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
Environmental and Social Management System and Policies. Genica has in place a set of policies and procedures related to E&S risks and impacts, including a Code of Ethics and Conduct (CoE&C), selective waste collection initiatives and other procedures aimed at reducing risks to employees, partners, the environment and the surrounding community. Biosafety procedures establish guidelines regarding general biosafety standards in the laboratory, protection mechanisms against handling toxic products, potential pathogenic microorganisms or material contaminated with pathogens. All employees have workplace-related accident insurance, as per national regulations.
Genica has established certain elements of an ESMS in line with national regulations; the Company will strengthen its ESMS framework to align it with Good International Industry Practice (GIIP), IFC PS and WBG Guidelines to include: (i) the preparation, approval and implementation of a corporate Sustainability Policy encompassing all environmental, social and health & safety aspects of the Company’s activities (ESAP#1); an ESMS Manual that consolidates all policies and procedures related to the management of environmental and social aspects of the Company according to PS 1 requirements (ESAP#2).
Organizational Capacity. Genica’s organizational chart includes units and people responsible for Environmental, Occupational Health and Safety, HR, Security and Community Engagement aspects. The EHS team is currently composed of a Coordinator, an OHS technician and two apprentices, and reports directly to the Director of Operations and Innovation. The Company has a training plan in accordance with the risks involved in each of its operations.
Genica’s Finance Department is responsible for labor and working conditions, recruitment and training; the Legal Unit is in charge of the Company’s grievance mechanism and compliance with the CoE&C; the Supply Unit performs due diligence of contractors and suppliers and the Regulatory Unit is responsible for the Company’s licensing process and commercialization permits.
Identification of E&S Risks and Impacts. The Company is currently developing a matrix for identifying and assessing the environmental aspects and impacts of its activities and facilities, that partially aligns with PS1 requirements. As per ESAP#3, Genica will establish and implement a structured, company-wide risk identification and assessment process aligned with IFC PS, GIIP and the applicable World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines. The process will consider, at a minimum, air emissions and ambient noise; wastewater discharges and water intake; solid and hazardous waste management; spill prevention and containment; fire safety; hazardous materials management (e.g., fuels and chemicals); resource efficiency (energy, water, and materials); and assessment and management of E&S and OHS risks related to the construction of new facilities.
Genica’s products are approved through a regulatory process led by the Brazilian Federal Ministry of Agriculture (MAPA). Registration stages include i) documentation and submission of the request, ii) technical assessment and public consultation, iii) opinion and final decision, and iv) post-registration monitoring by MAPA. In the case of biocontrol products (fungicides, insecticides) the health (ANVISA, National Health Surveillance Agency) and environmental (IBAMA, Brazilian Institute of Environment and Renewable Natural Resources) agencies are consulted.
E&S Management and Monitoring Programs. The Company conducts internal and external EHS audits annually and maintains all required environmental licenses and permits, including R&D and commercialization licenses, LFS-related permits and all the regulatory permits for the business activities of the Company. The Company’s monitoring system is mainly related to the EHS country regulation requirements, including waste management, incidents and accidents in its facilities.
As per ESAP#4, Genica will develop and implement E&S Management and Monitoring Plans and E&S KPIs aligned with IFC PSs and applicable WBG EHS Guidelines. E&S plans will include, among others, a Contractor Management Plan, including EHS training programs and monitoring and reporting procedures; contractors and subcontractors will be contractually required to prepare and implement site-specific EHS management plans aligned with the WBG General EHS Guidelines (2007), addressing, at a minimum, solid and hazardous waste management, air emissions and ambient air quality, water use and groundwater abstraction, traffic safety and control. KPIs will include, among others, resource efficiency (energy and water) and greenhouse gases, as well as waste management, and the date will be disclosed annually in the Company’s Sustainability Report.
Emergency Preparedness and Response Plan (EPRP). Genica has in place an EPRP that includes emergency preparedness and response measures to address situations such as accidents and fire at the Company’s laboratory. Emergency exits are clearly marked, and evacuation exercises and fire drills are conducted annually in coordination and involvement of the local Fire Service Department. Staff members receive regular training and participate in emergency drills.
PS2: Labor and Working Conditions
As of October 2025, the Company had 297 employees with several types of contracts, including 236 formal permanent staff, 52 self-employed sales representatives and 9 cooperative members.
Human Resources Policies and Procedures: Genica’s HR Department includes a unit in charge of sustainability that prepares the Company’s annual Sustainability Report. The Company has in place policies and procedures that include a CoE&C, applicable to all employees, with provisions related to the prohibition of any type of harassment, discrimination or violence, including sexual harassment and moral harassment as well as sanctions to anyone who engages in any type of harassment. Most employees are hired under a collective agreement with the Chemical Workers Union. Within the Company operates an Internal Accident Prevention Committee (CIPA); all CIPA members are trained on workplace and sexual harassment.
The Company will develop and implement a corporate HR Policy (ESAP#5) as per requirements of IFC PS2 and national law, that integrates all existing human resources practices such as recruitment, onboarding, compensation, including overtime, employee development, performance management and employee relations; the HR Policy will cover all types of employees.
Working Conditions and Terms of Employment. Genica’s payrolls includes: i) formal employees, administered according to Brazilian labor laws with fixed salary and variable compensation according to the collective bargaining agreements; ii) self-employed sales officers hired as service providers, who receive payment via commissions based on sales, fuel allowance and expenses for client-related activities; iii) cooperative members, that are hired through a Cooperative as service providers and Genica makes payments to the cooperative. Formal employees receive benefits such as life & health insurance, dental plans, food & transportation vouchers, childcare assistance and assistance for children with disabilities. Self-employed and cooperative members are contracted as service providers; in the case of cooperative members, they are formal employees of the Cooperatives and the contracts are signed between Genica and the cooperative on a service provision model. Almost 100% of the Company’s permanent employees are unionized.
Genica’s Employee Handbook includes information on terms of employment, such as type of contracts, working hours, compensation, benefits, rights and responsibilities, disciplinary procedures, etc. The Company operates a Mental Health Platform that offers mental health, financial, legal and nutritional support to formal employees.
Workers Grievance Mechanism. The Company has hired a third-party service to improve its current grievance management process; the new service is provided by Contato Seguro, a specialized platform focused on governance and the screening of reports or complaints. This channel’s main features include confidentiality, impartiality, governance and the management of all matters submitted through the platform. The analysis of and actions related to each report are evaluated and decided by the Ethics Committee, composed of Senior Management and the Legal Team. Managers are instructed to contact the HR team in cases of harassment; they are advised not to investigate harassment cases on their own.
As per ESAP#6, Genica will enhance its grievance management procedure to provide access to it to all its employees (formal, self-employed and cooperative members) and to third parties, and to include specific actions to address complaints related to Gender Based Violence (GBV), sexual harassment and discrimination in an expedite, safe and confidential manner, including specialized training to the people involved in the management of such complaints.
Occupational Health and Safety (OHS): Genica implements occupational health and safety measures, including controls for exposure to adverse environmental conditions, preventive guidelines, use of PPE and monitoring of working conditions. The Company provides annual training to employees on preventive safety in electrical systems, correct use of emergency equipment, machinery and equipment, boilers and pressure vessels, preventive measures in the operation of hoists and forklifts, fire prevention and fighting, confined spaces, training on accident prevention at work. In 2025, 9 work-related injuries were reported, 5 of them resulting in lost-time injuries (39 lost days) with no fatalities, as well as 3 vehicle accidents. The Company prepares investigation reports for lost-time injuries.
The safety of laboratory workers at Genica is guaranteed by a combination of labor standards (NRs), biosafety legislation and ANVISA (health regulatory agency) regulations, which together require risk assessment, training, use of protective equipment, medical monitoring and specific procedures to minimize occupational and biological risks in the workplace.
During construction of the new facility, the Contractor Management Plan described above under ESP#4 will be implemented to ensure proper management of E&S and OHS issues related to construction activities.
Workers Engaged by Third Parties and Supply Chain: The Company maintains formal procedures for contracting services through internal processes and contracts. Each contract includes a description of services, scope and responsibilities of suppliers and contractors. A list of primary suppliers is maintained by the Purchasing Department, including a classification of suppliers based on business relevance and volume. All contracts and commercial agreements are subject to legal review by the Legal Department; standard contractual terms include compliance with applicable laws and regulations.
The CoE&C establishes that Genica does not use any type or form of forced, child or slave labor and does not engage with clients, partners, suppliers or service providers that employ labor under these conditions or outside the guidelines set by national labor legislation. These principles apply not only to the Company’s employees but also to the relations with clients, suppliers and business partners. The Code includes a specific section that outlines the rules governing relationships with third parties (clients, partners, suppliers and competitors).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. In 2025, energy consumption by Genica reached 2,309,537 kWh of electricity from the grid, 176.796 of LPG and 2,000 liters of diesel fuel. The Company operates three diesel generators that are used as back-up power sources and are activated in the event of a power outage to ensure continuity of operations. In 2025, water consumption reached 8,760 m3; currently, Genica does not perform water reuse or recycling in its operations. Currently, the Company does not have a structured process to monitor energy and water consumption or formal measures aimed at reducing their use. As per ESAP#4, Genica will develop and establish E&S KPIs and monitoring procedures to improve resource efficiency (energy and water) within the Company.
GHG Emissions: The Company monitors and complies with the legal and environmental requirements applicable to its activities through its environmental management programs, monitoring, and operational controls, assessing potential environmental and social risks associated with its operations. As per ESAP#4, Genica will develop and establish E&S KPIs and monitoring procedures to adhere to IFC PSs and WBG EHS Guidelines, including greenhouse gases, and will disclose the data annually in the Company’s Sustainability Report.
Pollution Prevention and Waste Management: Genica has protocols for handling hazardous, non-hazardous and biological waste safely. Sanitary waste is treated through the municipal system of the city of Piracicaba and industrial waste is collected in tanks and subsequently collected by specialized and approved companies. Processes that use water in the fermentation tanks send the residual waste to tanks, a truck collects the wastewater and sends it to an approved company for treatment. No air emissions and industrial effluents are discharged by the Company.
The Company adopts various measures to reduce waste and adopts structured and standardized processes to ensure the safe storage, use, transportation, and disposal of hazardous materials and waste, in accordance with current legislation and good HSE practices.
Pesticide Use and Management: The Company conducts urban pest control at all its facilities annually, targeting rodents and insects through certified contractors in compliance with national EHS laws and regulations and uses licensed pesticides in its experimental fields; no WHO Class Ia and Ib pesticides are used for this purpose.
PS4: Community Health, Safety and Security
Community Health and Safety: Genica’s facilities are not accessed by the public. The Company seeks to ensure that its operations do not cause negative environmental or social impacts on surrounding communities by complying with environmental legislation, controlling operational risks and adopting good environmental practices.
Genica does not have a transportation fleet, all freight is handled by third-party transportation companies, contracted for each delivery. In addition to complying with the CoE&C and Conduct, the suppliers of transportation services must also follow specific rules related to serving end customers, which require defined service and delivery standards, including aspects such as the type of transport, product handling, storage rules, among others.
Community Exposure to Disease: The Company’s operations do not involve effluents, emissions or other activities that could enhance community exposure to diseases. Local authorities conduct audits to inspect sanitation practices and other community health, safety and security-related issues.
Infrastructure and Equipment Design and Safety and Emergency Preparedness and Response: The Company has an Emergency Preparedness and Response Plan, and emergency response drills are conducted every month. All facilities have internal cameras, fire hydrants, fire extinguishers, fire alarms, an emergency brigade, emergency lighting, first aid stretchers, emergency showers, eye wash stations, and a fire alarm center. Genica has not had any fire events in the last 5 years.
Genica has all the national licenses required for fire prevention and fighting, including the Fire Department Inspection Certificate (AVCB), ensuring compliance with current legislation and the protection of people, facilities, and property.
Security: Genica has unarmed security personnel during night shifts and weekends to manage access control and these services are outsourced. The Company maintains a formal service agreement with the provider, which defines the scope and coverage of the performed services. Genica’s facilities are located within an industrial park that also maintains its own unarmed access control at the entrance to the complex.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and conservation of habitats. Genica will build a new manufacturing facility to fulfill product demand. The new facility will cover approximately 1,000 m2 and will be located in the same industrial park where the company is currently operating on a modified habitat, already converted land owned by Genica.
Sustainable management of living natural resources. During their development process, Genica’s products are applied in a 4 has experimental field located 40 km from their facilities in long-established agricultural areas. Trials conducted at this site follow strict internal biosafety and stewardship protocols, only taxonomically identified microorganisms are used, all strains belong to Risk Group 1 (low risk to humans and the environment), microorganisms tested have documented natural occurrence in Brazil and no genetically modified organisms are released in the plots. Field management practices follow standard sustainable agricultural practices, crop protection or agronomic inputs used are registered and approved products and the area is monitored as part of routine R&D oversight procedures. Prior to field use, strains undergo internal safety screening to confirm their suitability for environmental exposure under controlled research conditions.
Products are approved after a regulatory process that ensures that microorganisms used by the Company for their development are harmless to humans and the environment and are not pathogenic. The process includes review of the product’s composition, inert ingredient safety, formulation process, quality controls, organism history, phylogenetic links to known pathogens, effects on non-target species, substance incompatibility, mode of action, and results from toxicity or pathogenicity tests. After approval through the regulatory process, the products are used in small demoplots from farmers and cooperatives for demonstrative purposes.