heavy machinery operations, confined space entry, and excavation, and man-machine interface hazards. Acelen Renewables has implemented an OHS management system aligned with ISO 45001:2018 OHS Management Standard, supported by documented policies, procedures, and operational controls. These include mandatory OHS training, operational risk assessments, incident investigation, worker health surveillance workplace air monitoring and a permit-to-work system for critical activities such as work at heights, confined space entry and energy isolation. Additionally, all vehicles, machinery, and equipment will be subject to inspection and certification prior to use. As outlined under PS3, Acelen RefMat will develop site specific OHS procedures for remediation activities (ref. ESAP #12).

Simultaneous operations (SIMOPS) will occur during activities civil works in Pipeline construction while existing pipelines remain in operation, and during loading and offloading activities at the terminal. To mitigate risks associated with concurrent activities through the Project lifecycle, as per ESAP #8, Acelen Industrial will develop and implement a comprehensive SIMOPS procedure that includes hazard identification, interface coordination, and emergency preparedness and response measures.

Workers engaged by third parties. As outlined under PS1, Acelen Industrial will develop a CMAP for both construction and operations describing the controls for third-parties. The CMAP will include provisions to assess and manage accommodations in accordance with Brazilian Regulatory Standard NR-24 and with IFC/EBRD Guidance Note on Workers’ Accommodation: Processes and Standards (https://www.ifc.org/en/insights-reports/2000/publications-gpn-workersaccommodation). These requirements will be reflected in the contracts with relevant accommodation providers. Contractors will be required to adopt local hiring commitments as established in the Local Hiring Management Plan.

PS-3 Resource Efficiency and Pollution Prevention

Resource use. Main resources to be used in the process in addition to feedstock, include electricity, water, and natural gas which will be provided by local concessionaires (Coelba for electricity, Embasa for water and BahiaGas for gas) through tie-ins to existing networks near the plant. In addition, the production of RD and SAF will generate LPG and green naphtha as byproducts. Green naphtha can be either sold or used to produce hydrogen, reducing the dependance on external natural gas.
GHG emissions: Main sources of GHG emissions include steam reform reaction to produce hydrogen, fuel gas to produce energy and the flare, whose operation will not be continuous. Estimated emissions for the Project are 202,546 tCO2e/yr (Scope 1) and 31,127 tCO2e/yr (Scope 2), with an expected GHG emissions avoidance of 2,182,341 tCO2e/yr.

Air emissions. Main air emission pollutants expected at the refinery are volatile organic compounds (VOCs), particulate matters (PM), nitrogen oxides (NOx) and sulfur oxides (SOx) emitted from three stacks serving hydrogen production, hydro processing, and acid gas handling units. According to the EIA, predicted concentrations range from 189 to 320 mg/Nm³ for NOX and from 9 to 70 mg/Nm³ from SOX, all within the national air emission legal limits. As per ESAP #9, Acelen Industrial will upgrade the technical design of pollution prevention measures to achieve compliance with air emissions standards of WBG EHS Guidelines for Oleochemicals Manufacturing, CONAMA (Conselho Nacional do Meio Ambiente) and, where applicable, the WBG EHS Guidelines for Petroleum Refining. Further, Acelen Industrial will improve its air emissions monitoring procedures in alignment with WBG EHS Guidelines as applicable.

Air quality. As part of the EIA, dispersion modeling using AERMOD simulated PM10, NO2, and SO2 emissions under a synergy scenario with RefMat. Predicted concentrations for all modeled pollutants are below national and ambient air quality standards. However, the model does not include flare emissions for the biorefinery nor ambient air quality baseline data. As part of the supplemental ESIA (ref. ESAP #1), Acelen Industrial will submit an updated air dispersion modelling report covering all emissions sources and including baseline data for air quality. In addition, the Company will implement a VOC Emissions Management Plan, including fugitive emissions inventory, LDAR, among others.

Liquid effluents. The Project will generate wastewater from industrial processes (fuel production, hydrogen generation, and water treatment), sanitary facilities, and stormwater runoff. All process and sanitary effluents will be treated within the biorefinery in wastewater treatment plants (WWTPs) using a combination of physical-chemical and biological processes that will meet national effluent quality standards. The treated effluent will be transported to RefMats’s WWTP via a tie-in. According to recent effluent monitoring reports, RefMat’s WWTP effluent quality is overall compliant with standards established by Brazilian regulations (CONAMA 430/2011) and the WBG EHS Guidelines for Petroleum Refining. As part of its licensing conditions, RefMat will implement measures to improve the dispersion of WWTP effluents at the discharge point. As per ESAP #10, Acelen Industrial will
improve the biorefinery’s WWTP) design to achieve compliance with effluent standards of the WBG EHS Guidelines for Oleochemicals Manufacturing, CONAMA, and, where applicable, the WBG EHS Guidelines for Petroleum Refining. . Further, as part of the supplemental ESIA (ref. ESAP #1), Acelen Industrial will commission a Cumulative Impact Assessment to evaluate the potential impacts of effluent discharge into the Baía de Todos os Santos by the Project and propose mitigation framework, if necessary.

Water quality. The main water bodies surrounding the Project site are the Rio Mataripe, Rio São Paulo and Baía de Todos os Santos. Baseline data from the EIA indicates that both these rivers show signs of historical industrial pollution, including low dissolved oxygen and high concentrations of phosphorus, organic carbon, and metals (manganese and zinc). Bioaccumulation of metals was also detected, with copper, chromium, and zinc concentrations exceeding legal limits in crustaceans tissue sampled from mangrove areas near the project site. No significant concentration of hydrocarbons was detected. Monitoring of Baía de Todos os Santos between 2016 and 2024 shows stable water quality, with nutrients, heavy metals, and polycyclic aromatic hydrocarbons below quantification limits. Given evidence of historical industrial impacts and degradation of local mangrove ecosystems, as per ESAP #11, Acelen Industrial will engage a qualified environmental consultant to conduct sediment sampling and analyze key contaminants in the Rio São Paulo, Rio Mataripe, Baía de Todos os Santos and other relevant adjacent water bodies, supplementing the studies already carried out in the environmental licensing process. Directional drilling will be used to minimize potential impacts on surface water bodies during the installation of the pipelines.

Hazardous and industrial solid waste. As per the EIA, Acelen Industrial’s waste storage areas will be constructed following the ABNT (Associação Brasileira de Normas Técnicas) technical requirements, including impermeable floors and secondary containment to prevent soil and groundwater contamination. Temporary storage areas will be properly contained and identified, and all waste will be transported by licensed companies to authorized facilities offering Class I (hazardous waste) and Class II (non-hazardous waste) sanitary landfills, as well as co-processing services, preferably within a 50 km radius of the project. Acelen Industrial has developed a Civil Construction Solid Waste Management Plan and a Solid Waste Management Plan.

Management of hazardous materials. In addition to hydrogen and renewable fuels for which a QRA has been developed as stated under PS1, the main hazardous materials that will be present on-site include heavy distillation bottoms, lubricating oils and chemical reagents. Hazardous substances will be stored in secure areas with secondary containment and managed following the requirements of Acelen Industrial’s IMS.

Environmental noise. As per the EIA, the Project area is designated as industrial, and due to the distance between the site and nearby communities, significant ambient noise levels are not expected. Noise measurements at the property boundary are anticipated to meet Brazilian norm NBR ABNT 10.151. and WBG EHS Guidelines.

Soil and groundwater pollution. Part of the Project land was historically used for the disposal of construction and industrial waste between 1973 and 2012. Following the requirements of CONAMA Resolution 420/2009, Petrobras and Refinaria de Mataripe S.A. (RefMat) conducted several studies from 2016 to 2025, including confirmatory and detailed investigations covering 3D pollutants transport modeling and a health risks assessment to assess and characterize the pollution related with the waste dump. The studies identified pollution in soil and groundwater, including metals and organic compounds, particularly in the southern section of the site. The northern section of the site shows no evidence of contamination. RefMat is responsible for the remediation of the site and therefore, developed the site remediation plan and submitted it to authorities in July 2025. The environmental authorization was granted by INEMA on November 1, 2025. As requested by ESAP #12, Acelen Industrial will engage a third-party specialized technical and EHS advisor acceptable for IFC to: i) ensure that all remediation activities are carried out in compliance with the remediation plan approved and duly licensed by INEMA, strictly following the guidelines, procedures, and conditions established in the referenced instrument ; and, (ii) monitor, supervise, and report on the progress of site remediation works, including submission of a Post-Remediation Verification Report.

PS-4 Community Health, Safety and Security Personnel

The Project’s Direct Area of Influence includes several urban and rural communities in São Francisco do Conde and Candeias, Bahia. Main impacts related to the Project include influx of workers, increased traffic and temporary disruptions due to construction works, which will be managed by the Local Hiring Plan, the Code of Ethics and Conduct, the Contractors Management and Assurance Plan, the Traffic Management Plan, the Security Management Plan and the Ecosystem Services Management Plan as well as any other mitigation measures resulting from the revised ESIA.

Infrastructure and Equipment Design and Safety. The Project related infrastructure, including the biorefinery units and pipelines, will be designed, constructed and installed in accordance with national building codes, GIIP and relevant standards and codes (e.g. API, ASME, NFPA). As per ESAP #13, Acelen Industrial will undertake an operational readiness review completed by competent professionals prior to start of commercial operations and develop and implement an asset integrity management plan including a Risk-Based Inspection (RBI) program covering biorefinery units, tanks and pipelines.

The plant will include a fire protection system which includes a 20,000 m³, automatic foam injection systems, floating roof tank protection, detectors, portable extinguishers, and cooling water firefighting systems for high demand areas such as the RD and SAF tanks.

Emergency preparedness and repose planning. As mentioned under PS1, Acelen Industrial will request each contractor to prepare a specific EPRP for the construction phase and have prepared an EPRP for the operational phase. EPRPs will be developed in line with the Company IMS requirements which require communication protocols to inform neighboring communities and public agencies such as municipal health authorities and civil defense. As per ESAP #14, the EPRPs for the terminal and the Pipeline (Contingency Pipeline Plan) will be updated together with Transpetro and surrounding communities will be incorporated into emergency drills and exercises.

Hazardous Materials Management and Safety. As described under PS1 section, Acelen Industrial will develop an updated QRA to further assess the risks of the pipeline and implement adequate mitigation measures to avoid and minimize impacts on affected communities. Emergencies will be managed in accordance with Acelen Industrial and/or Transpetro’s EPRP.

Road Safety. During construction, over 600 pieces of equipment will be transported to the site and Acelen Industrial commissioned a geometric feasibility study for transporting oversized equipment to the biorefinery to identify viable transport routes, evaluate physical and logistical constraints and determine the necessary interventions and permits required. The study will be adjusted once the logistics company in charge of transporting equipment is secured and the final transportation route is decided. In addition, Acelen Industrial has developed a Traffic Management Plan for the construction phase that identifies road safety risks and community impacts from increased heavy vehicle traffic, and sets out mitigation measures such as safe routing, speed control, emergency access, and ongoing stakeholder communication.

Security Personnel. The Project will engage a licensed security company to provide security services. As requested by ESAP #15 Acelen Industrial will develop and implement a Security Management Plan in line with PS4 and the IFC Good Practice Handbook on the Use of Security Forces (https://www.ifc.org/en/insights-reports/2017/publications-handbook-securityforces) that outlines principles of proportionality and good international practices, including security forces vetting, equipping, monitoring, and training on Human Rights and SEAH. Security workers will also adhere to Acelen Renewables’ Code of Conduct.

Ecosystem services. As part of its risks and impacts identification process, Acelen Industrial conducted an ecosystem services assessment to identify potential impacts of the Project on local communities and their reliance on ecosystem services. The assessment included consultations with affected communities and highlighted five critical services (freshwater, artisanal fishing, marine and estuarine habitats, traditional identity, and mangrove nurseries) considered essential for food security, cultural cohesion, and ecological resilience. According to the assessment, the Project is not expected to cause significant adverse impacts under its current design and potential risks could include changes in bay water quality and mangrove degradation due to alterations in water quality from effluent discharge resulting in loss of fishing opportunities. To mitigate these risks, as per ESAP #16, Acelen Industrial will develop an Ecosystem Services Management and Monitoring Plan following PS requirements focused on adaptive management protocols to respond to cumulative impacts. The plan will: (i) ensure continuous monitoring of water quality and effluent parameters, (ii) promote stakeholder engagement; and (iii) include periodic review and adjustment of mitigation measures based on monitoring results and community feedback. The plan will be maintained throughout the project's lifecycle to ensure timely corrective actions and protect essential ecosystem services directly attributed to the project for the well-being of the community.

PS5 - Land Acquisition and Involuntary Resettlement
A D-line of approximately 11 km will connect the Project to the Jacaracanga substation, and over 250 pieces of equipment will be transported from nearby ports to the site. The final transportation strategy and D-line route were not decided at the time of the appraisal. Acelen Industrial is evaluating different alternatives for these in line with the mitigation hierarchy, exploring options to avoid any land acquisition or resettlement while minimizing economic displacement. Acelen Industrial will develop a Land Acquisition and Compensation Framework per ESAP #17 to assess, avoid and manage any potential resettlement risks. The Framework will include a socioeconomic survey to identify potentially affected people and assess physical or economic displacement risks. The Framework will include provisions to if required, implement a Resettlement Action Plan and Livelihood Restoration Program consistent with the requirements set forth in PS5.

PS6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project and its Associated Facilities are located in the Bahia Coastal Forests ecoregion, an endangered area with sensitive habitats such as mangroves and restinga. The biorefinery will lie on a historic waste site with low biodiversity but containing patches of secondary forest. The finished products pipeline will cross the Área de Proteção Ambiental Bahia Todos os Santos (IUCN Category V), and the D-line will intersect the Área de Proteção Ambiental Joanes–Ipitanga (IUCN Category V).
Priority Biodiversity Values within the wider project area include the Globally Critically Endangered Buff-headed Capuchin (Sapajus xanthosternos), Globally and Nationally Endangered Coimbra-Filho’s titi monkey (Callicebus coimbrai), the restricted range lizards Leposoma annectans (IUCN Global Redlist, Least Concern), and restricted range bird species. Preliminary screening for the biorefinery, the gas pipeline and water pipeline found no evidence of Critical Habitat (CH). A biodiversity baseline was conducted as part of the biorefinery permitting process.

Removal of about 4.65 ha of native vegetation has been authorized for the construction of the biorefinery, and the Company plans to offset this loss by restoring and protecting similar habitats within the same micro-basin as per permit conditions. The gas pipeline and water tie-in will be located along other existing infrastructure and minimal impacts are expected. Although the Pipeline will cross watercourses, directional drilling will be employed to avoid direct disturbance of surface water bodies. As part of the supplemental ESIA for the HEFA and Pipeline and ESIA for the D-Line and gas pipeline outlined under PS1 (ref. ESAP #1), Acelen Industrial will conduct targeted surveys for priority biodiversity values, engaging experts and collecting primary data as required. The supplemental ESIA for the HEFA and Pipeline and ESIA for the D-Line and gas pipeline will include (i) calculations of loss and gain to both meet legal regulatory compensation requirements and deliver No Net Loss of Natural Habitat, and a strategy to achieve Net Gain requirements for CH, if required; (ii) a robust monitoring program during construction and project operations to track towards NNL/NG targets; and (iii) additional conservation actions aimed at enhancing the conservation objectives for protected areas within the project’s area. Further, as per ESAP #18, Acelen Industrial will define and track all mitigation measures related to avoidance, minimization and on-site restoration and monitoring for the biorefinery, and Associated Facilities in a Biodiversity Management Plan (BMP).
With respect to the 11 km 69 kV D-line associated with this site and to ensure conformance with PS6 requirements, to inform the ESIA for the D-Line per ESAP #19, the Company will: (i) hire a qualified ecologist with experience on powerlines lines to conduct a habitat classification along the D-line with respect to PS6 definitions; and (ii) identify priority species at risk of collision and electrocution of wildlife. Further, Acelen Industrial, will seek i) to avoid habitats of highest risk; ii) select designs that minimize the risk of bird electrocution; (iii) install bird flight diverters in habitats associated with priority birds; (iv) maintain bird flight diverters for the duration of the Project; and (v) hire an international consultant with experience in fatality monitoring to design a fatality monitoring program for birds and procure a team of biologists to undertake fatality monitoring as needed and report on results for the first three years of Project. Mitigation measures will be implemented by the Company in a manner commensurate to the Company’s control and influence. The Company will meet No Net Loss and/or Net Gain as applicable.

Sustainable Management of Living Natural Resources. The Company intends to develop and operate 180,000 ha of macaúba plantations which is being supported as part of an Upstream project. PS6 will require Acelen Industrial to avoid the conversion of Natural/Critical Habitat and apply sustainable management practices as demonstrated by certification or verification to a recognized standard(s). However, the assessment of plantation management is not part of this investment.
Ecosystem Services. The Project is located near mangrove, aquatic and forested ecosystems that provide critical services to local communities, including fishing, shellfish gathering, subsistence farming, and firewood collection. These activities are closely linked to biodiversity values and local livelihoods. The Project will safeguard aquatic biodiversity, implementing measures to manage effluent discharges to compliance with applicable national legislation and WBG requirements as identified in ESAP #10 and #16. These actions aim to maintain ecosystem integrity and support the continued provision of essential services to local communities.

Supply Chain. For feedstock, the Project will enter contracts to source Used Cooking Oil (UCO) from China, Malaysia, Indonesia and Singapore, and soybean oil (SBO) from Argentina and Brazil for the first five years. UCO will be supported by documentation evidencing compliance and eligibility with EPA and will carry ISCC EU or ISCC CORSIA certifications to meet export and sustainability standards. Soybean oil will be supported by documentation evidencing compliance and eligibility with EPA (RFS) and CARB (LCFS) requirements. Acelen Renewables plans to gradually transition to a full integration with macaúba feedstock, a native Brazilian crop, , targeting the plantation of 178,000 ha of macaúba by 2034 managed to ISCC/EPA/CARB standards (plantations were not assessed as part of this investment). As plantations reach maturity it is expected that macaúba oil will become the dominant source of feedstock. Acelen Industrial will develop and implement a Supply Chain Management System to manage risks associated with PS6, including a supplier mapping and risk assessment process and third-party audits (ref. ESAP #5).

PS7 – Indigenous Peoples The EIA identified quilombola communities near the project area: , Monte Recôncavo, Ilha do Paty, Boca do Rio Aratu, and Ilha da Maré. Monte Recôncavo, Ilha do Paty and Ilha da Maré are located less than eight kilometers from the site. Some of these communities were engaged by Acelen Industrial through Free, Prior, and Informed Consultation, as required by the environmental agency. As mentioned in the PS1 section, Acelen Industrial will prepare a supplemental PS-compliant ESIA for the HEFA plant an ESIA for the associated facilities (ESAP #1) to confirm the project area of influence, assess potential risks and impacts on these communities. If impacts are confirmed, Acelen Industrial will implement culturally appropriate measures to avoid, reduce, restore, or compensate for such impacts.