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
E&S Management System & Programs. Alvorada manages environmental, social, and OHS matters across its operations with a focus on compliance with applicable Brazilian legal and regulatory requirements. The Company has policies, procedures, and operational controls addressing specific aspects of environmental management, OHS, regulatory compliance, and responsible business practices. Environmental licensing conditions and related regulatory obligations are monitored at the corporate and operational levels, with support from specialized external consultants, as needed.
Although Alvorada has several elements of an ESMS in place, it is not yet fully consolidated and systematically implemented across all business units. Areas for further consolidation include the identification and management of social risks and impacts, emergency preparedness and response, stakeholder engagement processes, and grievance management mechanisms. Under ESAP #1, Alvorada will develop and implement a corporate ESMS aligned with the requirements of PS1 and commensurate with the nature and scale of its operations and E&S risks and impacts.
E&S Policies. The Company has adopted a Corporate Sustainability Policy and an Environmental Management System (SGA) Policy, which establishes its commitments to regulatory compliance, environmental protection, prevention and mitigation of E&S risks and impacts, OHS, responsible management of natural resources, and continuous improvement of its management systems.
The Company’s policies establish the corporate framework for identifying, assessing, and managing E&S risks and impacts and are being progressively incorporated into operational procedures and practices across Alvorada’s decentralized network of units. Alvorada’s public commitments also include supply chain-related principles, including commitments not to finance, acquire, or commercialize agricultural products originating from areas subject to environmental embargoes, Indigenous Peoples lands, conservation areas, or from suppliers included in official lists related to forced labor or child labor.
Identification of E&S Risks and Impacts. The Company identifies E&S risks and impacts primarily through regulatory processes and environmental studies prepared as part of environmental licensing, as well as through internal environmental management practices. For the ethanol plant, environmental assessments have been conducted in line with licensing requirements. For other operations, environmental and social risks are assessed in accordance with applicable regulatory frameworks and operational controls.
As part of the implementation of its Environmental and Social Management System (“ESMS”), Alvorada will enhance its E&S risk assessment matrix to systematically identify, assess, and manage social risks, including traffic safety, SEAH, community health and safety, and risks associated with the use of security personnel (ESAP #1).
E&S Organization Capacity/Competency. Alvorada’s E&S management is coordinated through a dedicated Sustainability Department led by a Sustainability and Legal Manager, which oversees E&S matters across the Company’s operational units. The Company has established a corporate E&S framework through its Corporate E&S Policies. Legal compliance is monitored through specialized systems and complemented by periodic external environmental audits. OHS management is supported by dedicated teams distributed across operational units, responsible for inspections, contractor management, incident investigations, and implementation of safety procedures.
Emergency Preparedness and Response (EPR). Alvorada has established Emergency Response Plans (ERPs) for selected operations, covering key emergency scenarios such as spills and leaks, fires and explosions, occupational and industrial accidents, chemical releases, confined space incidents, transport-related emergencies, and events with potential environmental, worker health and safety, and community impacts. The plans define communication flows, roles and responsibilities, emergency classification and escalation procedures, response measures, containment and impact mitigation actions, emergency contacts, training requirements, and procedures for drills and post-incident review. The Company also maintains a contract with a specialized emergency response firm to provide 24-hour technical and operational support in situations requiring specialized intervention. While these arrangements provide a solid foundation for emergency preparedness and response, opportunities remain to further strengthen consistency across business units, ensure that emergency scenarios are systematically tailored to site- and activity-specific risks, and formalize periodic testing and review processes. Accordingly, under ESAP #2, Alvorada will further strengthen and consolidate its ERPs to ensure they are risk-based, site- and activity-specific, periodically tested, and implemented across all relevant operations.
Monitoring and Reporting. E&S performance is monitored through a combination of site-level controls and corporate oversight. Monitoring activities currently include waste management, effluents, air emissions, noise, water and energy consumption, and compliance with applicable environmental permit conditions. At selected sites, KPIs, objectives, and targets are formally defined with assigned responsibilities and monitoring frequencies, supported by monthly internal inspections and semiannual environmental assessments conducted by an external specialized consultancy. At other operational units, monitoring is conducted at the site level based on applicable legal, permitting, and operational requirements.
As part of the implementation of its ESMS (ESAP #1), Alvorada will progressively consolidate and standardize E&S monitoring requirements, indicators, reporting flows, and performance review mechanisms at the corporate level, and will incorporate additional monitoring programs to cover social aspects. Results from monitoring activities will be used to define, track, and close corrective and preventive actions.
Supply Chain Assessment and Management. Alvorada sources agricultural commodities, mainly soy and corn, from approximately 3,400 direct grain suppliers, predominantly rural producers located in Mato Grosso, within the Cerrado and Amazon biomes. The Company also sources wood biomass for its ethanol plant, although it is in the process of establishing its own biomass plantation. In addition, Alvorada maintains relationships with approximately 76 direct suppliers of agricultural inputs, including fertilizers, pesticides, and seeds.
Alvorada has established a Supplier Code of Conduct and a formal Procedure for Socio-Environmental Restrictions for Grain Origination, which include provisions related to deforestation, environmental compliance, and human rights violations. Supply chain management is supported by the internally developed “Alvorecer” Platform, which integrates supplier registration data, georeferenced property information, satellite-based monitoring tools, and public databases to conduct socio-environmental screening and ongoing compliance verification of suppliers. Through the platform, the Company monitors 100% of its direct grain suppliers, with suppliers identified as non-compliant automatically blocked from commercial operations.
Under ESAP #3, Alvorada will further strengthen its Supply Chain Management System (“SCMS”) through the establishment and implementation of (i) a time-bound action plan to progressively expand traceability to indirect grain suppliers, including procedures for supplier mapping, data collection, verification, and risk-based screening; (ii) implementation of an Enhanced Verification Protocol for properties with records of native vegetation conversion after December 31, 2020, comprising: (a) delineation of the conversion polygon; (b) overlay with the CAR, productive areas, and land-use history; (c) documentary assessment of the regularity of the conversion, where applicable; (d) verification of the physical segregation between the converted area and the area actually allocated to agricultural production; (e) field monitoring where justified by the risk assessment; and (f) an eligibility decision based on documented evidence, consistent with the mitigation hierarchy, not to source from areas non-compliant with such criteria; (iii) integrate spatial screening for Alliance for Zero Extinction (“AZE”) sites and Natural or Mixed UNESCO World Heritage Sites (“WHS”) into its traceability system to identify and restrict sourcing from areas with potential exposure to high biodiversity value areas; (iv) engage an independent third party to conduct annual audits of the traceability system; and (v) strengthen supplier contractual requirements, including through the revision of its Supplier Code of Conduct, to include zero tolerance for child labor, forced labor, inadequate working conditions, sexual harassment, and the conversion of natural habitats.
PS2: Labor and Working Conditions
At the time of the appraisal, the Company had a total of 914 direct employees (22% women) and 161 third-party workers engaged in cleaning, security, and transportation services on a permanent basis.
Human Resources Policies and Procedures, Working Conditions and Terms of Employment. The Company maintains human resources policies and procedures aligned with national labor legislation and collective bargaining agreements negotiated. Employment conditions, working hours, benefits, and OHS requirements are defined in individual work contracts and complemented by the Company's Code of Conduct and the Corporate Sustainability Policy, which include commitments to labor rights, safe working conditions, non-discrimination, and respect for workers. The Code of Conduct addresses workplace relations, including provisions against discrimination, harassment and sexual harassment, forced labor and child labor. The Code of Conduct is communicated to all employees during the onboarding integration process and reinforced through regulatory training and leadership development programs.
Worker’s Grievance Mechanism. The Company has established a worker grievance mechanism accessible to all employees, including contracted and subcontracted workers, through multiple channels: an independent third-party platform (Contato Seguro), available by telephone, website, and mobile app, which allows anonymous and confidential reporting; a corporate WhatsApp line; and in-person reporting at operational units. Grievances are recorded, investigated, and addressed through defined procedures, with oversight by an internal committee. Currently, the grievance mechanism has yet to be strengthened to promote broader awareness, accessibility, and consistent use across all units and worker categories. Under ESAP #4, Alvorada will strengthen its grievance mechanism by establishing provisions to handle SEAH with a survivor-centered approach, improving dissemination across operational units, and providing specialized training to staff responsible for managing such complaints.
Occupational Health & Safety (OHS). The Company implements OHS practices in accordance with applicable Brazilian regulatory requirements, including the Regulatory Standards (“NRs”) and Risk Management Program (“PGR”) requirements, supported by EHS directives, mandatory training programs, operational controls, and a field-based anonymous risk reporting tool. The OHS function is led by a dedicated EHS Coordinator, supported by five regional EHS technicians who conduct weekly site visits, with oversight from a cross-functional EHS Committee that includes director-level participation. Key OHS risks are associated with industrial operations at the ethanol plant, machinery and equipment used in grain storage and handling, and logistics activities, including the operation of more than 170 light vehicles supported by a fleet policy, telemetry, and speed monitoring.
Currently, the ethanol plant demonstrates a consistent, visible commitment to safety, including in areas such as contractor EHS management, clear contractual requirements, and effective oversight. However, serious incidents have been recorded in recent years in agricultural operations. Moving forward, under ESAP #5, Alvorada will conduct an EHS compliance assessment of all Project facilities and operations, including forestry plantations, with the support of a specialized external consultant, to evaluate alignment with applicable regulatory requirements and the relevant WBG EHS Guidelines. Based on the findings, Alvorada will develop and implement a corrective action plan to address any identified gaps. In addition, as described under ESAP #7, Alvorada will develop and implement a Transportation and Logistics Safety Framework for third-party transport activities.
PS3: Resource Efficiency and Pollution Prevention
Resource use. Alvorada sources electricity from the national grid and prioritizes renewable energy procurement where feasible. The ethanol plant uses biomass as its main source of thermal energy, while the Company’s vehicle fleet runs primarily on ethanol. Water is mainly sourced from permitted groundwater wells, supplemented by municipal supply at selected locations. Energy and water consumption are monitored at the site level. No complaints from other water users have been reported.
Greenhouse gas emissions. The Project includes ethanol production, which contributes to the supply of lower-carbon fuels in line with Brazil’s national biofuel policy, RenovaBio. The Company’s eucalyptus forestry base also has potential to contribute to carbon sequestration. At the same time, Alvorada’s operations generate greenhouse gas (“GHG”) emissions associated with energy consumption, industrial processes, and logistics. The Company has developed a GHG inventory, and emissions information is disclosed in its annual Sustainability Report. Reported emissions are below 25,000 tCO2e per year.
Wastewater Management. Wastewater generated across the Company's operations includes sanitary (domestic) effluents, oily effluents, operational wash water and stormwater. At the ethanol plant, industrial effluents are managed through treatment systems that include process water reuse, in accordance with the licensed project design. For other operations, wastewater is managed through public sewer connections (where available), septic systems, and oil-water separators, appropriate to the scale and nature of activities. Effluent monitoring is conducted at the local level per licensing requirements.
Solid Waste Management. The Company implements solid waste management practices covering segregation, storage, transportation, and final disposal, in accordance with applicable regulations. Non-hazardous waste is segregated by category (paper, plastic, metals, glass, organics) and directed to recycling, reuse, or treatment. Hazardous waste is managed through dedicated storage, and disposed of via licensed firms using incineration or co-processing. The Company has implemented a Zero Waste Program in select units, including source segregation and composting, with progressive expansion to other units. Waste data is tracked at the unit level and consolidated annually in the Sustainability Report.
Hazardous Materials and Pesticide Use and Management. Alvorada manages hazardous materials, including diesel for generators, bio-contaminated substances, and pesticides stored or used in its operations, under established procedures that set requirements for safe handling, storage, use, and disposal, in line with applicable regulatory and corporate standards. The Company also commercializes agricultural inputs, including fertilizers, pesticides, and seeds, and provides technical support to producers, although it does not directly control pesticide application at the farm level. Pesticides are stored at Alvorada’s operational units for commercialization purposes and are also used directly in its own operations for grain fumigation at storage facilities. To further align its practices with IFC PS requirements, under ESAP #6, Alvorada will develop and implement a plan to phase out agrochemicals classified by the World Health Organization (“WHO”) as Class Ia, or extremely hazardous, and Class Ib, or highly hazardous, and will commit not to purchase, store, use, manufacture, transport, or trade such chemicals.
PS4: Community Health, Safety and Security
Road safety. The Company’s logistics operations rely on arrangements with trading companies and owned and third-party transport service providers, supporting an average daily throughput of approximately 2,000 trucks during peak harvest periods. The Company has a fleet policy applicable to company-owned vehicles used by employees, which is incorporated into its disciplinary framework and communicated during onboarding and policy training sessions. However, the Company does not currently have a structured responsible logistics program addressing third-party driver management, road safety, driver well-being, community health and safety risks, or the prevention of human rights violations, including SEAH, along external transportation routes.
Pursuant to ESAP #7, Alvorada will develop and implement a Transportation and Logistics Safety Framework for third-party transport activities, aligned with IFC PS4 and applying the mitigation hierarchy. The framework will include, at a minimum: (i) a transportation risk assessment; (ii) a Transportation Management Plan; (iii) a Code of Conduct for third-party transport service providers; and (iv) training and awareness programs for drivers and relevant staff. SEAH prevention and mitigation measures will be integrated across the Framework, its policies and training programs.
Security Personnel. Security services at Alvorada's facilities are provided by outsourced private security companies, duly licensed under applicable Brazilian legislation. Security personnel may carry firearms in accordance with legal requirements, including mandatory training, registration, and oversight by the contracted firms. Contractual arrangements with security providers include requirements for compliance with applicable legislation, respect for human rights, proportional use of force, and prohibition of abusive or discriminatory practices. No security-related incidents were reported at the time of the appraisal. As per ESAP #8, Alvorada will develop a Security Risk Assessment and Security Management Plan to prevent and mitigate security risks across its operations, including protocols for the conduct of security personnel, in line with PS4 requirements.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity. The ethanol plant is located within the Cerrado ecoregion of Mato Grosso (“MT”), approximately 50 km north of Canarana town. The facility was developed on Modified Habitat within a consolidated agricultural landscape, predominantly surrounded by pasturelands, soy and corn croplands. The area includes large remnant blocks of tall Cerrado forest (Cerradao), maintained as mandatory set asides (Legal Reserves and Areas of Permanent Preservation) in accordance with Brazilian environmental legislation. There are no Legally Protected Areas or Internationally Recognized Areas within a 50 km radius of the plant. The closest Indigenous Peoples land, Pequizal do Naruvotu, is located approximately 40 km to the northwest. In addition to the ethanol plant, the company operates a network of 29 grain storage and agricultural retail units across the Cerrado and Mato Grosso tropical dry forest ecoregions. All units are situated either within modified habitats or consolidated urban areas.
Sustainable Management of Living Natural Resources. Alvorada sources its grains exclusively from third party producers. The company is currently establishing its own Eucalyptus forests in previously modified habitats in the Novo Sao Joaquim and Araguaiana municipalities, aiming at 12,000 ha of plantations, to be able to supply its future wood biomass demand for the ethanol plant and the drying of grains on its storage units. Per ESAP #9, Alvorada will apply sustainable management practices aligned with IFC Performance Standards and certify its plantations to Forest Stewardship Council (“FSC”), or another internationally recognized equivalent certification accepted by IFC, for its wood biomass production aimed as an energy source for its own operations.
Supply Chain. Alvorada manages corn, soy, and sorghum stocks sourced from 138 municipalities across MT, with a particular concentration of suppliers in the eastern portion of the state along the BR 158 corridor. In these landscapes, commercial agriculture expanded primarily over previously established pasturelands, following extensive land clearing during the late 1980s and early 1990s. Over the past decade, natural habitat cover across these municipalities has remained relatively stable. Currently, pasturelands and grain crops dominate the landscape, while remnants of Natural Habitat are largely confined to Indigenous Peoples lands, Protected Areas, and mandatory legal set asides (Legal Reserves and Areas of Permanent Preservation).
The company’s supplier base comprises approximately 3,400 farmers, predominantly medium scale producers (200–5,000 ha), but also including large and very large producers (>10,000 ha). Supplier management is conducted through the Alvorecer platform, which uses the Grainstation system, widely adopted by grain traders in Brazil. This system is aligned with the requirements of the Round Table on Responsible Soy Association (RTRS), of which Alvorada is a member, as well as with Brazil’s RenovaBio, which promotes the production of low carbon fuels. As part of its business model, Alvorada maintains close engagement with suppliers, providing technical, logistical, and storage support, access to agricultural inputs (fertilizers and pesticides), and flexible financial arrangements. The company also assists farmers with environmental compliance issues, including support for restoration of degraded areas, resolving embargoed areas, and facilitating the environmental regularization of rural properties (Alvorada’s ‘Renova’ and ‘Regulariza’ Programs).
The supply chain management system enables farm level traceability for most direct suppliers; however, it currently lacks full traceability for indirect suppliers, such as farms operating under cooperative arrangements (~6% of the total grain supply). All suppliers are required to be registered in Brazil’s Rural Environmental Cadaster (“CAR”) and are screened against embargo lists maintained by the Brazilian Institute of Environment and Renewable Natural Resources (“IBAMA”) and the Mato Grosso State Environment Secretariat (“SEMA”). Natural habitat loss in production areas is monitored using Brazil’s satellite imagery platforms PRODES (annual, high resolution monitoring), DETER (frequent, lower resolution monitoring) and MapBiomas Alerta systems, with focus on the Legal Amazon area and the Cerrado biome. At present, the system does not apply a cut off date for natural habitat conversion and does not restrict legally permitted suppression of natural vegetation. The system flags encroachment of production areas into Indigenous Peoples lands and, for production areas located within Protected Areas, compatibility with approved management plans is required; however, Internationally Recognized Areas are not currently addressed.
As per ESAP #3, Alvorada will strengthen its supply chain due diligence by extending traceability to indirect suppliers, establishing a natural habitat conversion cut-off date, integrating biodiversity risk screening for AZE and UNESCO World Heritage Sites, and conducting annual independent audits.
The ethanol plant and the company’s grain storage units currently require approximately 800,000 m³ of wood biomass per year for use as energy source for grain drying. At present, this demand is met through third party plantations, as well as biomass derived from authorized suppression of native forest vegetation. Certified biomass is not currently required. Per ESAP #10, Alvorada will implement a phase-out plan to discontinue the purchase and use of biomass sourced from native forests for ethanol production and will implement verification procedures to monitor compliance with this commitment.