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Environmental & Social Review Summary
Project Number
52106
Company Name
Fertil Pampa S.A.U.
Date ESRS Disclosed
Sep 10, 2026
Country
Argentina
Region
Latin America and the Caribbean
Last Updated Date
Oct 19, 2026
Environmental Category
A - Significant
Status
Pending Approval
Sector
Nitrogenous Fertilizer
Industry
Manufacturing
Department
Regional Industry MAS LAC & EUR
Project Description
Fertil Pampa S.A.U. ("Fertil Pampa" or the "Company") is a special purpose vehicle wholly owned by Pampa Energia S.A. ("Pampa" or the "Sponsor"), established to develop a greenfield urea production complex in Bahia Blanca, Province of Buenos Aires, Argentina (the "Project"). Pampa is Argentina's largest integrated energy company, with operations spanning power generation, oil and gas, and electricity transmission and distribution.
The Project will be located on an 80-hectare site within the Ingeniero White port complex, adjacent to Pampa's existing power generation assets, with access to natural gas supply, high-voltage transmission infrastructure, seawater intake facilities, and a deep-water export port. The nearest community is located at approximately 600 m northwest of the boundary of the Project property line, with no communities located at least 8 to 10 km to the south and west. The Project comprises: (i) an ammonia and carbon dioxide production unit with capacity to produce 3,450 metric tons per day (“MTPD”) of ammonia and 4,400 MTPD of CO2; (ii) two parallel urea production trains with a combined production capacity of 6,000 MTPD of granulated urea; (iii) auxiliary facilities for seawater treatment, compressed air, steam, and nitrogen production; (iv) storage facilities, including an ammonia tank with a 20,000 ton capacity and a granulated urea silo with a 200,000 ton capacity; and (v) logistics infrastructure for the dispatch of urea by truck and ammonia and urea by vessel. Construction will be carried out under an engineering, procurement, and construction (“EPC”) contract over 4 years, generating an estimated 3,500 jobs during construction and 300 permanent jobs during operations.
The proposed investment consists of an IFC A/B loan package of up to US$750 million, comprising an IFC A Loan of up to US$300 million for IFC's own account and a B/Parallel Loan of up to US$450 million to be mobilized from commercial banks and other development finance institutions. IFC's financing will support the design, construction, operation, and maintenance of the Project, which is expected to increase domestic fertilizer production, reduce reliance on urea imports in the Southern Cone (Argentina, Brazil, Paraguay, and Uruguay), and contribute to regional fertilizer supply security.
The Project will be located on an 80-hectare site within the Ingeniero White port complex, adjacent to Pampa's existing power generation assets, with access to natural gas supply, high-voltage transmission infrastructure, seawater intake facilities, and a deep-water export port. The nearest community is located at approximately 600 m northwest of the boundary of the Project property line, with no communities located at least 8 to 10 km to the south and west. The Project comprises: (i) an ammonia and carbon dioxide production unit with capacity to produce 3,450 metric tons per day (“MTPD”) of ammonia and 4,400 MTPD of CO2; (ii) two parallel urea production trains with a combined production capacity of 6,000 MTPD of granulated urea; (iii) auxiliary facilities for seawater treatment, compressed air, steam, and nitrogen production; (iv) storage facilities, including an ammonia tank with a 20,000 ton capacity and a granulated urea silo with a 200,000 ton capacity; and (v) logistics infrastructure for the dispatch of urea by truck and ammonia and urea by vessel. Construction will be carried out under an engineering, procurement, and construction (“EPC”) contract over 4 years, generating an estimated 3,500 jobs during construction and 300 permanent jobs during operations.
The proposed investment consists of an IFC A/B loan package of up to US$750 million, comprising an IFC A Loan of up to US$300 million for IFC's own account and a B/Parallel Loan of up to US$450 million to be mobilized from commercial banks and other development finance institutions. IFC's financing will support the design, construction, operation, and maintenance of the Project, which is expected to increase domestic fertilizer production, reduce reliance on urea imports in the Southern Cone (Argentina, Brazil, Paraguay, and Uruguay), and contribute to regional fertilizer supply security.
Overview of IFC's Scope of Review
IFC's Environmental and Social ("E&S") review of the Project included an appraisal site visit conducted in May 2026 to the Project site in Bahia Blanca and its surrounding area of influence. IFC’s review comprised of: (i) meetings with Fertil Pampa's and the Sponsor's management team, including representatives from Environment, Occupational Health and Safety ("OHS"), Human Resources ("HR"), Community Relations; (ii) review of the Project's Environmental and Social Impact Assessment ("ESIA") and supporting technical studies, including the Cumulative Impact Assessment ("CIA"), Critical Habitat Assessment ("CHA"), among others; (iii) evaluation of the proposed environmental management measures, including air emissions, greenhouse gas ("GHG") emissions, seawater intake and effluent discharge, water resource use, and waste management; (iv) assessment of labor and working conditions across direct and contracted workers, including OHS and process safety management during the construction and operation phases; (v) review of community health, safety, and security aspects, including emergency preparedness and response, hazardous materials management, and traffic and road safety associated with construction and operational logistics; (vi) evaluation of the Project's stakeholder engagement process, information disclosure, and grievance mechanisms, including policies for the prevention of gender-based violence (“GBV”) and sexual exploitation, abuse, and harassment ("SEAH"), which included meetings with community members, Civil Society Organizations (“CSOs”) and representatives of local government institutions; and (vii) assessment of biodiversity and living natural resources in the Bahia Blanca estuary, including potential impacts on protected areas, critical habitat, and artisanal fisheries.
E & S Project Categorization and Applicable Standard
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
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
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
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
This is a Category A project as per IFC’s Policy on Environmental and Social Sustainability (2012), as Project activities have the potential to cause significant adverse environmental risks and/or impacts that are diverse, irreversible, or unprecedented.
Key E&S risks and impacts associated with the Project include: (i) the Company’s capacity to develop, implement, and maintain an effective Environmental and Social Management System (“ESMS”) commensurate with the scale and complexity of the Project throughout construction and operations; (ii) management of labor and working conditions, including oversight of a large contractor workforce during construction and the associated OHS risks; (iii) risks related to the production, storage, handling, and transport of ammonia, natural gas, and other hazardous materials, including potential fires, explosions, toxic releases, and other major accident scenarios; (iv) community health, safety, and security risks associated with construction activities, worker influx, increased traffic, and the operation of a major industrial facility; (v) road safety risks arising from the transport of construction materials, heavy equipment, hazardous substances, and finished fertilizer products; (vi) management of air emissions, including GHG emissions, ammonia, nitrogen oxides (“NOx”), particulate matter, as well as wastewater discharges, solid and hazardous waste, and other industrial pollutants; (vii) biodiversity risks and impacts, including potential effects on natural habitats; (viii) water use, wastewater management, and potential impacts on shared water resources, aquatic environments, and ecosystem services; (ix) risks of GBV, SEAH, and other forms of worker misconduct associated with the construction workforce and its interaction with surrounding communities; and (x) emergency preparedness and response, including arrangements for coordination with local authorities, emergency services, port stakeholders, and neighboring industrial facilities within the Bahia Blanca industrial corridor.
Key E&S risks and impacts associated with the Project include: (i) the Company’s capacity to develop, implement, and maintain an effective Environmental and Social Management System (“ESMS”) commensurate with the scale and complexity of the Project throughout construction and operations; (ii) management of labor and working conditions, including oversight of a large contractor workforce during construction and the associated OHS risks; (iii) risks related to the production, storage, handling, and transport of ammonia, natural gas, and other hazardous materials, including potential fires, explosions, toxic releases, and other major accident scenarios; (iv) community health, safety, and security risks associated with construction activities, worker influx, increased traffic, and the operation of a major industrial facility; (v) road safety risks arising from the transport of construction materials, heavy equipment, hazardous substances, and finished fertilizer products; (vi) management of air emissions, including GHG emissions, ammonia, nitrogen oxides (“NOx”), particulate matter, as well as wastewater discharges, solid and hazardous waste, and other industrial pollutants; (vii) biodiversity risks and impacts, including potential effects on natural habitats; (viii) water use, wastewater management, and potential impacts on shared water resources, aquatic environments, and ecosystem services; (ix) risks of GBV, SEAH, and other forms of worker misconduct associated with the construction workforce and its interaction with surrounding communities; and (x) emergency preparedness and response, including arrangements for coordination with local authorities, emergency services, port stakeholders, and neighboring industrial facilities within the Bahia Blanca industrial corridor.
Environmental and Social Mitigation Measures
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. The Project has established an advanced foundation for managing E&S risks and impacts. This includes the ESIA, submitted to the competent authority in March 2026, which incorporates the identification and assessment of E&S impacts, mitigation measures, and an Environmental and Social Management Plan (“ESMP”) comprising environmental, social, monitoring, and contingency programs. These Project-level instruments are complemented by Pampa Energia’s corporate policies and procedures and the EHS management systems of the EPC contractors. Collectively, these instruments address most of the elements required under PS1; however, they have not yet been formally integrated into a Project-specific ESMS with a unified governance and implementation framework.
As part of ESAP Action #1, the Company will develop and implement an integrated, Project-specific ESMS that defines how these existing instruments and requirements will be applied, coordinated, and overseen at the Project level. The ESMS will establish clear governance arrangements and traceable links between risk and impact identification, management programs, organizational roles and responsibilities, contractor management, performance indicators, monitoring and reporting, corrective actions, and management review and continuous improvement. It will also ensure that management programs are prioritized according to E&S risk and impact significance, apply the mitigation hierarchy, and incorporate applicable requirements of the PSs, the WBG General EHS Guidelines, and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. The ESMS will apply throughout construction and operation and cover all Project components and activities.
Policy. The Project is supported by a comprehensive set of corporate and contractor policies, standards, and procedures addressing E&S management, OHS, ethics, legal compliance, risk management, stakeholder engagement, and continual improvement. Key instruments include Pampa Energia’s Integrated Management Policy, Code of Conduct, Respectful Treatment Policy, Strategic Stakeholder Management Procedure, Community Inquiries and Requests Management Procedure. The main EPC contractors, SACDE and Tecnimont, have also adopted corporate quality and EHS policies and plans covering environmental risk assessment, contractor management, training, environmental monitoring, incident investigation, auditing, OHS, emergency preparedness, with elements aligned with ISO 14001 and ISO 45001 standards. Collectively, these instruments provide an adequate policy foundation for the Project.
Identification of Risks and Impacts. The ESIA provides an E&S baseline and impact assessment covering the Project’s preconstruction, construction, operation, and closure phases. The main identified impacts relate to process and combustion emissions, liquid effluents, waste generation, increased traffic, and interaction with the estuarine environment. Social risks and impacts identified focus on management of high expectations of job and economic opportunities by the local population, health and social conflict from workers influx including SEAH, and safety risks associated with transportation of materials and equipment. Potential contingency scenarios associated with the Project include toxic releases, fires, explosions, natural gas leaks, transportation accidents, and other operational incidents that could pose risks to workers, the environment, and surrounding communities, in particular the Saladero, Boulevard, and 26 de Septiembre neighborhoods of Ingeniero White. The assessment also considers the Project’s associated infrastructure and is generally consistent with the principal risks addressed by the WBG General EHS Guidelines and the sector-specific guidelines applicable to nitrogenous fertilizer production.
The ESIA addresses cumulative impacts through its general methodology, supplemented by a June 2026 CIA. The CIA identifies Valued Environmental Components (“VECs”) and Valued Social Components (“VSC”) and evaluates the Project’s contribution to cumulative impacts in combination with other existing and reasonably foreseeable activities. The assessment identifies construction-related traffic, logistics demand, and temporary physical disturbance among the principal cumulative pressures, with lower cumulative effects expected during operations, and concludes that no high or critical cumulative impacts are anticipated. However, the analysis remains largely qualitative and could be further strengthened through the definition of explicit thresholds or limits of acceptable change for relevant VECs/VSCs, as well as through additional consideration of potentially relevant social, biodiversity, technological, and synergistic effects and reasonably foreseeable future developments.
Recent flooding events and preliminary hydrological assessments also highlight potential exposure of the Project and surrounding area to climate-related hazards. While certain climate-related considerations have been incorporated into the available studies, a comprehensive assessment of physical and transition climate risks, considering appropriate climate scenarios and time horizons aligned with the Project life cycle, has not yet been completed.
Under ESAP Action #2, the Company will update the CIA in accordance with IFC’s Good Practice Handbook to refine the selection of VECs/VSCs and associated spatial and temporal boundaries; consider relevant existing and reasonably foreseeable projects, activities, and E&S stressors; strengthen the baseline and assessment of cumulative effects; establish appropriate indicators and, where feasible, thresholds for determining significance; and identify any additional Project-specific or collaborative management and monitoring measures required to maintain relevant VECs/VSCs within acceptable conditions. The Company will also complete a comprehensive assessment of physical and transition climate-related risks, considering appropriate climate scenarios and time horizons aligned with the Project life cycle, identify material risks and vulnerabilities, and define corresponding adaptation and resilience measures, as applicable.
Given the Project’s current stage of development and the level of engineering information available, the potential consequences and impact ranges associated with major accident scenarios have not yet been quantitatively assessed, including potential impacts on workers and surrounding communities. As part of ESAP Action #3, during subsequent engineering phases, the Company will undertake a comprehensive Quantitative Risk Assessment (“QRA”) consistent with Good International Industry Practice (“GIIP”), to estimate potential impact ranges under credible major accident scenarios associated with the storage and handling of ammonia and other hazardous materials, including loading operations. The QRA will assess potential impacts on workers and off-site receptors, including nearby communities and industrial facilities. In addition, the Company will complete relevant process safety studies, including Hazard and Operability (“HAZOP”), Layers of Protection Analysis (“LOPA”), Safety Integrity Level (“SIL”), identification of Safety Critical Elements (“SCEs”) and associated Performance Standards, Hazardous Area Classification, Occupied Buildings Risk Assessment (“OBRA”), and Escape and Evacuation Risk Assessment (“EERA”). The findings and recommendations of these studies will be incorporated into the final facility design, including the final layout, the design of fire and explosion prevention, detection, protection, and mitigation systems, operating procedures, emergency preparedness and response measures, process safety management systems, and other measures required to further reduce risks to workers and surrounding communities in accordance with IFC PSs and GIIP. The QRA and other relevant process-safety studies will be completed sufficiently in advance of Project design finalization and commissioning to ensure that their findings can inform design decisions and when necessary, the implementation of additional risk mitigation measures.
Management Programs. The Project’s ESMP establishes the basis E&S management throughout the Project life cycle and includes an Environmental Protection Plan, Environmental Monitoring Plan, Environmental Contingency Plan, and Social Management Plan. These programs address, among other factors, air emissions, effluents, waste and hazardous materials, water and biological resources, noise, environmental restoration, stakeholder communication, and community relations.
While the ESMP generally addresses the main E&S risks and applicable Argentine regulatory requirements, it does not yet fully meet the management program requirements of PS1. In particular, it does not clearly demonstrate how management measures are linked to the identified risks and impacts, apply the mitigation hierarchy, establish measurable performance and monitoring requirements, or provide for systematic corrective action and revision of measures based on monitoring results. The ESMP also does not yet clearly incorporate the applicable performance criteria and management measures of the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Under ESAP Action #4, the Company will develop and implement phase-specific construction and operational ESMPs to: (i) incorporate applicable EHS performance criteria and management measures from the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production; (ii) link management measures to the identified E&S risks and impacts and apply the mitigation hierarchy; (iii) define measurable performance indicators, monitoring requirements, responsibilities, and reporting arrangements; and (iv) establish processes for corrective action and revision of management measures based on monitoring results. During construction, the EPC contractors’ EHS plans will be required to conform with these Project-level requirements, with Fertil Pampa retaining overall responsibility for supervision and E&S performance.
Based on the current Project design and available information, physical or economic displacement is not expected. The Project will be located entirely within the port’s industrial area, and the original design of the effluent discharge system has been modified to avoid potential impacts on the estuary. These factors substantially reduce the likelihood of physical or economic displacement of surroundings communities. The Company will continue to evaluate potential off-site risks through Project design studies and risk assessments, including the QRA. Should such assessments identify an unavoidable need for the relocation of households or economic activities, the Company will develop a Land Acquisition and Resettlement Framework to guide the management of any potential displacement.
Organizational Capacity and Competence. The Project has an established organizational basis for managing E&S risks, supported by Project personnel and Pampa Energia’s corporate functions with expertise in E&S management, OHS, HR, labor relations, institutional relations, communications, and stakeholder engagement. The ESMP also requires construction contractors to provide qualified EHS personnel and establishes coordination with the Project supervision team.
While the existing structure provides a sound basis for E&S management at the current stage, the key Project-level E&S functions have not yet been formally designated for the forthcoming construction phase. Given the scale and complexity of the Project and the expected contractor workforce, dedicated accountability for EHS and social management will be required to ensure effective implementation, supervision, and coordination of the Project’s E&S requirements. Under the ESAP (Action #5), the Company will designate for the Project: (i) an Environmental Officer; (ii) a Social Officer; and (iii) an OHS Officer. The Project’s ESMS will further define their roles and responsibilities, reporting lines, competency requirements, interfaces with corporate functions and contractors, and resource requirements for construction and operations.
Emergency Preparedness and Response (EPR). The Sponsor has established a corporate EPR framework that defines general roles, responsibilities, communication channels, and emergency-management criteria. The framework also references the Awareness and Preparedness for Emergencies at Local Level process to support coordination among facilities, competent authorities, emergency services, neighboring facilities, and other relevant stakeholders. It requires each facility to prepare an Emergency Preparedness and Response Plan (“EPRP”), with emergency levels, response arrangements, and notification requirements informed by the applicable safety studies and, where relevant, quantitative risk assessments.
Given the early stage of Project development, the Project has not yet been incorporated into the corporate EPR framework, and Project-specific process safety studies remain to be developed. Accordingly, during the detailed engineering phase, the Company will complete the applicable process-safety studies, including the QRA, and use the findings and recommendations to prepare, implement, and maintain a Project-specific EPRP (ESAP Action #6).
The EPRP will address credible accidental scenarios and their potential on-site and off-site consequences; emergency classification and activation criteria; response procedures, equipment, and resources; roles and responsibilities; notification and communication protocols; coordination with competent authorities, emergency services, port authorities, neighboring facilities, and potentially affected surroundings communities; and arrangements for training, drills, testing, review, incorporating lessons learned, and periodic updating.
Monitoring and Review. The ESMP establishes E&S monitoring, inspections, compliance tracking, performance records, periodic reporting, environmental audits, management review, and corrective-action processes. Pampa Energia’s corporate systems further provide for stakeholder identification and review, performance indicators, action-plan tracking, periodic management reporting, incident evaluation, and post-incident review. These arrangements provide an adequate framework for monitoring and review consistent with PS1.
Monitoring results and audit findings will be consolidated through the ESMS and used to assess the effectiveness of mitigation measures and identify corrective actions where required. The Project-specific monitoring requirements will be further developed and implemented as part of the ESMS (ESAP Action #1) and relevant management plans, with detailed technical monitoring commitments addressed in the PS3 and PS6 sections and the corresponding ESAP actions.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures. The Sponsor has established a corporate HR framework that includes policies and procedures covering recruitment and hiring, employee development and training, performance management, labor relations, ethics and conduct, diversity and inclusion, OHS, and a grievance mechanism. The framework is generally aligned with the objectives of PS2 and provides a basis for managing labor and working conditions for the Project. For contracted workers, applicable PS2 requirements will be implemented through contractual provisions, contractor and subcontractor management procedures, and Project-level oversight, including requirements related to terms and conditions of employment, non-discrimination and equal opportunity, freedom of association, child and forced labor, worker grievance mechanisms, and OHS.
As per ESAP Action #1, the applicable HR policies and procedures will be integrated into the Project’s specific ESMS, including provisions on child and forced labor and the right of freedom of association, to ensure consistent implementation and monitoring of labor requirements throughout the construction and operational phases. The Company will implement established HR processes and training programs, including the “Academia Pampa” corporate training platform, to support workforce development and competency building for Project personnel in line with corporate policies. Requirements applicable to contractors and subcontractors will be addressed through contractual provisions, contractor-management procedures, and Project-level supervision, while worker grievance requirements will be addressed under ESAP Action #8.
Working Conditions and Terms of Employment. The Project is expected to generate significant employment opportunities during construction and operation, with approximately 3,500 workers expected during the peak of construction and approximately 300 permanent workers during operations. Working conditions for direct and contracted workers will be governed by applicable Argentine labor legislation and corporate employment procedures, and the applicable requirements of PS2. A formal hiring program to promote local employment will be developed and implemented as per ESAP Action #7. Induction programs including clear disclosure of workers’ rights and responsibilities, performance management procedures, and ongoing training programs will be implemented throughout the Project life cycle, as established in the corporate HR framework.
The Company, through the HR corporate framework, has procedures governing labor administration, compensation, benefits, disciplinary processes, and workforce management that will be implemented at the Project level. Contractor management processes include verification of labor and social security compliance and occupational health and safety requirements.
Workers’ Organization. Workers involved in the Project will be entitled to exercise their rights in accordance with applicable Argentine legislation and international conventions, including freedom of association and collective bargaining. Labor unions are active in the Project area, including organizations representing construction workers and other industrial sectors that may be involved during Project construction and operations. The Company will respect workers’ rights to freedom of association and collective bargaining and will not discriminate or retaliate against workers exercising these rights.
Non-discrimination and Equal Opportunity. The corporate human resources procedures applicable to the Project include provisions promoting non-discrimination and equal opportunity in recruitment, hiring, career development and employment practices. The Company applies procedures intended to support objective and transparent candidate selection and evaluation, and to prevent discrimination based on personal characteristics protected under applicable legislation and Company policies. The Company recognizes the risks of GBV, SEAH, and other forms of workplace harassment, and has established programs and provisions under its Code of Conduct to promote respectful workplace practices and gender equality. Training for employees includes ethical leadership and prevention of sexual and other forms of harassment.
Worker’s Grievance Mechanism (“GM”). The Project will utilize established corporate grievance and whistleblower mechanisms applicable to employees, contractors, and subcontractors. These mechanisms provide multiple channels for reporting labor-related concerns, including allegations of misconduct, harassment, discrimination, unethical behavior, and other workplace grievances. The mechanisms include procedures for receiving, investigating, documenting, and resolving complaints while maintaining confidentiality where appropriate. Fertil Pampa will update and operationalize the workers’ grievance mechanism at the Project level to include specific provisions for receiving and managing GBVH-related grievances using a survivor-centered approach, as per ESAP Action #8. The Project-level mechanism will be designed to allow anonymous complaints to be raised and addressed, be accessible and culturally appropriate to all workers, and incorporate measures to support confidentiality, transparency, accountability, and protection against retaliation.
Protecting the Workforce. The Company’s HR and contractor management procedures prohibit child labor, forced labor, bonded labor, and other forms of involuntary labor. Hiring procedures require verification of worker identity and age and are designed to support compliance with applicable labor legislation and relevant International Labor Organization (“ILO”) conventions. The Company’s recruitment controls and contractor due diligence processes include measures to identify and prevent unlawful labor practices among the Project workforce and, where applicable, within the contractor workforce and relevant supply chains. Implementation of these requirements will be monitored through the ESMS, with corrective actions managed as necessary (ESAP Action #1).
Occupational Health and Safety (OHS). The main OHS and process safety risks associated with the Project relate to the handling, processing, storage and transfer of hazardous substances, including potential worker exposure to ammonia and other hazardous materials, as well as fire and explosions. As described under PS1 (ESAP Action #3), the Company will complete a QRA, followed by additional detailed process-safety studies. In addition, prior to commissioning (ESAP Action #9), the Company will develop and implement an OHS and Process Safety Management System integrated into the Project’s ESMS and aligned with applicable national requirements, the WBG General EHS Guidelines, the WBG EHS Guidelines for Nitrogenous Fertilizer Production and GIIP, including, as applicable, the elements of the U.S. Occupational Safety and Health Administration (“OSHA”) Process Safety Management standard (29 CFR 1910.119), the Center for Chemical Process Safety (“CCPS”) Risk Based Process Safety (“RBPS”)framework , the American Petroleum Institute Recommended Practice (“API RP”) 754, and relevant standard issued by the National Fire Protection Association (“NFPA”),. The system will include, at a minimum: (i) process hazard identification, risk assessment, and risk management; (ii) procedures for routine, non-routine, and emergency activities; (iii) management of change; (iv) mechanical integrity and management of safety critical elements; (v) contractor-safety management; (vi) emergency preparedness and response; (vii) occupational health surveillance and exposure monitoring; (viii) competency, training, and authorization requirements; (ix) incident reporting, investigation, and lessons learned; and (x) performance monitoring, auditing, management review, and continual improvement.
During construction, key risks are associated with the size of the workforce, which is expected to peak at approximately 3,500 workers, and the execution of high-risk activities, including work at height, excavation, lifting operations, confined-space entry, electrical work, heavy-equipment operation, transportation, and simultaneous activities involving multiple contractors and subcontractors.
Fertil Pampa will rely on Pampa Energia’s corporate EHS framework and the EHS management systems of the principal EPC contractors, SACDE and Tecnimont. These systems include OHS policies, hazard-identification and risk-assessment processes, permit-to-work systems, training programs, incident notification, reporting and investigation procedures, inspections, audits, EPR arrangements, and contractor-performance monitoring. The Project ESMP also establishes OHS requirements for the construction phase and requires contractors to appoint dedicated EHS personnel and prepare and implement site-specific EHS plans.
Workers Engaged by Third Parties. The Project's workforce during construction will be predominantly composed of workers engaged by third parties, including contractors, subcontractors, and specialized service providers. Contractual agreements require EPC contractors to manage their workforce in accordance with applicable Argentine labor legislation and the Company’s applicable HR and OHS requirements. The Company will oversee contractor performance through the Project’s ESMS and contractor-management arrangements, including monitoring of labor and working conditions against applicable PS2 requirements.
PS3: Resource Efficiency and Pollution Prevention
Resource Use and Efficiency. Main resources to be used in the process include natural gas, seawater and electricity and the Project will benefit from existing infrastructure within the Ingeniero White industrial and port complex. The Project will incorporate process optimization measures, including heat recovery and water reuse to improve resource efficiency and reduce energy consumption per unit of production.
GHG Emissions. The Project will generate 0.436 tons of CO2 eq/year, primarily from natural gas consumption, fuel combustion, and process emissions associated with ammonia production. The selected process configuration includes the recovery and use of carbon dioxide generated during ammonia production as feedstock for urea manufacturing. This will reduce direct CO2 releases relative to standalone ammonia production, although a proportion of the carbon incorporated into urea may ultimately be released during product use.
Water Consumption. Water will be sourced from the Bahia Blanca estuary through the existing water intake infrastructure associated with the adjacent Central Termica Piedra Buena (“CTPB”), rather than through a new Project-specific intake. Water will be used in the ammonia and urea production processes, as well as associated utility systems, including cooling and steam generation. As per the ESIA, Fertil Pampa has obtained a Water Prefeasibility Certificate (Certificado de Prefactibilidad Hidrica) confirming that the required water demand can be met. The Project’s water requirements can be accommodated within the existing authorized abstraction capacity of the CTPB intake, without the need to increase the currently authorized withdrawal volume or develop a new intake structure.
Air Emissions. The principal sources of air emissions during operations will include the ammonia and urea production units, reforming and combustion systems, auxiliary boilers, vents, material-handling systems, and other process equipment. Key pollutants are expected to include nitrogen oxides, particulate matter, carbon monoxide, ammonia, and GHG emissions.
The proposed design incorporates emission-control technologies and operational measures intended to meet applicable Argentine requirements. As part of the ESIA, Fertil Pampa conducted an air-dispersion modeling of the main process units to assess potential impacts on ambient air quality and all modeled pollutant concentrations remained below Argentinian air quality standards. However, the modeling identified that ammonia emissions from the granulation units would exceed the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Under ESAP Action #10, the Company will upgrade the technical design of pollution prevention measures to reduce ammonia emissions and seek alignment with the WBG EHS Guidelines for Nitrogenous Fertilizer Production. The Company will also strengthen and implement the Air Quality Monitoring Program by defining monitoring frequencies for gaseous emissions and ambient air quality and incorporating applicable international standards.
Wastewater. The Project will generate industrial wastewater from process operations, cooling systems, water-treatment units, equipment cleaning, and other ancillary activities, together with sanitary wastewater from worker and operational facilities. The proposed wastewater-management system will include segregation, collection, treatment, monitoring, reuse where feasible, and controlled discharge. Fertil Pampa modeled the discharge of treated effluent into Bahia Blanca RIA, with results indicating that the originally proposed discharge could increase salinity and adversely affect water quality and aquatic communities. To reduce these impacts, the Company has evaluated design improvements, including relocation of the discharge point, incorporation of additional wastewater streams into the treatment system, and reduction of seawater consumption and associated salt loads. However, additional characterization of wastewater streams and assessment of the final discharge configuration are still required to demonstrate that the wastewater-management system and final effluent discharge will me applicable requirements of the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Therefore, under ESAP Action #11, the Company will: (i) further characterize wastewater streams, finalize the wastewater management system design, and demonstrate compliance with applicable WBG effluent guidelines; (ii) assess potential impacts of brine discharge on the receiving marine/estuarine environment, including water quality, aquatic communities, fisheries resources, ecosystem services, and artisanal and recreational fishers, as applicable, and implement appropriate mitigation measures, as necessary; and (iii) develop and implement a Final Liquid Effluent Discharge Quality Monitoring Program.
Further, as part of the CIA (ESAP Action #2), the Company will also assess the cumulative effects of the Project’s effluent discharge in combination with other existing and reasonably foreseeable discharges and activities affecting the Bahia Blanca estuary and identify additional mitigation or management measures, as necessary.
Waste. Construction activities will generate non-hazardous and hazardous waste, including excavated materials, construction debris, scrap metal, packaging, used oils, contaminated materials, chemical containers, and domestic waste from worker facilities. During operations, waste will arise from process activities, maintenance, water and wastewater treatment, laboratories, offices, and other ancillary facilities. The ESMP includes general procedures for waste identification, segregation, labeling, storage, transport, recycling, treatment, and disposal through authorized service providers. Hazardous and non-hazardous wastes will be managed separately in accordance with applicable national requirements.
Hazardous Materials. In addition to natural gas and ammonia for which a QRA and other process safety studies will be developed as described under PS1 (ESAP Action #3), the main hazardous materials that will be present on-site, include fuels, lubricants, process chemicals, catalysts, and water-treatment chemicals. As part of ESAP Action #4, the Company will develop a Hazardous Materials Management Plan that includes the inventory of hazardous materials and safety data sheets, establishes compatibility and segregation requirements, define secondary-containment and leak-detection measures, operational procedures for transport, handling, spill prevention, emergency response, and disposal in accordance with applicable requirements and GIIP. Requirements will be also applicable to the EPC contractor’s EHS system.
Noise. As part of the ESIA, the Company conducted a noise impact assessment covering construction and operational activities. The assessment concluded that predicted noise levels at the nearest residential and recreational receptors are generally expected to remain below applicable standards and WBG General EHS Guidelines and are not expected to result in significant noise impacts.
PS4: Community Health, Safety and Security
Identification of risks and impacts and mitigation measures. The main community health and safety risks associated with the Project, as identified in the ESIA, include increased traffic and logistics activity, transportation of hazardous materials and potential major accident scenarios associated with ammonia storage and handling. The Project ESMP includes preliminary mitigation measures to manage these risks.
Infrastructure, Hazardous Materials Management and Safety. The facility will incorporate multiple layers of process-safety protection, including fire and gas detection, fire-protection systems, emergency shutdown and isolation systems, hazardous-material containment measures, and pressure-relief systems. As described under PS1 (ESAP Action #3), the Company will complete a preliminary QRA to evaluate risks to off-site receptors and identify any additional prevention, mitigation, land-use planning, and emergency preparedness measures needed to achieve risk levels consistent with GIIP and PS4 requirements.
Emergency Preparedness and Response. As described under PS1 (ESAP Action #6), the Company will develop and implement a Project-specific Emergency Preparedness and Response Plan informed by the findings of the QRA and other process-safety studies. The plan will address credible on-site and off-site emergency scenarios and establish appropriate response, communication, notification, and coordination arrangements with workers, emergency services, competent authorities, neighboring facilities, port operators, and potentially affected communities.
Traffic Impacts and Transportation Safety. Construction and operation of the Project will increase road and port-related traffic associated with the movement of personnel, construction materials, equipment and final products. The CIA identifies construction-related traffic and logistics demand as one of the principal cumulative pressures within the Project’s area of influence. The Project benefits from its location within an established industrial and port complex with existing logistics infrastructure and access to regional transportation networks and the Company has developed a Traffic Management Program to manage safety risks from materials, equipment and personnel transportation. The Project has the potential to increase traffic due to the increased workforce during construction and interactions with the surrounding communities. The Company will prepare a Community Health and Safety Plan (ESAP #12) to establish prevention and mitigation measures for those risks.
Ecosystem Services. The Project is located within the Bahia Blanca estuary, an environmentally sensitive area that supports ecological functions, fisheries, navigation, industrial activities, and other ecosystem services used by local communities. Potential impacts on ecosystem services are primarily associated with seawater abstraction, wastewater discharge, dredging and port activities where relevant, accidental releases, and cumulative pressures on estuarine habitats and biological communities.
Under the consolidated ESMP, the Company will further assess Project dependencies and impacts on priority ecosystem services (Please refer to the PS6 section), including services relevant to artisanal and recreational fishing, navigation, water quality, and other users of the estuarine environment. The Company will establish appropriate monitoring indicators, stakeholder engagement arrangements, management thresholds, and adaptive management measures to identify and respond to material changes throughout construction and operation.
Security Personnel. The Project is located within the industrial area of the port of Bahia Blanca and will rely on a combination of authorized private security contractors providing unarmed guards operating under the corporate security procedures, and coordination with public authorities responsible for maintaining security within the port complex. Security requirements during construction will primarily focus on controlling access to the Project site, protecting personnel and assets, managing interactions with contractors and visitors, and ensuring the safe movement of equipment and materials. During operations, security management will consider the presence of critical industrial infrastructure and significant quantities of ammonia, natural gas, and other hazardous materials. The Company's "Security Personnel and Community Relations Management Procedure” incorporates provisions for contracting and managing private security companies, including vetting personnel and ensuring adequate training on human rights, use of force and deescalation of conflicts.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is located on coastal land historically reclaimed with dredged material and subsequently colonized by a mix of exotic and native vegetation within an industrial port zone and boundaries of the Bahia Blanca, Bahia Falsa y Bahia Verde estuary recognized as a Key Biodiversity Area (“KBA”) and Important Bird Area (“IBA”). The area of indirect influence overlaps two provincial legally protected areas: the Reserva Natural Provincial Bahia Blanca, Bahia Falsa y Bahia Verde, a large multiple-use reserve encompassing islands, channels, and coastal marshes; and the Reserva Natural Provincial Islote de la Gaviota Cangrejera, located approximately 1–2 km from the Project footprint and established specifically to protect the Olrog's Gull (Larus atlanticus) and associated shorebird communities. The estuary also forms part of the Western Hemisphere Shorebird Reserve Network, underscoring its hemispheric significance for migratory shorebird species, and has been proposed as a potential Ramsar Wetland Site.
Biodiversity values of conservation priority potentially within the project’s area of influence include Narrownose Smooth-hound (Mustelus schmitti, globally CR), Angular Angelshark (Squatina guggenheim, globally EN), Franciscana Dolphin (Pontoporia blainvillei, globally VU), Olrog’s Gull (globally NT, nationally VU), and Red Knot (Calidris canutus rufa, globally NT and nationally EN). No species of conservation concern are likely to occur or have been detected in the Project footprint. Howeverin order to fill baseline survey gaps identified during ESDD review, per ESAP Action #13, Fertil Pampa will conduct additional targeted surveys within the project’s area of direct influence as well as Natural Habitat at the discharge point, to document presence of biodiversity values and manage accordingly.
Given the Project’s location on modified terrestrial habitat and the implementation of management measures to manage potential estuary-related impacts, the Project is not expected to jeopardize priority biodiversity values or result in significant long-term impacts to Critical Habitat (CH) or the ecological processes that support those values, as long as the risk of chemical spills is adequately managed. However, to identify target biodiversity management goals aligned with PS6 requirements, Fertil Pampa will complete the Critical Habitat Assessment (CHA) and formally adopt findings of risk assessment results and proposed mitigation, as per ESAP Action #14. Compliance with IFC PS6 also requires Fertil Pampa to prepare a Biodiversity Action Plan (“BAP”), supported by a Biodiversity Monitoring and Evaluation Plan (“BMEP”), to outline, implement and track mitigation actions towards Net Gain objectives in CH, under ESAP Action #15. The BAP needs to apply the mitigation hierarchy, quantify any residual loss, and establish a credible pathway to Net Gain for each Critical Habitat-qualifying biodiversity value. The BAP/BMEP should also address broader operational biodiversity risks, including chemical spill prevention and response measures (see PS3), controls to prevent invasive aquatic species from being introduced through vessel ballast water, water quality/salinity monitoring, and potential construction phase impacts including light pollution and underwater sound impacts. The Project’s BAP and BMEP will be embedded in the company’s ESMS, to include measures specific to protect biodiversity and ecosystem services, cross referenced to applicable construction and operational management. Adaptive management will feed back into the NG strategy outlined in the BAP for CH and the ecological processes that support it.
In addition, given the project’s location in a KBA, in agreement with relevant sponsors, Fertil Pampa will identify and implement additional conservation actions consistent with Paragraph 20 of PS6 to support the conservation aims of the Bahia Blanca, Bahia Falsa, Bahia Verde KBA/IBA as per ESAP Action #16.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Management System. The Project has established an advanced foundation for managing E&S risks and impacts. This includes the ESIA, submitted to the competent authority in March 2026, which incorporates the identification and assessment of E&S impacts, mitigation measures, and an Environmental and Social Management Plan (“ESMP”) comprising environmental, social, monitoring, and contingency programs. These Project-level instruments are complemented by Pampa Energia’s corporate policies and procedures and the EHS management systems of the EPC contractors. Collectively, these instruments address most of the elements required under PS1; however, they have not yet been formally integrated into a Project-specific ESMS with a unified governance and implementation framework.
As part of ESAP Action #1, the Company will develop and implement an integrated, Project-specific ESMS that defines how these existing instruments and requirements will be applied, coordinated, and overseen at the Project level. The ESMS will establish clear governance arrangements and traceable links between risk and impact identification, management programs, organizational roles and responsibilities, contractor management, performance indicators, monitoring and reporting, corrective actions, and management review and continuous improvement. It will also ensure that management programs are prioritized according to E&S risk and impact significance, apply the mitigation hierarchy, and incorporate applicable requirements of the PSs, the WBG General EHS Guidelines, and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. The ESMS will apply throughout construction and operation and cover all Project components and activities.
Policy. The Project is supported by a comprehensive set of corporate and contractor policies, standards, and procedures addressing E&S management, OHS, ethics, legal compliance, risk management, stakeholder engagement, and continual improvement. Key instruments include Pampa Energia’s Integrated Management Policy, Code of Conduct, Respectful Treatment Policy, Strategic Stakeholder Management Procedure, Community Inquiries and Requests Management Procedure. The main EPC contractors, SACDE and Tecnimont, have also adopted corporate quality and EHS policies and plans covering environmental risk assessment, contractor management, training, environmental monitoring, incident investigation, auditing, OHS, emergency preparedness, with elements aligned with ISO 14001 and ISO 45001 standards. Collectively, these instruments provide an adequate policy foundation for the Project.
Identification of Risks and Impacts. The ESIA provides an E&S baseline and impact assessment covering the Project’s preconstruction, construction, operation, and closure phases. The main identified impacts relate to process and combustion emissions, liquid effluents, waste generation, increased traffic, and interaction with the estuarine environment. Social risks and impacts identified focus on management of high expectations of job and economic opportunities by the local population, health and social conflict from workers influx including SEAH, and safety risks associated with transportation of materials and equipment. Potential contingency scenarios associated with the Project include toxic releases, fires, explosions, natural gas leaks, transportation accidents, and other operational incidents that could pose risks to workers, the environment, and surrounding communities, in particular the Saladero, Boulevard, and 26 de Septiembre neighborhoods of Ingeniero White. The assessment also considers the Project’s associated infrastructure and is generally consistent with the principal risks addressed by the WBG General EHS Guidelines and the sector-specific guidelines applicable to nitrogenous fertilizer production.
The ESIA addresses cumulative impacts through its general methodology, supplemented by a June 2026 CIA. The CIA identifies Valued Environmental Components (“VECs”) and Valued Social Components (“VSC”) and evaluates the Project’s contribution to cumulative impacts in combination with other existing and reasonably foreseeable activities. The assessment identifies construction-related traffic, logistics demand, and temporary physical disturbance among the principal cumulative pressures, with lower cumulative effects expected during operations, and concludes that no high or critical cumulative impacts are anticipated. However, the analysis remains largely qualitative and could be further strengthened through the definition of explicit thresholds or limits of acceptable change for relevant VECs/VSCs, as well as through additional consideration of potentially relevant social, biodiversity, technological, and synergistic effects and reasonably foreseeable future developments.
Recent flooding events and preliminary hydrological assessments also highlight potential exposure of the Project and surrounding area to climate-related hazards. While certain climate-related considerations have been incorporated into the available studies, a comprehensive assessment of physical and transition climate risks, considering appropriate climate scenarios and time horizons aligned with the Project life cycle, has not yet been completed.
Under ESAP Action #2, the Company will update the CIA in accordance with IFC’s Good Practice Handbook to refine the selection of VECs/VSCs and associated spatial and temporal boundaries; consider relevant existing and reasonably foreseeable projects, activities, and E&S stressors; strengthen the baseline and assessment of cumulative effects; establish appropriate indicators and, where feasible, thresholds for determining significance; and identify any additional Project-specific or collaborative management and monitoring measures required to maintain relevant VECs/VSCs within acceptable conditions. The Company will also complete a comprehensive assessment of physical and transition climate-related risks, considering appropriate climate scenarios and time horizons aligned with the Project life cycle, identify material risks and vulnerabilities, and define corresponding adaptation and resilience measures, as applicable.
Given the Project’s current stage of development and the level of engineering information available, the potential consequences and impact ranges associated with major accident scenarios have not yet been quantitatively assessed, including potential impacts on workers and surrounding communities. As part of ESAP Action #3, during subsequent engineering phases, the Company will undertake a comprehensive Quantitative Risk Assessment (“QRA”) consistent with Good International Industry Practice (“GIIP”), to estimate potential impact ranges under credible major accident scenarios associated with the storage and handling of ammonia and other hazardous materials, including loading operations. The QRA will assess potential impacts on workers and off-site receptors, including nearby communities and industrial facilities. In addition, the Company will complete relevant process safety studies, including Hazard and Operability (“HAZOP”), Layers of Protection Analysis (“LOPA”), Safety Integrity Level (“SIL”), identification of Safety Critical Elements (“SCEs”) and associated Performance Standards, Hazardous Area Classification, Occupied Buildings Risk Assessment (“OBRA”), and Escape and Evacuation Risk Assessment (“EERA”). The findings and recommendations of these studies will be incorporated into the final facility design, including the final layout, the design of fire and explosion prevention, detection, protection, and mitigation systems, operating procedures, emergency preparedness and response measures, process safety management systems, and other measures required to further reduce risks to workers and surrounding communities in accordance with IFC PSs and GIIP. The QRA and other relevant process-safety studies will be completed sufficiently in advance of Project design finalization and commissioning to ensure that their findings can inform design decisions and when necessary, the implementation of additional risk mitigation measures.
Management Programs. The Project’s ESMP establishes the basis E&S management throughout the Project life cycle and includes an Environmental Protection Plan, Environmental Monitoring Plan, Environmental Contingency Plan, and Social Management Plan. These programs address, among other factors, air emissions, effluents, waste and hazardous materials, water and biological resources, noise, environmental restoration, stakeholder communication, and community relations.
While the ESMP generally addresses the main E&S risks and applicable Argentine regulatory requirements, it does not yet fully meet the management program requirements of PS1. In particular, it does not clearly demonstrate how management measures are linked to the identified risks and impacts, apply the mitigation hierarchy, establish measurable performance and monitoring requirements, or provide for systematic corrective action and revision of measures based on monitoring results. The ESMP also does not yet clearly incorporate the applicable performance criteria and management measures of the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Under ESAP Action #4, the Company will develop and implement phase-specific construction and operational ESMPs to: (i) incorporate applicable EHS performance criteria and management measures from the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production; (ii) link management measures to the identified E&S risks and impacts and apply the mitigation hierarchy; (iii) define measurable performance indicators, monitoring requirements, responsibilities, and reporting arrangements; and (iv) establish processes for corrective action and revision of management measures based on monitoring results. During construction, the EPC contractors’ EHS plans will be required to conform with these Project-level requirements, with Fertil Pampa retaining overall responsibility for supervision and E&S performance.
Based on the current Project design and available information, physical or economic displacement is not expected. The Project will be located entirely within the port’s industrial area, and the original design of the effluent discharge system has been modified to avoid potential impacts on the estuary. These factors substantially reduce the likelihood of physical or economic displacement of surroundings communities. The Company will continue to evaluate potential off-site risks through Project design studies and risk assessments, including the QRA. Should such assessments identify an unavoidable need for the relocation of households or economic activities, the Company will develop a Land Acquisition and Resettlement Framework to guide the management of any potential displacement.
Organizational Capacity and Competence. The Project has an established organizational basis for managing E&S risks, supported by Project personnel and Pampa Energia’s corporate functions with expertise in E&S management, OHS, HR, labor relations, institutional relations, communications, and stakeholder engagement. The ESMP also requires construction contractors to provide qualified EHS personnel and establishes coordination with the Project supervision team.
While the existing structure provides a sound basis for E&S management at the current stage, the key Project-level E&S functions have not yet been formally designated for the forthcoming construction phase. Given the scale and complexity of the Project and the expected contractor workforce, dedicated accountability for EHS and social management will be required to ensure effective implementation, supervision, and coordination of the Project’s E&S requirements. Under the ESAP (Action #5), the Company will designate for the Project: (i) an Environmental Officer; (ii) a Social Officer; and (iii) an OHS Officer. The Project’s ESMS will further define their roles and responsibilities, reporting lines, competency requirements, interfaces with corporate functions and contractors, and resource requirements for construction and operations.
Emergency Preparedness and Response (EPR). The Sponsor has established a corporate EPR framework that defines general roles, responsibilities, communication channels, and emergency-management criteria. The framework also references the Awareness and Preparedness for Emergencies at Local Level process to support coordination among facilities, competent authorities, emergency services, neighboring facilities, and other relevant stakeholders. It requires each facility to prepare an Emergency Preparedness and Response Plan (“EPRP”), with emergency levels, response arrangements, and notification requirements informed by the applicable safety studies and, where relevant, quantitative risk assessments.
Given the early stage of Project development, the Project has not yet been incorporated into the corporate EPR framework, and Project-specific process safety studies remain to be developed. Accordingly, during the detailed engineering phase, the Company will complete the applicable process-safety studies, including the QRA, and use the findings and recommendations to prepare, implement, and maintain a Project-specific EPRP (ESAP Action #6).
The EPRP will address credible accidental scenarios and their potential on-site and off-site consequences; emergency classification and activation criteria; response procedures, equipment, and resources; roles and responsibilities; notification and communication protocols; coordination with competent authorities, emergency services, port authorities, neighboring facilities, and potentially affected surroundings communities; and arrangements for training, drills, testing, review, incorporating lessons learned, and periodic updating.
Monitoring and Review. The ESMP establishes E&S monitoring, inspections, compliance tracking, performance records, periodic reporting, environmental audits, management review, and corrective-action processes. Pampa Energia’s corporate systems further provide for stakeholder identification and review, performance indicators, action-plan tracking, periodic management reporting, incident evaluation, and post-incident review. These arrangements provide an adequate framework for monitoring and review consistent with PS1.
Monitoring results and audit findings will be consolidated through the ESMS and used to assess the effectiveness of mitigation measures and identify corrective actions where required. The Project-specific monitoring requirements will be further developed and implemented as part of the ESMS (ESAP Action #1) and relevant management plans, with detailed technical monitoring commitments addressed in the PS3 and PS6 sections and the corresponding ESAP actions.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures. The Sponsor has established a corporate HR framework that includes policies and procedures covering recruitment and hiring, employee development and training, performance management, labor relations, ethics and conduct, diversity and inclusion, OHS, and a grievance mechanism. The framework is generally aligned with the objectives of PS2 and provides a basis for managing labor and working conditions for the Project. For contracted workers, applicable PS2 requirements will be implemented through contractual provisions, contractor and subcontractor management procedures, and Project-level oversight, including requirements related to terms and conditions of employment, non-discrimination and equal opportunity, freedom of association, child and forced labor, worker grievance mechanisms, and OHS.
As per ESAP Action #1, the applicable HR policies and procedures will be integrated into the Project’s specific ESMS, including provisions on child and forced labor and the right of freedom of association, to ensure consistent implementation and monitoring of labor requirements throughout the construction and operational phases. The Company will implement established HR processes and training programs, including the “Academia Pampa” corporate training platform, to support workforce development and competency building for Project personnel in line with corporate policies. Requirements applicable to contractors and subcontractors will be addressed through contractual provisions, contractor-management procedures, and Project-level supervision, while worker grievance requirements will be addressed under ESAP Action #8.
Working Conditions and Terms of Employment. The Project is expected to generate significant employment opportunities during construction and operation, with approximately 3,500 workers expected during the peak of construction and approximately 300 permanent workers during operations. Working conditions for direct and contracted workers will be governed by applicable Argentine labor legislation and corporate employment procedures, and the applicable requirements of PS2. A formal hiring program to promote local employment will be developed and implemented as per ESAP Action #7. Induction programs including clear disclosure of workers’ rights and responsibilities, performance management procedures, and ongoing training programs will be implemented throughout the Project life cycle, as established in the corporate HR framework.
The Company, through the HR corporate framework, has procedures governing labor administration, compensation, benefits, disciplinary processes, and workforce management that will be implemented at the Project level. Contractor management processes include verification of labor and social security compliance and occupational health and safety requirements.
Workers’ Organization. Workers involved in the Project will be entitled to exercise their rights in accordance with applicable Argentine legislation and international conventions, including freedom of association and collective bargaining. Labor unions are active in the Project area, including organizations representing construction workers and other industrial sectors that may be involved during Project construction and operations. The Company will respect workers’ rights to freedom of association and collective bargaining and will not discriminate or retaliate against workers exercising these rights.
Non-discrimination and Equal Opportunity. The corporate human resources procedures applicable to the Project include provisions promoting non-discrimination and equal opportunity in recruitment, hiring, career development and employment practices. The Company applies procedures intended to support objective and transparent candidate selection and evaluation, and to prevent discrimination based on personal characteristics protected under applicable legislation and Company policies. The Company recognizes the risks of GBV, SEAH, and other forms of workplace harassment, and has established programs and provisions under its Code of Conduct to promote respectful workplace practices and gender equality. Training for employees includes ethical leadership and prevention of sexual and other forms of harassment.
Worker’s Grievance Mechanism (“GM”). The Project will utilize established corporate grievance and whistleblower mechanisms applicable to employees, contractors, and subcontractors. These mechanisms provide multiple channels for reporting labor-related concerns, including allegations of misconduct, harassment, discrimination, unethical behavior, and other workplace grievances. The mechanisms include procedures for receiving, investigating, documenting, and resolving complaints while maintaining confidentiality where appropriate. Fertil Pampa will update and operationalize the workers’ grievance mechanism at the Project level to include specific provisions for receiving and managing GBVH-related grievances using a survivor-centered approach, as per ESAP Action #8. The Project-level mechanism will be designed to allow anonymous complaints to be raised and addressed, be accessible and culturally appropriate to all workers, and incorporate measures to support confidentiality, transparency, accountability, and protection against retaliation.
Protecting the Workforce. The Company’s HR and contractor management procedures prohibit child labor, forced labor, bonded labor, and other forms of involuntary labor. Hiring procedures require verification of worker identity and age and are designed to support compliance with applicable labor legislation and relevant International Labor Organization (“ILO”) conventions. The Company’s recruitment controls and contractor due diligence processes include measures to identify and prevent unlawful labor practices among the Project workforce and, where applicable, within the contractor workforce and relevant supply chains. Implementation of these requirements will be monitored through the ESMS, with corrective actions managed as necessary (ESAP Action #1).
Occupational Health and Safety (OHS). The main OHS and process safety risks associated with the Project relate to the handling, processing, storage and transfer of hazardous substances, including potential worker exposure to ammonia and other hazardous materials, as well as fire and explosions. As described under PS1 (ESAP Action #3), the Company will complete a QRA, followed by additional detailed process-safety studies. In addition, prior to commissioning (ESAP Action #9), the Company will develop and implement an OHS and Process Safety Management System integrated into the Project’s ESMS and aligned with applicable national requirements, the WBG General EHS Guidelines, the WBG EHS Guidelines for Nitrogenous Fertilizer Production and GIIP, including, as applicable, the elements of the U.S. Occupational Safety and Health Administration (“OSHA”) Process Safety Management standard (29 CFR 1910.119), the Center for Chemical Process Safety (“CCPS”) Risk Based Process Safety (“RBPS”)framework , the American Petroleum Institute Recommended Practice (“API RP”) 754, and relevant standard issued by the National Fire Protection Association (“NFPA”),. The system will include, at a minimum: (i) process hazard identification, risk assessment, and risk management; (ii) procedures for routine, non-routine, and emergency activities; (iii) management of change; (iv) mechanical integrity and management of safety critical elements; (v) contractor-safety management; (vi) emergency preparedness and response; (vii) occupational health surveillance and exposure monitoring; (viii) competency, training, and authorization requirements; (ix) incident reporting, investigation, and lessons learned; and (x) performance monitoring, auditing, management review, and continual improvement.
During construction, key risks are associated with the size of the workforce, which is expected to peak at approximately 3,500 workers, and the execution of high-risk activities, including work at height, excavation, lifting operations, confined-space entry, electrical work, heavy-equipment operation, transportation, and simultaneous activities involving multiple contractors and subcontractors.
Fertil Pampa will rely on Pampa Energia’s corporate EHS framework and the EHS management systems of the principal EPC contractors, SACDE and Tecnimont. These systems include OHS policies, hazard-identification and risk-assessment processes, permit-to-work systems, training programs, incident notification, reporting and investigation procedures, inspections, audits, EPR arrangements, and contractor-performance monitoring. The Project ESMP also establishes OHS requirements for the construction phase and requires contractors to appoint dedicated EHS personnel and prepare and implement site-specific EHS plans.
Workers Engaged by Third Parties. The Project's workforce during construction will be predominantly composed of workers engaged by third parties, including contractors, subcontractors, and specialized service providers. Contractual agreements require EPC contractors to manage their workforce in accordance with applicable Argentine labor legislation and the Company’s applicable HR and OHS requirements. The Company will oversee contractor performance through the Project’s ESMS and contractor-management arrangements, including monitoring of labor and working conditions against applicable PS2 requirements.
PS3: Resource Efficiency and Pollution Prevention
Resource Use and Efficiency. Main resources to be used in the process include natural gas, seawater and electricity and the Project will benefit from existing infrastructure within the Ingeniero White industrial and port complex. The Project will incorporate process optimization measures, including heat recovery and water reuse to improve resource efficiency and reduce energy consumption per unit of production.
GHG Emissions. The Project will generate 0.436 tons of CO2 eq/year, primarily from natural gas consumption, fuel combustion, and process emissions associated with ammonia production. The selected process configuration includes the recovery and use of carbon dioxide generated during ammonia production as feedstock for urea manufacturing. This will reduce direct CO2 releases relative to standalone ammonia production, although a proportion of the carbon incorporated into urea may ultimately be released during product use.
Water Consumption. Water will be sourced from the Bahia Blanca estuary through the existing water intake infrastructure associated with the adjacent Central Termica Piedra Buena (“CTPB”), rather than through a new Project-specific intake. Water will be used in the ammonia and urea production processes, as well as associated utility systems, including cooling and steam generation. As per the ESIA, Fertil Pampa has obtained a Water Prefeasibility Certificate (Certificado de Prefactibilidad Hidrica) confirming that the required water demand can be met. The Project’s water requirements can be accommodated within the existing authorized abstraction capacity of the CTPB intake, without the need to increase the currently authorized withdrawal volume or develop a new intake structure.
Air Emissions. The principal sources of air emissions during operations will include the ammonia and urea production units, reforming and combustion systems, auxiliary boilers, vents, material-handling systems, and other process equipment. Key pollutants are expected to include nitrogen oxides, particulate matter, carbon monoxide, ammonia, and GHG emissions.
The proposed design incorporates emission-control technologies and operational measures intended to meet applicable Argentine requirements. As part of the ESIA, Fertil Pampa conducted an air-dispersion modeling of the main process units to assess potential impacts on ambient air quality and all modeled pollutant concentrations remained below Argentinian air quality standards. However, the modeling identified that ammonia emissions from the granulation units would exceed the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Under ESAP Action #10, the Company will upgrade the technical design of pollution prevention measures to reduce ammonia emissions and seek alignment with the WBG EHS Guidelines for Nitrogenous Fertilizer Production. The Company will also strengthen and implement the Air Quality Monitoring Program by defining monitoring frequencies for gaseous emissions and ambient air quality and incorporating applicable international standards.
Wastewater. The Project will generate industrial wastewater from process operations, cooling systems, water-treatment units, equipment cleaning, and other ancillary activities, together with sanitary wastewater from worker and operational facilities. The proposed wastewater-management system will include segregation, collection, treatment, monitoring, reuse where feasible, and controlled discharge. Fertil Pampa modeled the discharge of treated effluent into Bahia Blanca RIA, with results indicating that the originally proposed discharge could increase salinity and adversely affect water quality and aquatic communities. To reduce these impacts, the Company has evaluated design improvements, including relocation of the discharge point, incorporation of additional wastewater streams into the treatment system, and reduction of seawater consumption and associated salt loads. However, additional characterization of wastewater streams and assessment of the final discharge configuration are still required to demonstrate that the wastewater-management system and final effluent discharge will me applicable requirements of the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. Therefore, under ESAP Action #11, the Company will: (i) further characterize wastewater streams, finalize the wastewater management system design, and demonstrate compliance with applicable WBG effluent guidelines; (ii) assess potential impacts of brine discharge on the receiving marine/estuarine environment, including water quality, aquatic communities, fisheries resources, ecosystem services, and artisanal and recreational fishers, as applicable, and implement appropriate mitigation measures, as necessary; and (iii) develop and implement a Final Liquid Effluent Discharge Quality Monitoring Program.
Further, as part of the CIA (ESAP Action #2), the Company will also assess the cumulative effects of the Project’s effluent discharge in combination with other existing and reasonably foreseeable discharges and activities affecting the Bahia Blanca estuary and identify additional mitigation or management measures, as necessary.
Waste. Construction activities will generate non-hazardous and hazardous waste, including excavated materials, construction debris, scrap metal, packaging, used oils, contaminated materials, chemical containers, and domestic waste from worker facilities. During operations, waste will arise from process activities, maintenance, water and wastewater treatment, laboratories, offices, and other ancillary facilities. The ESMP includes general procedures for waste identification, segregation, labeling, storage, transport, recycling, treatment, and disposal through authorized service providers. Hazardous and non-hazardous wastes will be managed separately in accordance with applicable national requirements.
Hazardous Materials. In addition to natural gas and ammonia for which a QRA and other process safety studies will be developed as described under PS1 (ESAP Action #3), the main hazardous materials that will be present on-site, include fuels, lubricants, process chemicals, catalysts, and water-treatment chemicals. As part of ESAP Action #4, the Company will develop a Hazardous Materials Management Plan that includes the inventory of hazardous materials and safety data sheets, establishes compatibility and segregation requirements, define secondary-containment and leak-detection measures, operational procedures for transport, handling, spill prevention, emergency response, and disposal in accordance with applicable requirements and GIIP. Requirements will be also applicable to the EPC contractor’s EHS system.
Noise. As part of the ESIA, the Company conducted a noise impact assessment covering construction and operational activities. The assessment concluded that predicted noise levels at the nearest residential and recreational receptors are generally expected to remain below applicable standards and WBG General EHS Guidelines and are not expected to result in significant noise impacts.
PS4: Community Health, Safety and Security
Identification of risks and impacts and mitigation measures. The main community health and safety risks associated with the Project, as identified in the ESIA, include increased traffic and logistics activity, transportation of hazardous materials and potential major accident scenarios associated with ammonia storage and handling. The Project ESMP includes preliminary mitigation measures to manage these risks.
Infrastructure, Hazardous Materials Management and Safety. The facility will incorporate multiple layers of process-safety protection, including fire and gas detection, fire-protection systems, emergency shutdown and isolation systems, hazardous-material containment measures, and pressure-relief systems. As described under PS1 (ESAP Action #3), the Company will complete a preliminary QRA to evaluate risks to off-site receptors and identify any additional prevention, mitigation, land-use planning, and emergency preparedness measures needed to achieve risk levels consistent with GIIP and PS4 requirements.
Emergency Preparedness and Response. As described under PS1 (ESAP Action #6), the Company will develop and implement a Project-specific Emergency Preparedness and Response Plan informed by the findings of the QRA and other process-safety studies. The plan will address credible on-site and off-site emergency scenarios and establish appropriate response, communication, notification, and coordination arrangements with workers, emergency services, competent authorities, neighboring facilities, port operators, and potentially affected communities.
Traffic Impacts and Transportation Safety. Construction and operation of the Project will increase road and port-related traffic associated with the movement of personnel, construction materials, equipment and final products. The CIA identifies construction-related traffic and logistics demand as one of the principal cumulative pressures within the Project’s area of influence. The Project benefits from its location within an established industrial and port complex with existing logistics infrastructure and access to regional transportation networks and the Company has developed a Traffic Management Program to manage safety risks from materials, equipment and personnel transportation. The Project has the potential to increase traffic due to the increased workforce during construction and interactions with the surrounding communities. The Company will prepare a Community Health and Safety Plan (ESAP #12) to establish prevention and mitigation measures for those risks.
Ecosystem Services. The Project is located within the Bahia Blanca estuary, an environmentally sensitive area that supports ecological functions, fisheries, navigation, industrial activities, and other ecosystem services used by local communities. Potential impacts on ecosystem services are primarily associated with seawater abstraction, wastewater discharge, dredging and port activities where relevant, accidental releases, and cumulative pressures on estuarine habitats and biological communities.
Under the consolidated ESMP, the Company will further assess Project dependencies and impacts on priority ecosystem services (Please refer to the PS6 section), including services relevant to artisanal and recreational fishing, navigation, water quality, and other users of the estuarine environment. The Company will establish appropriate monitoring indicators, stakeholder engagement arrangements, management thresholds, and adaptive management measures to identify and respond to material changes throughout construction and operation.
Security Personnel. The Project is located within the industrial area of the port of Bahia Blanca and will rely on a combination of authorized private security contractors providing unarmed guards operating under the corporate security procedures, and coordination with public authorities responsible for maintaining security within the port complex. Security requirements during construction will primarily focus on controlling access to the Project site, protecting personnel and assets, managing interactions with contractors and visitors, and ensuring the safe movement of equipment and materials. During operations, security management will consider the presence of critical industrial infrastructure and significant quantities of ammonia, natural gas, and other hazardous materials. The Company's "Security Personnel and Community Relations Management Procedure” incorporates provisions for contracting and managing private security companies, including vetting personnel and ensuring adequate training on human rights, use of force and deescalation of conflicts.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project is located on coastal land historically reclaimed with dredged material and subsequently colonized by a mix of exotic and native vegetation within an industrial port zone and boundaries of the Bahia Blanca, Bahia Falsa y Bahia Verde estuary recognized as a Key Biodiversity Area (“KBA”) and Important Bird Area (“IBA”). The area of indirect influence overlaps two provincial legally protected areas: the Reserva Natural Provincial Bahia Blanca, Bahia Falsa y Bahia Verde, a large multiple-use reserve encompassing islands, channels, and coastal marshes; and the Reserva Natural Provincial Islote de la Gaviota Cangrejera, located approximately 1–2 km from the Project footprint and established specifically to protect the Olrog's Gull (Larus atlanticus) and associated shorebird communities. The estuary also forms part of the Western Hemisphere Shorebird Reserve Network, underscoring its hemispheric significance for migratory shorebird species, and has been proposed as a potential Ramsar Wetland Site.
Biodiversity values of conservation priority potentially within the project’s area of influence include Narrownose Smooth-hound (Mustelus schmitti, globally CR), Angular Angelshark (Squatina guggenheim, globally EN), Franciscana Dolphin (Pontoporia blainvillei, globally VU), Olrog’s Gull (globally NT, nationally VU), and Red Knot (Calidris canutus rufa, globally NT and nationally EN). No species of conservation concern are likely to occur or have been detected in the Project footprint. Howeverin order to fill baseline survey gaps identified during ESDD review, per ESAP Action #13, Fertil Pampa will conduct additional targeted surveys within the project’s area of direct influence as well as Natural Habitat at the discharge point, to document presence of biodiversity values and manage accordingly.
Given the Project’s location on modified terrestrial habitat and the implementation of management measures to manage potential estuary-related impacts, the Project is not expected to jeopardize priority biodiversity values or result in significant long-term impacts to Critical Habitat (CH) or the ecological processes that support those values, as long as the risk of chemical spills is adequately managed. However, to identify target biodiversity management goals aligned with PS6 requirements, Fertil Pampa will complete the Critical Habitat Assessment (CHA) and formally adopt findings of risk assessment results and proposed mitigation, as per ESAP Action #14. Compliance with IFC PS6 also requires Fertil Pampa to prepare a Biodiversity Action Plan (“BAP”), supported by a Biodiversity Monitoring and Evaluation Plan (“BMEP”), to outline, implement and track mitigation actions towards Net Gain objectives in CH, under ESAP Action #15. The BAP needs to apply the mitigation hierarchy, quantify any residual loss, and establish a credible pathway to Net Gain for each Critical Habitat-qualifying biodiversity value. The BAP/BMEP should also address broader operational biodiversity risks, including chemical spill prevention and response measures (see PS3), controls to prevent invasive aquatic species from being introduced through vessel ballast water, water quality/salinity monitoring, and potential construction phase impacts including light pollution and underwater sound impacts. The Project’s BAP and BMEP will be embedded in the company’s ESMS, to include measures specific to protect biodiversity and ecosystem services, cross referenced to applicable construction and operational management. Adaptive management will feed back into the NG strategy outlined in the BAP for CH and the ecological processes that support it.
In addition, given the project’s location in a KBA, in agreement with relevant sponsors, Fertil Pampa will identify and implement additional conservation actions consistent with Paragraph 20 of PS6 to support the conservation aims of the Bahia Blanca, Bahia Falsa, Bahia Verde KBA/IBA as per ESAP Action #16.
Stakeholder Engagement
The Company has a corporate procedure for the identification, characterization, prioritization, monitoring, and periodic review of stakeholders. Through the ESIA process, national, provincial, and local levels institutions were informed about the Project description and potential impacts. Community organizations, local health providers, educational institutions and local government officials were consulted through interviews and social-perception surveys.
As part of ESAP Action #17 Fertil Pampa will strengthen its stakeholder engagement process through the development of a Project-specific Stakeholder Engagement Plan (“SEP”) based on a thorough stakeholder identification and analysis process. Stakeholders in the area of influence such as vocational training institutions, universities, trade unions, sector organizations, business chambers, labor cooperatives, artisanal and recreational fishing interests, and community-based organizations will be mapped based on their interest and level of influence on the Project. The analysis will differentiate between affected and interested groups and will systematically consider vulnerability, livelihoods, exposure to Project risks, risk perception, and potential conflict. The SEP will describe the engagement strategy for each stakeholder with special considerations for vulnerable groups and will define the information disclosure and consultation processes, as well as how documentation and tracking of stakeholder inputs will be managed, methods for providing feedback and reporting to affected communities, schedules, and monitoring indicators.
Community Grievance Mechanism. At the corporate level, the Sponsor has in place a mechanism to receive and address community grievances as part of its environmental and social management approach. Based on the corporate policies and procedures, Fertil Pampa will implement at the Project level a Community Grievance Mechanism ("CGM") fully aligned with PS1 (ESAP Action #18). The CGM will: (i) provide multiple accessible channels for communities and vulnerable groups; (ii) establish procedures for receipt, registration, assessment, investigation, response, escalation, and closure of grievances; (iii) define response and resolution timeframes; (iv) maintain a register and performance indicators; (v) include procedures for confidentiality and anonymous complaints and protection against retaliation; (vi) establish periodic monitoring and reporting to identify trends and implement corrective actions to minimize recurrence; and (vii) provide feedback to affected stakeholders and communities in a culturally appropriate manner. The CGM will be widely disclosed through the implementation of the SEP (ESAP Action # 17).
As part of ESAP Action #17 Fertil Pampa will strengthen its stakeholder engagement process through the development of a Project-specific Stakeholder Engagement Plan (“SEP”) based on a thorough stakeholder identification and analysis process. Stakeholders in the area of influence such as vocational training institutions, universities, trade unions, sector organizations, business chambers, labor cooperatives, artisanal and recreational fishing interests, and community-based organizations will be mapped based on their interest and level of influence on the Project. The analysis will differentiate between affected and interested groups and will systematically consider vulnerability, livelihoods, exposure to Project risks, risk perception, and potential conflict. The SEP will describe the engagement strategy for each stakeholder with special considerations for vulnerable groups and will define the information disclosure and consultation processes, as well as how documentation and tracking of stakeholder inputs will be managed, methods for providing feedback and reporting to affected communities, schedules, and monitoring indicators.
Community Grievance Mechanism. At the corporate level, the Sponsor has in place a mechanism to receive and address community grievances as part of its environmental and social management approach. Based on the corporate policies and procedures, Fertil Pampa will implement at the Project level a Community Grievance Mechanism ("CGM") fully aligned with PS1 (ESAP Action #18). The CGM will: (i) provide multiple accessible channels for communities and vulnerable groups; (ii) establish procedures for receipt, registration, assessment, investigation, response, escalation, and closure of grievances; (iii) define response and resolution timeframes; (iv) maintain a register and performance indicators; (v) include procedures for confidentiality and anonymous complaints and protection against retaliation; (vi) establish periodic monitoring and reporting to identify trends and implement corrective actions to minimize recurrence; and (vii) provide feedback to affected stakeholders and communities in a culturally appropriate manner. The CGM will be widely disclosed through the implementation of the SEP (ESAP Action # 17).
Investor Relations - Pampa Energia S.A.
Telephone Number: +54 (11) 4344-6000
Email: investor@pampa.com
Mailing Address: Maipu 1 (C1084ABA), Ciudad de Buenos Aires, Argentina
Website: www.pampa.com
Telephone Number: +54 (11) 4344-6000
Email: investor@pampa.com
Mailing Address: Maipu 1 (C1084ABA), Ciudad de Buenos Aires, Argentina
Website: www.pampa.com
Broad Community Support
Broad Community Support is not applicable for this project.
Environmental & Social Action Plan
| S.no | Description | Anticipated Completion Date |
|---|---|---|
| 1 | The Company will develop, implement, and maintain a Project ESMS consistent with IFC PS1 and commensurate with the Project’s risks and impacts. At a minimum, the ESMS will: (i) strengthen processes to identify and manage key E&S risks, including contractor and labor management, OHS and process safety, community health and safety, biodiversity, resource efficiency, climate risks, emergency preparedness, social conflict and GBV/SEAH; (ii) implement the required management plans and procedures; (iii) define adequate roles, staffing, competencies, resources, and reporting lines, including contractor oversight; and (iv) establish procedures for OHS, environmental and social monitoring, reporting, incident management, corrective actions, management review, and continuous improvement. | 07/31/2029 |
| 2 | The Company will: (i) Update the Cumulative Impact Assessment (CIA) to strengthen VEC/VSC selection, incorporate relevant receptors, and integrate related E&S studies and management programs; and (ii) Develop a comprehensive assessment of physical and transition climate risks, including climate scenarios, time horizons aligned with the project life, material risks, and adaptation/resilience measures. | 12/31/2026 |
| 3 | The Company will: (i) Undertake a comprehensive Quantitative Risk Assessment (QRA)to estimate potential impact ranges under credible worst-case scenarios associated with the storage and handling of ammonia and other hazardous materials, including loading operations; (ii) complete relevant process safety studies consistent with GIIP, including Hazard and Operability (HAZOP), Layers of Protection Analysis (LOPA), Safety Integrity Level (SIL), identification of Safety Critical Elements (SCEs) and associated Performance Standards, Hazardous Area Classification, Occupied Buildings Risk Assessment (OBRA), and Escape and Evacuation Risk Assessment (EERA); and (iii) incorporate the findings and recommendations of these studies into the final facility design, including the final layout, the design of fire and explosion prevention, detection, protection, and mitigation systems, operating procedures, emergency preparedness and response measures, process safety management systems, and other measures required to further reduce risks to workers and surrounding communities in accordance with IFC PSs and GIIP. | 07/31/2029 |
| 4 | The Company will develop and implement phase-specific Environmental and Social Management Plans (ESMPs) under a common Project ESMS framework:(i) Prior to the commencement of construction, develop and implement a consolidated Construction ESMP that integrates the EPC contractor and subcontractor EHS plans and: (a) links management measures to the identified E&S risks and impacts and applies the mitigation hierarchy; (b) establishes uniform Project-level requirements, roles and responsibilities; (c) defines measurable performance indicators, monitoring requirements, and reporting arrangements; (d) establishes supervision and assurance mechanisms and corrective-action processes; and (e) provides for periodic review and adaptive management based on monitoring results and Project performance.(ii) Prior to commissioning, develop and implement an Operational ESMP reflecting the final Project design, applicable process-safety and environmental studies, and operational E&S risks and impacts. The Operational ESMP will incorporate applicable WBG EHS performance criteria and management measures; apply the mitigation hierarchy; define measurable performance indicators, monitoring requirements, responsibilities, and reporting arrangements; establish corrective-action and adaptive-management processes based on monitoring results; and incorporate applicable emergency preparedness and response arrangements. | 05/02/2029 |
| 5 | The Company will, as part of the Project’s E&S organizational structure, establish and maintain adequate organizational capacity by defining a team with sufficient resources, qualifications, and skill sets to oversee E&S performance during construction and operation, including, at a minimum: (i) an environmental officer; (ii) a social officer; and (iii) an occupational health and safety officer. | 12/31/2026 |
| 6 | The Company will adapt and implement a Project-specific Emergency Preparedness and Response Plan (EPRP) for the Project facilities and operations. The EPRP will build upon and establish interfaces with the existing emergency preparedness and response arrangements of the Ingeniero White industrial and port complex, including the APELL-based arrangements for surrounding communities. The EPRP will address credible emergency scenarios identified through the applicable process-safety studies and QRA, including major accident scenarios involving ammonia and other hazardous materials. It will define on-site and off-site response measures, roles and responsibilities, notification and coordination procedures with competent authorities, emergency services, port stakeholders, and other relevant parties, required resources, and arrangements for training, drills, review, and periodic updating. The EPRP will be aligned with the Sponsor’s corporate framework, applicable legal requirements, and GIIP, and will be finalized and operational prior to commencement of operations. | 07/31/2029 |
| 7 | The Company will develop and implement a formal local employment program establishing objectives, eligibility and selection criteria, outreach and recruitment measures, and monitoring indicators to promote transparent and equitable access to Project employment opportunities for local communities. | 12/31/2026 |
| 8 | The Company will update the workers’ grievance mechanism at the Project level to include specific provisions to report and manage GBVH related grievances with a survivor centered approach. The Company will ensure that the mechanism allows for anonymous complaints to be raised and addressed, is accessible and culturally appropriate to all workers, with a diversity of channels to raise grievances, and assuring transparency and accountability without retribution | 12/31/2026 |
| 9 | For construction and operations, the Company will develop and implement an OHS and Process Safety Management System integrated into the Project’s ESMS and aligned with applicable national requirements, the WBG General EHS Guidelines, and the WBG EHS Guidelines for Nitrogenous Fertilizer Production, and recognized international process safety standards and good practice, including OSHA 29 CFR 1910.119, CCPS Risk Based Process Safety elements, API RP 754, and other applicable NFPA, API, IEC/ISA and ISO standards.The system will address, at a minimum: (i) process safety information; (ii) process hazard identification, risk assessment and risk management; (iii) operating procedures for routine, non-routine, start-up, shutdown and emergency activities; (iv) management of change; (v) pre-start-up safety review and operational readiness; (vi) mechanical integrity, asset integrity and management of Safety Critical Elements; (vii) contractor safety management; (viii) competency, training and authorization requirements; (ix) emergency preparedness and response; (x) occupational health surveillance and exposure monitoring; (xi) incident reporting, investigation and lessons learned; (xii) process safety performance indicators; and (xiii) auditing, management review and continual improvement. | 07/31/2029 |
| 10 | The Company will: (i) upgrade the technical design of pollution prevention measures to reduce ammonia emissions and seek alignment with WBG EHS Guidelines for Nitrogenous Fertilizer Production; and (ii) strengthen and implement the Air Quality Monitoring Program by: (a) defining the monitoring frequency for gaseous emissions and air quality; and (b) including international standards. | 07/31/2029 |
| 11 | The Company will: (i) further characterize the different wastewater streams and review the design of the wastewater-management system to assess and, as necessary, optimize treatment and discharge arrangements to achieve alignment with the effluent parameter values established in the WBG General EHS Guidelines and the WBG EHS Guidelines for Nitrogenous Fertilizer Production. The Company will also assess the potential impacts of the brine discharge on the receiving marine/estuarine environment, including potential effects on water quality, aquatic communities, fisheries resources, ecosystem services, and artisanal and recreational fishers, as applicable, and, as necessary, implement appropriate design, operational, and mitigation measures to avoid or minimize such impacts; and (ii) Develop and implement a Final Liquid Effluent Discharge Quality Monitoring Program. | 07/31/2029 |
| 12 | The Company will develop and implement a Community Health and Safety Management Plan including prevention of transitable diseases and risks associated to road safety incorporating provisions through the enforcement of the worker codes of conduct, workforce induction and training, workers health programs, management of workers accommodation where applicable, access to health services, awareness and prevention activities, the traffic management program, and stakeholder engagement. | 01/31/2027 |
| 13 | The Company will conduct additional targeted surveys within the project’s area of direct influence to document the presence of biodiversity values. | 07/31/2027 |
| 14 | The Company must complete the CHA, and formally adopt findings of risk assessment results and proposed mitigation. | 01/31/2027 |
| 15 | The Company will retain a qualified, independent contractor to prepare a Biodiversity Action Plan (BAP), accompanied by a Biodiversity Monitoring and Evaluation Plan (BMEP). Together, these plans will define and guide the implementation of mitigation and monitoring programs designed to document Net Gain for Critical Habitat and, more broadly, to track the effectiveness of measures to manage key ecological risks associated with Project construction and operations. | 12/31/2027 |
| 16 | Given the project’s location in a KBA, in agreement with relevant sponsors, the Company will identify and implement additional conservation actions consistent with Paragraph 20 of PS6 to support the conservation aims of the Bahia Blanca, Bahia Falsa, Bahia Verde KBA/IBA. The Company will include these measures in the BAP. | 07/31/2027 |
| 17 | The Company will develop and implement a Stakeholder Engagement Plan (SEP) covering stakeholder mapping and segmentation, identification of vulnerable groups, phase-specific engagement strategies, disclosure and meaningful consultation methods, documentation and tracking of stakeholder inputs, feedback and reporting to affected communities, implementation responsibilities, schedules, and monitoring indicators. | 01/31/2027 |
| 18 | The Company will develop and implement a Community Grievance Mechanism that will: (i) provide multiple accessible channels for communities and vulnerable groups; (ii) establish procedures for receipt, registration, assessment, investigation, response, escalation, and closure of grievances; (iii) define response and resolution timeframes; (iv) maintain a register and performance indicators; (v) include procedures for confidentiality and anonymous complaints and protection against retaliation; (vi) establish periodic monitoring and reporting to identify trends and implement corrective actions to minimize recurrence; and (vii) provide feedback to affected stakeholders and communities in a culturally appropriate manner. | 12/31/2026 |
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.