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

It is noted that the actions listed under this previous investment are overdue, however substantial progress has been made in closing out items. Key E&S risks and issues associated with this project will include: a) Ensuring that Life and Fire Safety requirements are met at the Central Rama 2 mall; b) implementing HR policies to promote and assure fair, safe and healthy working conditions for staff and contractors operation; c) management of contractors to ensure that they comply with labor laws, particularly in relation to protection of migrant workers , d) OHS for workers and contractors, e) community health and safety; and f) implementation of Grievance Redress Mechanisms (GRM) with workers and the community.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS1-Assessment and Management of Environmental and Social Risks and Impacts

The Central Rama 2 mall was built on leasehold land in 2002 with a major renovation in 2022. An Environmental Impact Assessment has not been completed as only notification is required under local laws for construction and operation of shopping malls. However, the building was certified as safe and fit to occupy by local authorities. An independent certifier issues a yearly occupation certificate following an inspection. The risks and impacts are identified through the Risk and Opportunity Assessment (ROA) procedure under the ESMS, which also includes Hazard Identification, OHS, Risk and Opportunity Assessment as the major components. The client will align the ROA procedure with the IFC PS requirements


PS2- Labor and working conditions

CPN has a Code of Conduct and Work Regulation that outlines employment standards, working hours, training, leave, employee welfare, wages and benefits, minimum age, training, the principle of equal opportunity, fair treatment, and non-discrimination, including relating to gender-based violence and harassment (GBVH). These requirements apply to the directly employed workforce and are included in induction training. The requirements are also consistent with Thai labor laws.
As part of the CPN Bond investment, a review was undertaken of CPN’s policies and procedures. The review identified several procedural and policy updates to adhere to IFC PS, including developing site-specific management plans for HR related actions; developing and implement human rights training; conducting regular audits of third-party contractor labor conditions and facilities, develop a Labor Accommodation Plan, increasing the awareness of workers of their labor rights and updating the GRM [see ESAP#2]. Further discussion on the findings is outlined below.



PS3-Resource Efficiency and Pollution Prevention

Resource Efficiency
CPN has policies in place on reducing energy, water and use of materials. Central Rama 2 has installed high efficiency lighting, heat recovery ventilation and a high efficiency air conditioning system. The Project also currently operates a recycling program for materials reuse.
Water and Wastewater
A SOP is in place for wastewater management. Central Rama 2 has a wastewater treatment plant (WWTP) with a capacity of 1,500 m3/day, which is close to capacity (currently discharges are 1,310-1,490 m3/day). Wastewater at the site originates from food courts, restaurants and toilets. Wastewater from the food court and restaurants undergoes preliminary treatment through grease traps and septic tanks before being directed to the WWTP for further processing. The effluent is discharged to surface waters. A review of the current wastewater monitoring standards and results show that they comply with national and WBG Guidelines.
Solid waste and hazardous material management
For waste management, CPN has a SOP in place covering segregation, handling, storage and disposal of wastes. Central Rama 2 has adopted the SOP for implementation at the site level. Hazardous waste, domestic waste and food waste is currently separated and managed at source. Licences hazardous waste contractors are hired to manage any such material. A food waste management program is also run to provide edible food to people in need.
Two above ground diesel storage tanks were observed during the appraisal. It was noted that the tank in the backup generator room has secondary containment compliant with relevant standards.
Air emissions
The primary sources of air emissions at the site are limited to diesel backup generators. There are 4 emergency generator sets on-site. It is reported that the on-site team conducts weekly test runs lasting approximately 15–20 minutes. Emission monitoring for these generators is not mandated by national regulations, and no compulsory air quality monitoring requirements apply to the site operations as a shopping mall.
Central Rama 2 has implemented real-time air quality monitoring using multi-gas sensors both indoors and outdoors. Additionally, air quality monitoring is conducted annually. Tested parameters included total bacteria, total fungi, PM10, PM2.5, carbon dioxide, and Legionella spp. The results indicated no exceedances based on national regulations or WBG EHS Guidelines.
GHG Emissions
The estimated GHG emissions for the Project are expected to be 2024 baseline of 43,259.68tCO2e/year; and a projected 2032 emission of 41058.68tCO2e/year, leading to a total of total: -2201tCO2e/year. These results have been simulated based on existing CPN mall assets for the mall’s operational emissions.
Climate
IFC’s review identified a low level of project E&S risks and impacts resulting from a changing climate, including increased temperatures, frequent precipitation and flooding, drought/water scarcity. The client will manage and mitigate risks and potential adverse impacts. The client will monitor and report on their implementation.



PS4-Community Health, Safety and Security

Infrastructure and Equipment Design, Life and Fire Safety
The Central Rama 2 mall has been designed with local building codes, local fire department regulations and local legal/insurance requirements. The design of Life and Fire Safety (LFS) Management Systems are consistent with Thai standards which are based on the United States National Fire Protection Agency requirements. The systems include the provision of sprinklers, fire hydrants, alarms, mobile fire extinguishers, emergency exits and emergency lighting. Regular tests and annual fire drills occur at the site in coordination with local emergency authorities.
The Central Rama 2 building is compliant with local regulations related to earthquakes, tropical storms, and other natural disasters which are prevalent in Thailand. The design of the mall incorporates universal access principles providing accessibility and egress for Persons with Disabilities (PWD).
Traffic Impacts and Transportation Safety
Traffic consists of deliveries for retail shops and patron vehicles. There are no reports of any traffic congestion within the mall or loading dock. The surrounding roads, including Rama 2, suffer traffic congestion, which is a normal occurrence in Bangkok.
Security Personnel:
CPN hires 20 security personnel through licensed security service providers for the Rama 2 mall. These providers have been trained to comply with Thai law. CPN has security procedures and manuals in place and provides mandatory training for all personnel on the use of force and safe community interaction. Rama 2 E&S staff conduct safety inspections of critical and hazardous activities before commencing work. The security staff are trained to manage situations to respect customers and visitors to the mall.

As part of its sustainability framework, CPN regularly engages with its stakeholders, including but not limited to residents, shoppers, tenants, employees, workers, business suppliers and vendors, creditors, NGOs, communities, national and local government units, and media to understand their concerns and issues. Annually, CPN discloses stakeholders' concerns and issues in its annual integrated report. Common issues and concerns identified and raised by employees and workers include occupational health, welfare and safety, training and career development, compensation and rewards, labour practices, and human rights. CPN has stakeholder engagement policies that apply at a corporate and project level but are not specific for each of the malls. The Grievance Redress Mechanism is available for community and customer stakeholders through the CPN website. A Stakeholder Engagement Plan (SEP) will be prepared for the Central Rama 2 site, which is to include the establishment and advertisement of a community GRM [ESAP #5].

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	CPNREIT will through CPN, for Rama 2, review and update the Risk and Opportunity Assessment (ROA) procedure to capture requirements of IFC PS. The ROA will include all environment, social and labor components, as well as, Occupational Health and Safety, life and fire safety, community access and security risks. The Emergency and Crisis Management (ECM) and Safety, Security, and Loss Prevention (SSLP) procedures are to be updated to include further information on crowd and evacuation control for people with disabilities, the elderly and children.	03/01/2026
2	CPNREIT will through CPN for Rama 2 : i) develop site-specific management plans for HR related actions; ii) ensure their recruitment and labor conditions are in line with legal requirements and reflect PS2; iii) conduct regular audits of third-party contractor labor recruitment practices, conditions and facilities, including a labor audit conducted by an independent consulting firm; iv) develop a Labor Accommodation Plan in compliance with IFC Guidelines; v) conduct training to increase awareness of workers of their labor rights; vi) update the Grievance Redress Mechanism for worker grievances; vii) Conduct noise monitoring in plant rooms; and viii) review and enforce the use of Personal Protective Equipment (PPE).	03/01/2026
3	CPN will prepare a Stakeholder Engagement Plan (SEP) for the Central Rama 2 site.	03/01/2026