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

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). The Project is expected to have limited adverse E&S risks and impacts that can be addressed through adequate mitigation measures and good international industry practices (GIIP). Key risks identified for this project include: (i) E&S management and capacity (ii) labor and working conditions, particularly management of independent service providers and contractors, (iii) gender-based violence and harassment (GBVH), (iv) food safety, and (v) transport and road safety of delivery workers; and, (vi) recruitment and management of young workers (15-17 year olds) as permitted by the Egyptian labor code under specific terms and conditions.

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 Assessment and Management System
Breadfast has recently developed an Environmental and Social Risk Management system (ESMS), which includes its EHS Policy, OHS procedures (e.g. manual handling Policy, safe work, incident investigation), Operations Central Warehouses Standard Operating Procedures (SOPs), Quality & Food Safety Policy, waste management, community health and safety, road safety, and complaints management. The Company’s production facilities are certified ISO 22000/2018 for food safety management, and ISO 9001/2015 for quality management. All production facilities have completed limited E&S assessments required as per local regulation and have received the environmental permits required by the local authorities.

However, key risks including food safety, occupational health and safety (OHS), road safety, contractor and supplier management, and gender-based violence and harassment (GBVH) were not addressed in these assessments. While Breadfast has initiated a risk management framework as part of its ESMS, the current EHS risk register remains limited to OHS risks. For this investment, Breadfast will update its ESMS (ESAP#1) to (i) strengthen its risk assessment framework to integrate all risks associated with its operations, ii) expand its management programs to address all identified risks, defining clear objectives, responsibilities, actionable steps, measurable performance indicators, and necessary resources, and iii) develop a roll-out plan for the different ESMS components to allow its full implementation within a reasonable timeframe. The ESMS will cover all operations regardless of their location, including offices, production facilities, warehouses, fulfilment points, supply chain activities, and contractors. The risk assessments will be applied to all new services provided by Breadfast and all geographies before launching. Topics to be covered in the ESMS will include GBVH, contractor and supplier management, Occupational Health and Safety (OHS), food safety, resource efficiency, solid waste management, road safety, external communication and customer grievance management, emergency planning and response, auditing and monitoring of E&S performance indicators, and reporting to the Company’s senior management and Board of Directors in line with IFC PS1.

E&S organizational structure
Breadfast has established dedicated QHSE (Quality, Health, Safety, and Environment) teams responsible for managing all aspects of quality assurance, occupational health and safety, and environmental risk management. The function is headed by a QHSE Director, who reports to the company’s senior management and board. One or more EHS specialists are assigned to each warehouse, production site and coffee shops, with EHS leads overseeing operational units (warehouses, production, and coffee). The EHS leads report to senior EHS Manager, who in turn reports to the QHSE director.

E&S Training
Breadfast has developed an EHS training plan focusing on OHS aspects, including road safety, in addition to environmental management including waste management. New hires receive induction training covering the code of conduct, anti-harassment and discrimination commitments, grievance channels, basic OHS guidance including for delivery associates, and role-specific instructions. Breadfast will extend the trainings to all employees including third party workers employed by labor agencies, contracted ones, and independent contracted services (delivery associates and pickers) (ESAP#2). Trainings will cover OHS, road safety, HR policies, code of conduct, food safety, emergency preparedness, and environmental management. They will be function-specific, documented, regularly updated, and tracked.

E&S Monitoring & Review
Breadfast currently monitors certain E&S aspects such as quality, food safety and inventory waste, and significant OHS incidents. As part of its ESMS update (ESAP#1), Breadfast will develop an E&S monitoring and reporting manual which will specify Key Performance Indicators (KPIs) and associated benchmarks, including occupational health and safety (OHS) leading and lagging indicators (incident records, near miss, hazard reporting and other workplace monitoring data), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and supplier and contractor E&S performance. The procedures will also cover audits, as well as reporting on E&S to senior management and the Board.

Emergency Preparedness and Response
Breadfast has developed a Business Continuity and Disaster Recovery Plan to address potential operational disruptions, and policies specifically addressing data security. The Company maintains an Emergency Response Plan (EPRP) for its warehouses, factories, and hot kitchens, which includes documented drills and training, emergency response scenarios covering different hazards, incident reporting and investigation forms, and communication and coordination with local emergency services. However, site-specific emergency preparedness and response plans remain to be developed. Breadfast will update, finalize and implement site-specific emergency preparedness and response plans for warehouses, production facilities, fulfillment points, kitchens, and offices (ESAP#3). Each plan will cover evacuation routes, emergency teams, fire equipment inventory and maintenance, fire hazard management, communication tools, emergency contacts, drill schedules, and coordination with local authorities.

Supply Chain
Breadfast’s supply chain primarily involves procurement of Fast-Moving Consumer Goods (FMCGs) and food products, which are mostly locally sourced within Egypt (except for coffee). Supplier selection is based on product quality, production facility adequacy and licensing. No E&S criteria (OHS, child labor, biodiversity impacts) are currently included in the supplier selection process. Breadfast’s sole coffee supplier directly sources coffee beans from smallholder farms and cooperatives across Latin America, Africa, and Asia, where coffee production is associated with potential child and forced labor and biodiversity impacts. Breadfast also sources its fresh produce (fruits and vegetables) from local wholesalers and traders, where potential supply chain risks include child labor and significant occupational health and safety risks.
As part of this investment, Breadfast will map and assess risks for child and forced labor, significant OHS, and biodiversity (habitat conversion, deforestation, overlap with sites of high biodiversity value) for its primary suppliers for coffee and fresh produce. Based on the risk assessment outcomes, the Company will develop a Supply Chain Risk Management System which includes a Sustainable Sourcing Policy, a Supplier Code of Conduct, a Supplier Risk and Onboarding Procedure describing the due diligence for screening, categorization, and approval of suppliers, contractual clauses to adhere to the Code of Conduct for coffee suppliers and local wholesalers and traders for fresh produce, monitoring and audit requirements, non-compliance tracking and a management approach to address recurrent non-compliance incidents and trends (ESAP#4).

PS2: Labor and Working Conditions
Due to the nature of its operations, Breadfast employs four categories of labor. The first category is direct employees hired on fixed term contracts, around 20% of which are female. The second category is workers hired via employment agencies for various functions across their offices, production facilities, warehouses, logistics and coffee shops. The third category is workers hired through contractors/vendors for specialized services (e.g. logistics, cleaning), and some high turnover functions (mostly for delivery, and production facilities). The fourth category is the independent service providers, which includes delivery associates (DAs) and pickers (workers who prepare the orders in fulfillment points (FPs)). The Company is expecting significant growth in its workforce from a total of 8,430 (directly hired employees, outsourced employees, and independent service providers) to approximately 16,000 as it expands in the next 5 years. Given the risks associated with the Company’s large and rapidly expanding workforce and its significant reliance on service agreements for pickers and delivery associates, the Company will conduct a comprehensive labor assessment to review all employment practices and working conditions, with a particular focus on pickers and delivery associates, and workers employed through labor agencies, and contracted workers (ESAP#5). This assessment will assess and identify potential gaps regarding employment terms and conditions including employment terms, OHS, management of third-party employees, in line with Egypt’s labor law and IFC PS2 to be addressed by the Company.

Human Resource Policy, Working Conditions and Terms of Employment
Breadfast has documented HR policies and procedures largely aligned with national labor regulations and IFC PS 2 requirements. The Company hires direct employees through written contracts that outline employment terms, working hours, and overtime. HR policies, procedures, and manuals address topics such as employment conditions, leave, social insurance, recruitment, promotions, employee health and safety, code of conduct, anti-harassment, and employee investigations. Core policies such as the Code of Conduct, Leaves Policy, Anti-Harassment Policy, and Grievance Procedure apply to all employees. Other policies, including Hybrid Work Conditions, Internal Transfers, and Promotions, are limited to office-based staff, while bonus policies differ by function. Going forward, the Company will review its HR policies to i) update where needed to align with the changes in the new Egyptian Labor Law, and ii) explicitly reference its respect to the provisions of the Egyptian laws related to employee freedom of association and collective bargaining in line with the requirements of the IFC PS2 (ESAP#6).
Non-discrimination and Equal Opportunity

Breadfast’s HR policies include explicit statements on non-discrimination, equal opportunity and fair treatment during recruitment and selection, and promotions.

Employees’ Grievance Mechanism:
Employees including delivery associates, and pickers have several channels to raise grievances, including the “Speak Up” platform, which also provides for anonymous reporting, direct access provided by an open-door policy, consultation with HR staff, discussions with line managers, and a confidential email channel. The recently updated grievance mechanism broadly aligns with the requirements of the IFC PS2, and outlines procedures for complaints submission, timelines for responses, routes for escalation, and commitments to non-retribution. The procedure is communicated to all direct employees and is supported by a grievance recording mechanism. All Breadfast workforce, including service providers, can submit complaints or reports on Company policies’ breaches (whistleblowing) through the “Speak Up” platform, with the option to submit complaints anonymously. GBVH complaints’ procedures are detailed separately in the Company’s Anti-Harassment policy. As part of its HR policy review and update (ESAP#6), the Company will communicate the recently updated grievance mechanism to the entire workforce in Arabic.

Gender Based Violence and Harassment
Breadfast’s Workplace Anti-Harassment Policy applies to all employees, contractors, independent service providers (delivery associates and pickers), suppliers, customers, and visitors (e.g. in the coffee shops). The policy adopts a zero-tolerance approach to harassment, including sexual harassment, discrimination, and inappropriate workplace conduct, both within and outside Company premises. It outlines clear definitions, reporting channels, complaint investigation procedures, and potential disciplinary actions up to and including termination. Anti-harassment, anti-discrimination commitments and awareness and information on the whistleblowing channel are embedded in the Company’s Code of Conduct and included in onboarding and training for all employees regardless of employment contract type.
Going forward, Breadfast will strengthen its approach towards GBVH by conducting a GBVH risk assessment focusing on two key areas: (i) internally, across its entire workforce, including direct employees, labor hired by labor agencies, service contracted labor and independent service contract labor such as DAs and pickers); and, (ii) across all the customer facing aspects of its business to identify potential risks both to its workforce, in particular young workers, DAs and chefs, as well as to customers. Based on the outcomes of the risk assessment. The Company will formulate a GBVH action plan that entails prevention, mitigation and response strategies guided by safety, confidentiality, and non-discrimination (ESAP#7).

Child labor and young workers (15-17 years old)
Egyptian laws stipulate strict terms and conditions applied to young workers, including strict record keeping, bans on hazardous jobs and night shifts, restricted working hours, and mandatory breaks which is aligned with IFC PS2. While some 16-17 years old workers have been identified among the Company’s workforce, Breadfast does not currently have a policy on child labor or specific procedures to manage young workers. The Company will identify precisely all the workers under 18 years old currently involved in their operations, conduct a thorough assessment of their employment risks, and establish and implement a detailed child labor policy (ESAP# 8). The policy should cover, at minimum, the prohibition of hiring children below the legal minimum age of 15 as per the Egyptian labor law, restrictions on hazardous work for workers under the age of 18, clear age verification procedures, supplier compliance requirements, safe working conditions for young workers, monitoring, remediation, and training measures across all operations including for outsourced and third-party employees. The policy will be supported by labor management procedures to monitor and record young workers working conditions (e.g. hazardous work, working hours, breaks).

Management of delivery associates and pickers
In addition to its direct employees, independent service providers—specifically delivery associates and pickers—constitute almost half of the Company’s workforce. Both categories are engaged under Service Level Agreements (SLAs) that define the scope of services, performance standards, and payment terms. These agreements set out service fees, payment terms, service hours, exclusivity (non-compete clauses), associate conduct, and termination conditions. Although these individuals are not classified as employees, delivery associates and pickers are expected to work 54 hours per week. They receive compensation through the Company’s payroll system based on hours worked. They’re also paid additional performance-based incentives and are provided with medical insurance. This arrangement creates a hybrid structure where, despite their contractual independence, their working conditions resemble those of employees in terms of hours, supervision, and remuneration. Delivery associates’ minimum earnings for a typical work month including fixed and variable payments exceed the minimum monthly wage in Egypt. Delivery associates provide their own vehicles and are responsible for the validity of their licenses and their maintenance, however they get a variable allowance to help cover petrol costs.
Given the resemblance of their working conditions to those of employees and the evolving legislation around new forms of employment in Egypt, the Company will conduct a legal review of its service level agreements, The review will confirm their compliance with applicable laws, the provisions of the new Labor Law, and any associated Ministerial Orders that clarify the functioning of these new forms of employment relationship (ESAP#9).

Workers engaged by third-parties
Breadfast engages employees through labor agencies for various functions across its offices, production facilities, warehouses, logistics and coffee shops, as well as third-party workers via contractors/vendors, for specialized services (e.g. logistics, lifting activities, cleaning, chefs). The Company does not currently exercise adequate oversight into third party workers’ contracts, compensation or working conditions. Going forward, Breadfast will develop a contractor management policy and procedures (ESAP#10) that defines Breadfast’s labor compliance expectations and outline processes for contractor selection, ongoing compliance monitoring, and audits. This will include requirements for statutory wages, social security benefits, leave provisions, prohibition of child and forced labor, alignment of working hours and overtime with laws, adherence to OHS guidelines, and regular contractor audits.

Occupational Health and Safety
The Company has an E&S policy that reflects its commitment to providing a safe work environment that prioritizes the health, safety, and welfare of its employees, contractors, visitors, and members of the public who may be impacted by its operations. Road accidents have been identified as a key contextual safety risk for the Company. Breadfast has established a Fleet Management Procedure along with Delivery Operations Protocols, a Journey Management Plan, and Pre-Use EHS Inspection Checklists for both vehicles and motorbikes, and incident tracking and investigation procedures. To further mitigate these risks, Breadfast will strengthen its Road Safety Management System (ESAP#11) to (i) establish operational procedures for plan implementation; (ii) set safe driving standards, including helmet use, prohibition of substance use, vehicle maintenance, and roadworthiness; (iii) track courier app time to reduce fatigue risks; (iv) strengthen journey management by mapping high-risk roads, integrating safer routes, and providing guidance on hazard awareness and speed control; and (v) update road safety training for delivery associates on new protocols and expectations.

PS3: Resource Efficiency and Pollution Prevention
Energy Consumption and GHG Emissions
Production facilities and warehouses primarily use grid electricity, while fuel is consumed by logistics and delivery vehicles. Although GHG emissions have not been tracked or quantified to date, the Company is developing a formal GHG accounting framework as part of its newly developed ESMS to monitor and report these emissions. The Company is also piloting initiatives such as optimizing vehicle routes, improving load utilization, and electric vehicle trials for deliveries for last- and mid-mile logistics.

Water and Wastewater Management
The production facilities rely exclusively on municipal water supply, with no groundwater abstraction or surface water intake. Water consumption is not yet monitored but will be tracked under newly implemented processes under the ESMS (ESAP#1). Operations generate mainly sanitary and kitchen effluent wastewater, discharged to the municipal sewer network, with no industrial or process effluents.

Pollution Prevention
The Company does not generate significant air emissions except from vehicle operations and occasional backup generators. Noise emissions are minimal and limited to logistics operations.

Solid Waste Management
Waste streams primarily consist of food waste, bakery products, fruits, vegetables, dairy, poultry, and minimal Fast Moving Consumer Goods product waste (e.g., detergents, cleaners), as well as packaging waste. Waste reduction is a key operational priority, with food waste being tracked and reduced through AI-driven forecasting, distribution optimization, inventory repositioning, and contractual supplier returns. Packaging waste is minimized via waste optimization models. A waste-offsetting program is being explored with support from external partners. The Company’s Waste Management Plan and procedures will be improved to cover waste stream identification, a waste register, storage, hazardous waste handling, and procedures for transport and final disposal for each facility (ESAP#12).

PS4: Community Health, Safety and Security
Breadfast’s production facilities are all located in industrial areas, whereas the fulfillment points and kitchens are located mainly in residential areas. The Company’s operations entail risks to Community Health, Safety and Security, including road safety risks associated with delivery operations; GBVH risks related to customers and neighboring community interactions; food safety risks; and fire safety and emergency preparedness.
Community GBVH risks
Breadfast’s delivery associates and chefs come in close contact with customers and operate daily in neighborhoods, and public spaces, and delivery routes may intersect with sensitive locations such as schools, hospitals, and other public facilities. Delivery associates and chefs are trained on the Code of Conduct, Ati-harassment policy commitments during their onboarding. To further mitigate the risks of GBVH in relation to its customers and the general public, Breadfast will improve its public grievance channels to allow for customers and other members of the public to submit complaints (e.g., in-app, hotline), with a structured process for investigation and resolution, and communicate behavioral expectations from its employees and reporting options to customers across relevant platforms (e.g., app, website, receipts) (ESAP#13).

Road Safety
Road safety risks and mitigants are discussed under the PS2 section.

Food Safety
Breadfast has obtained ISO 22000:2018 and ISO 9001:2015 certifications for its production facilities. Good practices followed include the processing of meat products and raw vegetables in separate rooms, staff generally follow guidelines for protective gear, and finished products are tested for metal contamination. Areas for improvement include the coffee brewing process, housekeeping and suitability of facility floors for food conditions in the production area need improvement.
Breadfast will improve its system to be a comprehensive Food Safety and Quality Management System aligned with internationally recognized food safety standards, including the principles of Hazard Analysis and Critical Control Points (HACCP) and relevant Codex Alimentarius guidelines (ESAP#14). The management system will address key areas such as cold chain maintenance, sanitation, good manufacturing practices, pest and chemical control, allergen management, staff hygiene and training, customer complaint mechanisms, and product traceability.

Breadfast currently has a customer complaints channel on its application, through which any customer complaints related to the orders quality, speed or delivery associates’ behavior can be submitted. There is a formal and robust procedure on handling customer complaints related to orders quality, but there is no clear procedure for handling complaints related to delivery associates’ behavior or other complaints from customers or the general public not related to orders but associated to the code of conduct. Breadfast will strengthen its community and customer grievance channels as detailed in ESAP#14 to allow customers and other members of the public to submit complaints (e.g., in-app, hotline), with a structured process for investigation and resolution, and communicate behavioral expectations from its employees and reporting options to customers across relevant platforms (e.g., app, website, receipts).

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Strengthen its Company-wide Environmental and Social Management System (ESMS) to align it to the requirements of the IFC PS1 to include the following key aspects and not limited to:• Strengthen the risk assessment framework to integrate all relevant risks including road safety, worker and community GBVH, and environmental risks, labor, contractor management, supply chain risks, food safety, external grievances• Develop management programs to address all identified risks in its operations through the risk assessment framework, defining clear objectives, responsibilities, actionable steps, measurable performance indicators, and necessary resources• Develop an E&S monitoring and reporting manual, which will specify Key Performance Indicators (KPIs) and associated benchmarks, including occupational health and safety (OHS) leading and lagging indicators (incident records, near miss, hazard reporting and other workplace monitoring data), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and supplier and contractor E&S performance• Develop a roll-out plan for the different ESMS components to allow its full implementation within a reasonable timeframe	01/15/2027
2	Extend the trainings to all employees including third-party workers employed by labor agencies, contracted workers, and independent contracted services (delivery associates and pickers). • Develop annual training plans for each function, focusing in particular on OHS, road safety, code of conduct, food safety, emergency preparedness and response, environmental management. These will be documented and updated where necessary.	12/15/2027
3	Develop and implement site-specific emergency preparedness and response plans (EPRP) for warehouses, production facilities, fulfillment points, kitchens, and offices. The site-specific EPRP will include the following key aspects and not limited to:• the emergency response team; site layout showing evacuation routes and assembly points; inventory of emergency equipment showing type, quantity, and locations such as fire extinguishers, fire alarm, portable siren, smoke detector, first aid box, spill kit, etc.; inspection and maintenance schedules for all fire safety equipment; management of fire hazards including compressed gas cylinders; communication equipment used to communicate an incident; list of certified first aiders and trained fire marshals; location of the closest medical facility to receive injured persons; internal and external emergency contacts (e.g., ambulance/hospital); minimum emergency drill frequency; coordination or approval of EPRP with the local authority and/or third parties.	12/01/2026
4	Conduct a supply chain risk assessment in line with IFC PS2 by mapping and assessing the risks for child and forced labor, significant OHS, deforestation, habitat conversion and overlapping sites of high biodiversity value for its key and primary suppliers for coffee and fresh produce. Based on the outcomes of the supply chain risk assessment, develop a Supply Chain Risk Management System to include, and not limited to:• Sustainable Sourcing Policy • Supplier Code of Conduct• Supplier Risk and Onboarding Procedure describing the due diligence for screening, categorization, and approval of suppliers, contractual clauses referring to compliance requirements with the Code of Conduct for wholesalers, traders and suppliers, monitoring and audit requirements, non-compliance tracking and a management approach to address recurrent non-compliance incidents and trends	01/31/2027
5	Conduct a labor assessment to review employment practices and working conditions of all workers involved in company’s operations- with a particular focus on the independent contract service workers (pickers and delivery associates), workers employed through labor agencies, and contracted workers – identify gaps with respect to compliance with the newly adopted Egyptian Labor Law and the requirements of IFC PS2, and make recommendations to close these gaps. The labor assessment will include the following key aspects and not limited to: • Workforce composition, including employees, temporary staff, contractors, and service providers, with their roles and contributions. • Employment terms for company staff, such as wages, benefits, working hours, overtime, leave, and social protections. • Conditions for third-party and service-level workers, ensuring compliance with legal and IFC PS2 standards • Policies for managing third-party employers, identifying gaps and recommending improvements• Workplace health and safety risks and effectiveness of mitigation measures. • Grievance mechanisms for all workers	05/31/2026
6	Review and update its HR policies to: Update where needed to align with the changes in the new Egyptian Labor Law.Explicitly reference its respect to the provisions of the Egyptian laws in relation to employee freedom of association and collective bargaining.Communicate the recently established grievance mechanism to the entire workforce in Arabic and English.	06/30/2026
7	Conduct GBVH risk assessment focusing on two key areas: (i) internally, across its entire workforce, including direct employees, labor hired by labor agencies, service contracted labor and independent service contract labor such as DAs and pickers); and, (ii) across all the customer facing aspects of its business to identify potential risks both to its workforce, in particular young workers, DAs and chefs, as well as to customers. The GVBH risk assessment will also cover other forms of GBV such as sexual abuse, and a review of prevention measures which are included in the Company’s policies and procedures for both its workforce and the customers. Based on the outcomes of the risk assessment. Formulate a comprehensive GBVH action plan that entails prevention, mitigation and response strategies guided by safety, confidentiality, and non-discrimination. Breadfast will further strengthen its anti-harassment, anti-discrimination and GBVH prevention and mitigation by developing a specific code of conduct and procedures tailored to protect both the Company’s workforce and its customers on products and services with workers and customer interaction. The policy will adopt a survivor-centered approach to the investigation and response process for GBVH incidents.	09/30/2026
8	Undertake a child labor risk assessment to identify all workers under the age of 18 currently engaged in its operations and evaluate the scope and nature of their tasks, working hours, and potential hazards in line with Egyptian Labor Law and IFC Performance Standard 2. This assessment will form the basis for developing labor management procedures that allows for the continuous monitoring and accurate recording of young workers’ conditions, including exposure to hazardous work, compliance with legal limits on working hours, and provision of adequate breaks. Building on these measures, the company will establish a detailed child labor policy that explicitly prohibits the employment of children below the legal minimum age of 15, restricts hazardous work for anyone under 18, and sets out clear age verification protocols. The policy will extend to all third-party contractors, mandating compliance with the same standards, and will incorporate provisions for safe working conditions, ongoing monitoring, remediation processes, and targeted training programs for staff and partners.	05/31/2026
9	Conduct a legal review of its service level agreements to clarify the laws and regulations applicable to such relationships and confirm their compliance with the provisions of the new Labor Law (14/2025) and any forthcoming Ministerial Orders that would come to further clarify the functioning of these new forms of employment relationship.	03/31/2026
10	Complete a mapping of all contractors and their associated workforce across all operational areas. Develop a contractor management policy and procedures that clearly defines Breadfast’s labor compliance expectations and establish a process for identifying new contractors, ongoing monitoring of contractor compliance with the Breadfast’s EHS policies and various statutory requirements, including for minimum wages both for full time and part-time workers, social security related benefits and leave provisions, prohibition of child and forced labor, alignment of working hours and overtime payment with statutory requirements, and OHS guidelines for the workers, as well as contractor audits and monitoring.	07/31/2026
11	Strengthen the Road Safety Management System and procedures to include the following key aspects and not limited to: (i) establish operational procedures for plan implementation; (ii) set safe driving standards, including helmet use, prohibition of substance use, vehicle maintenance, and roadworthiness; (iii) track courier app time to reduce fatigue risks; (iv) strengthen journey management by mapping high-risk roads for each site, integrating safer routes, and providing guidance on hazard awareness and speed control; and (v) update road safety training for delivery associates on new protocols and expectations.Drivers will be provided training in line with the system, procedures and requirements including on:- Road safety and safe driving standards- Vehicle safety and maintenance- Emergency procedures and incident reporting	12/01/2026
12	Strengthen the Company’s Waste Management plans to cover: identification of waste streams, waste register/inventory, waste minimization, waste storage points and conditions, criteria for selecting third-party waste transporters, waste transport and final disposal, and specific provisions for hazardous waste management.Strengthen Breadfast’s grievance channels to allow for customers and other members of the public to submit complaints (e.g., in-app, hotline), with a structured process for investigation and resolution, and communicate behavioral expectations from its employees and reporting options to customers across relevant platforms (e.g., app, website, receipts)	09/30/2026
13	Strengthen Breadfast’s grievance channels to allow for customers and other members of the public to submit complaints (e.g., in-app, hotline), with a structured process for investigation and resolution, and communicate behavioral expectations from its employees and reporting options to customers across relevant platforms (e.g., app, website, receipts)	09/30/2026
14	Strengthen the Food Safety and Quality Management System to align it with internationally recognized food safety standards, including the principles of Hazard Analysis and Critical Control Points (HACCP) and relevant Codex Alimentarius guidelines. The management system will address key areas such as cold chain maintenance, sanitation, good manufacturing practices (GMP), pest and chemical control, allergen management, staff hygiene and training, customer complaint mechanisms, and product traceability.	12/31/2026