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:
To systematically manage E&S in full alignment with the requirements of the IFC PS, as per ESAP item #1, Parque Mosaico will develop and implement an E&S Management System (ESMS) for the Project, commensurate to the scale and impacts of its activities and consistent with national law, the requirements of the IFC PS, and the World Bank Group (WBG) General Environmental, Health and Safety (EHS) General Guidelines (2007), (“WBG Guidelines”). The ESMS will also include: i) an E&S policy with an explicit commitment on biodiversity conservation and the adherence to GIIP on environmental, health and safety, and social standards; ii) an E&S monitoring and review process; iii) a chance find procedure, aligned with local regulations and IFC PS8 provisions.
E&S risk and impacts are identified for each phase of the Project following local regulatory requirements. The Company engages external consultants to identify potential E&S risks, conduct fauna and flora surveys, undertake E&S impacts and risk identification, develop environmental management plans (“Plano de Control Ambiental” for its acronym in Portuguese) or ESIAs in case of Phase 3, with specific management plans to mitigate identified E&S risks and impacts of the Project.
Parque Mosaico’s operations manager (COO) is responsible for overseeing construction of the Project, and is also responsible for E&S, ensuring compliance with environmental licenses, legal regulations, and socio-environmental commitments. The Company relies on experienced external consultancy firms to conduct E&S studies and permits. As per ESAP item #2, the Company will assign a qualified E&S officer for the development and implementation of the ESMS in all Parque Mosaico’s construction and for the development of internal or external capacity to adequately manage the ESMS.
The Project incorporates preventive public safety and fire protection measures into the design of the facilities and ensures compliance with the requirements of the Fire Departments and relevant municipal authorities. These measures include the installation of a hydrant network, ensuring adequate support in the event of fire or other emergencies. To enhance the Company’s capacity to respond effectively to unforeseen events and emergencies, as per ESAP item #3, Parque Mosaico will develop and implement a comprehensive Emergency Preparedness and Response Plan. This plan will establish clear procedures, roles, and responsibilities to ensure the protection of employees, communities, and the environment. It will include communication protocols, risk mitigation measures, and recovery strategies aligned with applicable regulations and the IFC Performance Standards. The plan will be periodically reviewed, tested, and updated to maintain its relevance and effectiveness.
PS2: Labor and Working Condition:
To October 2025, Parque Mosaico has thirteen direct employees being six male and seven female. MAIZ, the parent company, adopts a centralized management model through its “Shared Services Center”, which coordinates administrative, human resources, and occupational health and safety functions in an integrated manner, providing technical and operational support to Parque Mosaico. It is expected that during the peak of the remaining construction works a total of 100 workers will be hired. Project activities may not induce influx of workers, since the Project is located in Manaus’ urban area, where most of the workers will be secured from.
Parque Mosaico’s parent company has developed a suit of human resources policies as well as a Code of Conduct. These are aligned with Brazilian regulations and generally consistent with PS2 requirements, covering labor and working conditions, including prohibition of child, forced labor, non-discrimination, promoting equal opportunity and respecting freedom of association. Employees are provided with contracts describing labor and working conditions, and through the induction program, are informed of the corporate policies. Training in the Code of Conduct and Ethics is mandatory as part of the onboarding process, and documentation and HR and labor procedures are available on the Company’s intranet site. The holding has also de also developed a specific policy for Sexual and Moral Harassment, which is aligned with IFC PS2 requirements.
Parque Mosaico has a workers’ grievance mechanism designed to receive claims or complaints from workers via e-mail, which are then submitted to the Company’s ombudsman department. As per ESAP item #4, Parque Mosaico will develop a workers grievance mechanism in line with IFC PS2 requirements to include a detailed, clear, and transparent process to register and resolve grievances in a prompt manner, providing timely feedback to those concerned, and with relevant provisions prohibiting retaliation. The mechanism will allow for anonymous complaints to be raised and addressed, including grievances and cases of sexual harassment with a survivor-centered approach. Grievances will be treated with anonymity and confidentiality, and a clear pathway to address GBV and SEAH will be incorporated.
Parque Mosaico manages OHS risks and processes in line with Brazilian regulatory requirements adopting a structured approach for the identification, control, and mitigation of occupational risks, ensuring the safety of employees and third parties. Non-conformities are identified through internal audits, which are promptly addressed through corrective and preventive action plans.
The Company’s construction activities rely on third-party contractors, delegating EHS responsibilities and management and labor and working conditions to contractor companies as part of their legal and contractual obligations. As per ESAP item #5, Parque Mosaico will develop an E&S Contractor Management Plan in line with IFC PSs requirements, including: (i) minimum environmental and social health and safety (ESHS) requirements for contractors as required in IFC PSs and WBG General EHS Guidelines ; (ii) ESHS pre-qualification selection criteria; (iii) an E&S communication and training plan; (iv) ESHS audits; (v) E&S risk assessments prior to the commencement of works; (vi) monitoring and reporting (including KPIs to assess E&S performance in terms of water and energy efficiency, waste management, OHS statistics, and workers and community grievances), (vii) labor requirements in line with Brazilian labor laws and IFC PS2, and (viii) audit process to assess labor and OHS performance, including prevention and management of GBV and SEAH risks and grievance mechanism effectiveness.
PS3: Resource Efficiency and Pollution Prevention:
Throughout the Company's facilities, electricity is supplied by the local utility provider, while drinking water comes from the public network. Wastewater is collected and discharged into the public sewer system and treated at dedicated plants designed and built by the Company for the Project and transferred to the public utility company for its operation, following local regulations and design criteria. As per ESAP item #6 Parque Mosaico will formalize their resource efficiency initiatives in a Corporate Resource Efficiency Strategy to be implemented during construction all assets (office buildings, warehouses, commercial properties). The strategy will define how Parque Mosaico will gradually implement measures for improving efficiency in terms of energy, water, and construction materials use. This strategy will include regular measurements and reporting of energy consumption, definition of energy efficiency targets for similar types of assets and comparison with benchmark data to confirm that targets are set at an appropriate level.
The Company does not track its carbon footprint or GHG emissions. The estimated GHG emissions are expected to be less than 25,000 tons of CO2-equivalent annually due to its low carbon intensity nature.
The Project’s construction activities are expected to generate non-hazardous and hazardous waste, environmental noise and particulate matter. As part of ESAP #1, Parque Mosaico will develop a Construction Waste, Environmental Noise and Dust Management Plan to be implemented by contractors during construction and decommissioning activities in line with the WBG General EHS Guidelines.
PS4: Community Health, Safety and Security:
The Project complies with national fire safety codes and local regulatory requirements including fire detection and alarm systems, fire suppression systems, evacuation routes, and site-specific EPRPs. The Project is required to obtain municipal permits and is subjected to audits from the local authority. For structural safety, Parque Mosaico follows national building codes and permits. As per ESAP item #7, Parque Mosaico will develop a Life and Fire Safety (LFS) framework following the best fire codes in Brazil, as well as international good practice on LFS or similar, and will seek the certification of each building from a qualified professional and will report to IFC on a yearly basis. The design will include but not be limited to (i) fire alarm system in common areas, and (ii) enclosed fire rated staircase in residential buildings with height over 30 meters.
Parque Mosaico will not be involved in the O&M phase of the AFH projects, therefore as per ESAP item #8, the company will develop an O&M handbook that will hand over relevant LFS O&M instructions to the O&M contractor or building manager (e.g., condominium). This will help with the continuity of the performance and reliability of L&FS systems in the buildings and other relevant systems (water, elevators, etc.) during operations.
With regards to security management, Parque Mosaico hired a specialized unarmed security contractor for the Master Plan development managed by the Company. The security contractor patrols project areas and reports any alarm to first responders and the local police. As per ESAP item #9, the Company will develop a Security Management Plan aligned with the requirements set forth in IFC PS4 to prevent and mitigate any risks related to security, human rights and provide adequate engagement with neighbors and communities. The Plan will include requirements for vetting of any security personnel engaged in past abuse, noncompliance with rules of conduct, perform background checks, and include training requirements in the Voluntary Principles on Security and Human Rights, the grievance mechanism, and all GVBH/SEAH policies and procedures.
Moreover, in order to improve the E&S management of community risks and impacts during the construction phase, Parque Mosaico will, as part of ESAP item #10, develop a Community Health and Safety Management Plan (CHS-MP). The plan will be in line with the requirements set forth in IFC PS4 and will include provisions for the management of E&S aspects related to traffic, emissions, hazardous and non-hazardous waste management, as well as any other ESHS identified risk for the community during construction. The plan will also include necessary provisions to prevent sexual harassment and exploitation. The CHS-MP should cross reference the Stakeholder Engagement Plan and grievance mechanism in relation to the response and management of community grievances, as well as security arrangements from the Security Management Plan. The CHS-MP shall include key performance indicators to assess the effectiveness of the proposed E&S mitigation measures.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources:
Protection and Conservation of Biodiversity. The project is situated in the western urban area of Manaus municipality (AM), within the Uatuma-Trombetas moist forests Ecoregion, near the transition to the Japura-Solimoes-Negro moist forests Ecoregion. The 65.1 ha project area is predominantly covered with remnants of dense ombrophyllous forest in different regeneration stages, as well as riparian forests and bare soil patches. It is surrounded by consolidated residential areas, a cemetery, barren areas aimed at new urban developments, and large surrounding remnant forest patches. Biodiversity-relevant contextual risks in the project region include the loss of urban forest habitat connectivity from urban development, encroachment and fires; wildlife predation and spread of zoonotic diseases from domestic fauna; fauna roadkill; and wildlife electrocution along power distribution lines.
The Project area is surrounded by and partially overlaps the Environmental Protection Area (APA) Parque Linear do Igarape do Gigante and is immediately adjacent to the APA Taruma / Ponta Negra (both IUCN Cat. V). The Client will engage with administrative authorities of the APA Parque Linear do Igarape do Gigante and APA Taruma / Ponta Negra to develop additional conservation actions aimed at supporting biodiversity conservation in those areas, with emphasis on the Globally Critically Endangered (CR) Pied Tamarin (Saguinus bicolor) (see ESAP#11).
Available baseline surveys for the ESIA consisted of rapid assessments of vertebrate fauna (September/October 2020; May 2021) and flora (June 2025). Several priority biodiversity values occur in the area, including the above-referred Pied Tamarin; the Globally Endangered (EN) tree Lecythis prancei; the Globally Vulnerable (VU) Channel-billed Toucan (Ramphastos vitellinus) and Dalbergia spruceana tree; and the Nationally VU tree Heteropsis flexuosa. Potentially occurring priority values include the Globally CR Klages's Antwren (Myrmotherula klagesi) and Globally EN frog Atelopus manauensis.
The Project will entail the removal of 30.3 ha of Natural Habitat, consisting of lowland forest remnants, while the existing riparian forest corridors will remain protected as mandatory set asides (Areas of Permanent Preservation, per Brazil’s Forest Code). The forest habitat loss is expected to increase the fragmentation and isolation of arboreal fauna populations throughout the urban landscape, in particular for primates, given their dependence on canopy connectivity.
Per ESAP item #11, the Project will secure support from competent professionals to develop a Biodiversity Management Plan, acceptable to IFC, to integrate all the project’s biodiversity-related mitigation and monitoring measures, including: (i) loss/gain calculation and outline of an offsetting strategy to achieve No Net Loss, with priority focus on the conservation of the Pied Tamarin, in line with the species National Action Plan; (ii) the enrollment of local primate specialists for the development of a mitigation and monitoring plan to facilitate arboreal fauna crossings along riparian corridors throughout the project area and adjacent forest remnants, with emphasis on the Pied Tamarin; (iii) engagement with the administrative authorities of the APA Parque Linear do Igarape do Gigante and APA Taruma / Ponta Negra to agree on the implementation of additional conservation actions with focus on the Pied Tamarin; (iv) implementation, when applicable, of measures to mitigate fauna electrocution risks on distribution lines, in accordance with State approved technical specifications; (v) adoption of measures to prevent the introduction and spread of alien invasive species as part of vegetation management, restoration and landscaping programs; and (iv) a Biodiversity Monitoring Program to verify effectiveness of mitigation measures. The Project will adapt its management practices based on the monitoring results, as necessary.
