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 Policy:
For the design and construction of the Project, the SPV will assign responsibility for E&S management to Portafolio as the developer and primary implementer of E&S management. Portafolio has established a corporate construction ESMS, including a Sustainability Policy, Contractor Management Policy, Code of Ethics, and Biodiversity Policy, complemented by project procedures such as the Sustainable Construction Manual and Eco-efficiency Procedure. The construction ESMS is defined, implemented, and enforced contractually by the Developer on the construction contractors, and risks will be managed under these corporate policies and procedures, which are generally aligned with IFC Performance Standards and the WBG EHS Guidelines. However, to achieve full alignment during the whole project lifecycle, additional management plans and measures are required, as outlined in ESAP#1 to ESAP#8.
As the facility transitions from construction to operations, E&S performance will be a shared responsibility: Portafolio will continue to manage park-wide E&S aspects, while Insulet will assume direct E&S management for its manufacturing activities within the facility, using its global policies aligned with Costa Rican regulations and international standards. As per ESAP#1, the Project will develop and implement an ESMS for the operations phase, aligned with the IFC PS, the WBG General EHS Guidelines (2007) and the WBG EHS Guidelines for Semiconductors and Other Electronics Manufacturing (2007) (the “relevant WBG Guidelines”).
Identification of Risks and Impacts and Management Programs:
Portafolio has prepared an EIA for the Savia Sur industrial park, aligned with national requirements, which has been formally approved by the relevant authority. The EIA and license approval will be disclosed together with this ESRS. The EIA provides an initial understanding of the industrial park’s risks and impacts. The design of the park was also informed by a Climate Risk Assessment. To strengthen the Project’s understanding of the E&S impacts, as per ESAP#2, the Project will prepare supplementary risk and impact assessments to complement the existing EIA, in accordance with the IFC PS and the relevant WBG Guidelines. These will cover potential impacts related to noise, visual, traffic, and dust issues during construction and operations, and will take into account concerns raised by nearby communities as well as the Project’s interface with public infrastructure. Based on the updated assessment, the Developer will prepare the necessary E&S management plans to ensure that identified risks and impacts are effectively managed throughout the project lifecycle.
Organizational Capacity and Competency:
Portafolio manages E&S through a multidisciplinary sustainability team led by a Director of Sustainability, Innovation, and IT. The structure includes roles for environmental compliance, integrating sustainability into projects, climate and biodiversity strategy, and social development, each with clear responsibilities. Four field coordinators support site-level oversight.
To further strengthen oversight during the construction phase, Insulet has selected an independent E&S consultant to provide third-party monitoring and verification of the Developer’s E&S performance. For the operations phase, as part of ESAP#1, the Project will appoint a qualified EHS Coordinator/Manager with expertise in management systems, IFC PS, and the E&S national requirements of Costa Rica. This role will sit within the Project Company for the operational phase and will lead the development, implementation, and maintenance of the operations phase ESMS and associated E&S programs, plans, and procedures.
Contractor Management:
A Contractor Management Framework is in place, grounded in Portafolio’s ESMS, which establishes policies, procedures, and oversight mechanisms that are generally aligned with the IFC PS and relevant WBG Guidelines. Portafolio requires all contractors engaged during the design, construction, and operational phases of Savia South to comply with its corporate-level policies, including the Contractor Management Policy, Code of Ethics, and Sustainability Policy, as well as project-specific procedures such as the Sustainable Construction Manual and Ecoefficiency Procedure. Prior to engagement, contractors undergo a rigorous pre-qualification and evaluation process, which includes self-assessment questionnaires covering legal, social, environmental, and occupational health and safety (OHS) compliance. Contractors must demonstrate alignment with Portafolio’s standards and provide evidence of compliance with Costa Rican regulations, including registration with the national social security system and relevant authorities. Oversight mechanisms during construction include weekly site inspections, monthly reporting on OHS and environmental performance, quarterly audits, and corrective action plans. As part of ESAP#1, Insulet will develop a Contractor Management Plan for the Project’s operations phase, in line with the IFC PS and relevant WBG Guidelines.
Emergency Response Planning:
Portafolio maintains corporate-level emergency management systems, and each facility within the Savia Sur development is required to prepare and implement emergency preparedness and response plans (EPRP) in accordance with Costa Rican legal requirements and the standards applicable to free trade zone industrial operations. For the construction phase, the development of an EPRP by the main contractors is a legal and contractual requirement, and therefore construction EPRPs are expected to be prepared prior to contractor mobilization. As part of ESAP#1 for the operations phase and ESAP#3 for the construction phase, the Project will develop EPRPs in alignment with the IFC PS and relevant WBG Guidelines.
Monitoring and Review:
Portafolio implements a comprehensive monitoring program as part of its ESMS, in line with IFC PS requirements. This includes regular tracking of resource efficiency (water, energy, waste), wastewater, hazardous materials, and contractor compliance, with defined reporting frequencies and responsibilities at both project and corporate levels. Site inspections are conducted weekly by sustainability coordinators, and quarterly audits are performed by the sustainability supervision team to verify adherence to E&S requirements and identify areas for improvement. Contractors are required to submit monthly evidence of compliance with waste management and wastewater treatment procedures, and all monitoring data is reviewed by Portafolio’s sustainability team. Non-conformities are documented, and corrective actions are tracked to closure. Performance metrics and audit results are reported to senior management and incorporated into ongoing improvement initiatives. As part of ESAP#1, the Project will develop procedures to monitor and measure effectiveness of its operations phase ESMS and compliance with legal and contractual obligations, including E&S key performance indicators (KPIs) and performance targets.
PS2: Labor and Working Conditions
Earthworks for Insulet’s facilities in the Savia development will be carried out by Traesa, while Portafolio will lead, through a specialized contractor, the main construction and cold-shell works. Together, both contractors are expected to employ a peak construction workforce of 400–600 workers. Labor management during operations will be overseen by Insulet’s corporate HR team in line with global company policies.
Human Resources (HR) Policies and Procedures:
Portafolio and its subsidiaries have a comprehensive set of Human Resources (HR) policies and procedures that regulate labor relations, workplace conduct, and employee protection. These policies apply to all personnel, regardless of position, contract type, or seniority, and are aligned with Costa Rican labor legislation. Insulet also maintains a robust global Code of Business Conduct and Ethics that governs employee behavior across its global operations and reinforces commitments to integrity, respect, and a safe workplace. The Company’s HR framework reinforces commitments to integrity, respect, non discrimination, and a safe and inclusive work environment.
Grievance Mechanism:
Both Portafolio and Insulet have established channels that allow workers to raise concerns confidentially. Portafolio provides an online platform (teescuchamos.portafolio.cr) where direct employees can submit complaints, suggestions, or grievances, anonymously or identified, which are received and managed by HR following defined steps for registration, classification, and response. Portafolio’s HR framework also maintains formal procedures for preventing, investigating, and sanctioning workplace harassment and sexual harassment, which include due process guarantees, confidentiality, and is managed through an internal investigative commission.
Insulet complements this with its independently operated global Ethics & Compliance Hotline, available 24/7 in multiple languages, as well as internal reporting channels supported by its Code of Business Conduct and Ethics. Portafolio also maintains formal procedures for workplace harassment and sexual harassment. These cases are handled through dedicated investigative commissions, in compliance with Costa Rican Law 7476. The procedures include formal intake, confidentiality safeguards, the right to legal representation, interviews with all parties, evidence review, protective measures where needed, and documented recommendations for corrective actions. As part of ESAP#5, the project will establish a workers’ grievance mechanism accessible to construction labor including contractors and subcontractors, ensuring anonymity, gender-based violence-related grievances, registration, tracking, and timely resolution.
Occupational Health and Safety:
Both Portafolio and Insulet have established corporate OHS systems aimed at preventing workplace accidents and promoting safe working conditions which are consistent with IFC PS2 and the relevant WBG Guidelines. Portafolio applies corporate safety procedures across its operations, including emergency preparedness, hazard identification, and compliance with national regulations. Manufacturing and office facilities operate with documented safety protocols, routine inspections, training requirements, and incident reporting mechanisms managed by HR and facility level safety committees. Workers receive induction training covering site rules, emergency procedures, and safe behaviors, and supervisors are responsible for ongoing monitoring of compliance.
Insulet has a corporate global health and safety framework that includes formal OHS management practices, mandatory safety training, risk prevention tools, and monitoring mechanisms. During construction and subsequent operations at Savia Sur, including the Insulet facility, contractors and subcontractors will be required contractually to comply with national OHS regulations, project specific safety measures, and GIIP. This includes hazard identification and risk assessments, personal protective equipment requirements, toolbox talks, incident reporting, and emergency response measures. An OHS manual covering general and critical risk controls for the construction phase (e.g., working at heights, excavations, hot work, confined spaces, electrical work, etc.) aligned with IFC PS2 and the relevant WBG Guidelines is in place. All workers must be properly trained, authorized for high risk activities, and provided with adequate supervision. Updated risk assessments and ESMPs will be integrated into the main contractors and subcontractor E&S requirements. For the operations phase ESMS, as per ESAP#1, Insulet will prepare a project-specific OHS management system in line with IFC PS2 and the relevant WBG Guidelines for the operation of the new facility.
Workers Engaged by Third Parties:
The project will involve workers employed by third party entities, particularly construction contractors, subcontractors, and service providers during both the construction and operational phases. Portafolio and Insulet require that all third party employers comply with national labor regulations and adhere to the principles established in their respective Codes of Ethics and HR policies. As part of ESAP#6, the Project will consolidate a Labor Management Plan (LMP) that integrates labor commitments for workers engaged by third parties, to ensure full alignment with IFC PS2 requirements, including working conditions, oversight, and documentation of labor related risks and mitigation measures.
Supply Chain:
Insulet manages its supply chain through a mature set of corporate policies and due diligence processes that emphasize human rights, ethical sourcing, and supplier accountability. The Company is a member of the Responsible Business Alliance (RBA) and has adopted the RBA Code of Conduct as its Supplier Code requiring suppliers to meet international standards on labor rights, environmental performance, and business ethics. Insulet’s Human Rights Statement reinforces commitments to prevent forced labor, child labor, discrimination, and other abuses, while the Conflict Minerals Policy mandates traceability and responsible sourcing of 3TG minerals. Supplier oversight is implemented through risk assessments, training, third party audits such as RBA Validated Assessment Program assessments for high-risk suppliers and use of E&S contract addenda in certain regions. These measures are complemented by strong quality and traceability requirements aligned with recognized international compliance standards for medical devices.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency:
Portafolio applies corporate sustainability standards across its developments, including practices to reduce consumption of energy and water, promote efficient building systems, and minimize environmental footprint during construction and operations. During construction, contractors will be required to implement measures regarding proper sourcing and storage of materials, efficient use of equipment, prevention of leaks and losses, and separation and responsible disposal of construction waste. Insulet also maintains global sustainability commitments focused on responsible use of natural resources, energy efficient operations, waste minimization, and continuous improvement in facility level environmental performance. These practices will complement project specific E&S management plans once the facility becomes operational and addressed under ESAP#1.
Power for the Project will be supplied by the national electrical grid, predominantly renewable, and no on site power generation is planned. Potable water will be provided through the municipal public water supply system.
Pollution Prevention:
Construction activities may generate noise, dust, and air emissions, while both construction and operations may result in illumination and visual impacts within the project boundary. As part of ESAP#2, the supplementary impact assessments will be conducted and based on the results, the Developer will prepare and implement E&S management plans, aligned with the IFC PS and relevant WBG Guidelines, including a Noise and Air Quality Management Plan and a Visuals and Illumination Management Plan, with site-specific mitigation (e.g., scheduling of high-noise activities, dust suppression, light shielding, and complaint-response procedures), which will be integrated into the main contractors and subcontractor E&S requirements. Operations at the Insulet facility will not generate air emissions from the manufacturing processes.
Waste Management:
Portafolio applies internal sustainability practices across its developments that emphasize responsible handling of waste, including hazardous substances when present, the minimization of waste generation, and the reuse or recycling of materials where feasible. Construction contractors are contractually required to develop a waste management plan and implement basic waste management measures, including waste segregation at source, proper storage and labeling of materials, and disposal of both hazardous and non hazardous waste through licensed service providers. As per ESAP#7, the construction phase waste management plan will be developed aligned with IFC PS and WBG EHS Guidelines.
Insulet maintains global sustainability commitments that include waste minimization efforts within its operations, responsible use of materials, and initiatives to reduce waste across its facilities. These efforts include waste diversion programs, recycling of recoverable materials, initiatives to reduce packaging materials, and measures to improve material efficiency. As part of ESAP#1, the Project will develop a waste management plan for the operations phase aligned with IFC PS and WBG EHS Guidelines.
Wastewater Management:
Construction wastewater will be managed through temporary sanitary systems, sediment controls, and spill prevention measures to ensure no untreated discharges reach natural water bodies, in line with SETENA and Ministry of Health requirements. The manufacturing process will produce minimal wastewater from operations, with most water being used for domestic purposes or cooling towers. The production line operates without wet processes, solvents, or chemical washing steps, and therefore no process effluents will be produced. Water from the cooling towers will be reused whenever feasible, and all sanitary wastewaters will be treated at the Savia Sur on-site wastewater treatment facility, designed to meet both Insulet’s requirements and local regulatory standards. This approach is consistent with the IFC PS and WBG General EHS Guidelines.
PS4: Community Health, Safety and Security
Community Health and Safety:
The industrial park will operate as a controlled access free trade zone and Insulet facility will not be accessible to the public. As part of ESAPs #1 and #3, the EPRPs for both construction and operations will include considerations for the participation and collaboration of key stakeholders, as relevant.
The Savia Sur industrial park is bordered on its western limit by the residential neighborhood of Los Arcos and on its southern limit by the settlement of La Carpio, separated by the Virillas River. As part of ESAP#2, Portafolio and Insulet will conduct a traffic impact assessment and prepare a Traffic Management Plan covering routing, schedules, driver training, community signage, and incident response.
Security:
Security services will be used during both the construction and operational phases of the Savia Sur project, and it is expected that armed security personnel will be deployed to safeguard the site, personnel, and assets. Portafolio’s existing corporate practices emphasize ethical conduct, respect, and appropriate behavior within its managed properties, which indirectly inform expectations for interactions between security personnel and workers, contractors, and visitors. As part of ESAP#8, Portafolio will prepare and implement a project specific Security Management Plan (SMP) for construction and operations in line with IFC PS4.
