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 5 - Land Acquisition and Involuntary Resettlement
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources
PS 8 - Cultural Heritage

This is a Category A project according to IFC's Policy on Environmental and Social Sustainability considering the Project is a photovoltaic (PV) power generation project with an expected installed capacity with 1.2 GWp and will be among the largest PV facilities in Europe once operational with activities that have the potential to cause significant adverse E&S risks and/or impacts that are diverse, irreversible, or unprecedented. The Project is located in a rural area, and its infrastructure overlaps with two Natura 2000 protected sites Campia Crisului Alb si Crisului Negru (ROSPA0115) and Nadab – Socodor – Varsad (ROSCI023) as designated under the EU Habitats Directive and Birds Directive. As such, a key E&S risk for this project concerns avoiding, monitoring, and managing potential adverse impacts on habitats used by bird species during construction and operation of the solar PV plant. The distance to the nearest neighboring residential structure is 270m to southwest and in the settlement of Graniceri.

Key E&S aspects and risks which have been evaluated for this project are expected to include the following:
(i) The Sponsors management systems and their capacity to assess and manage the E&S risks and impacts from both construction and operations in line with IFC PS;
(ii) Management of Contractors’ E&S performance;
(iii) Labor and working conditions, including:
- Occupational health and safety (OHS) policies and practices;
- Labor rights, prohibitions and exclusions;
- Gender-based violence and harassment policies and practices;
- Supply chain considerations;
(iv) Life and fire safety standards, including electrical safety;
(v) Hydrology, flood prevention and water run-off
(vi) Erosion and soil management
(vii) Glare and visual impacts
(viii) Waste management, including options for recycling and disposal of used PV modules;
(ix) Emergency preparedness, planning and response,
(x) The company's stakeholder engagement activities related to E&S aspects;
(xi) Community Health and Safety, including prevention of gender-based violence and harassment (GBVH).
(xii) Land and livelihood impacts
(xiii) Biodiversity impacts and mitigation measures
(xiv) Cultural heritage

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

An Environmental and Social Impact Assessment (ESIA) was prepared for the Project in 2023. During appraisal it was determined that the ESIA contained some gaps and as a result the Sponsor has prepared a Supplementary Lenders Information Package (SLIP), and which compliments the original ESIA. The ESIA and subsequent SLIP describes the environmental baseline and provides a series of mitigation measures to minimize the likelihood of significant impacts from occurring. The SLIP has provided additional environmental and social assessment on the following thematic areas (i) geology and soil management (ii) groundwater and surface water management (iii) wastewater and waste management (iv) biodiversity conservation (v) cultural heritage (vi) socio-economic impact assessment, including labor and working conditions and employment (vii) community health and safety (viii) traffic and transport (ix) land and livelihood impacts (x) cumulative impacts. The Project is fully permitted as relevant to the current stage of its development and construction.

The Project construction will be phased and split into sub-projects to align with the Contracts for Difference awarded to Sponsor (i) Dama A approximately 399 MW (ii) Dama B approximately 399 MW (iii) Dama C approximately 246 MW. It is intended that construction of the Project will be procured on a multi-contracting basis, consisting of separate Engineering, Procurement and Construction (EPC) Contractors for Dama A and Dama B, with each having a potential option over Dama C. It is intended that there will be a separate balance of plant (BoP) and HV electricals construction contract covering the design, procurement, manufacturing, construction, commissioning and testing of the substation and interconnection facilities. It is intended that the PV modules will be procured directly by the Sponsor from module manufacturers and then issued to the relevant EPC contractor for installation. No contracts with the necessary primary contractors or suppliers are currently in place and the respective entities are yet to be selected by the Sponsor.

For operations and maintenance (O&M), it is intended that the O&M contracts would be entered into at, or around, the time of entry into the corresponding construction contracts (i) Dama A O&M (ii) Dama B O&M (iii) balance of plant and HV electricals O&M. It is intended that each of these O&M contracts will be entered into for an initial period of two years following completion of construction and with the same entity which will act as the contractor for the corresponding construction package.

The Sponsor has a corporate sustainability team based in Prague, Czechia. The Sponsor has developed and maintains group level polices, including a Sustainability Framework which requires its projects to align with applicable national standards, E&S regulatory permits, IFC Performance Standards and good international industry practice (GIIP). The Sponsor addresses this objective through the development of project-specific environmental and social management systems (ESMS), with necessary governance, controls and thematic management plans.

The Sponsor has developed an initial Construction Environmental and Social Management Plan (C-ESMP) for the SPV and in respect of the entire Project (i.e. all phases A, B & C and BoP & HV electricals). The C-ESMP presents the requirements for implementation, management and monitoring of the environment and social (E&S), including health and safety (H&S), labor and security requirements for the Project. An initial list of proposed Project sub-plans is provided in the C-ESMP and it includes mechanisms for inspection and audit, training, monitoring, regular reporting, incident reporting, templates and data logs.

Whilst the overarching framework is of an adequate standard, and commensurate with the phase of project development, there is some strengthening required to meet project specificities and the requirements of IFC PS 1. The Sponsor will revise the E&S Policy (ESAP #1) to strengthen commitments on climate-related risk and resilience, prevention of sexual exploitation and abuse, and harassment (SEAH) and Contract and Procurement Policy and will develop a project specific HR Policy (ESAP #2). In addition, the Sponsor will create a project specific ESMS (ESAP #3) which will incorporate the objectives of the revised E&S Policy, the HR Policy, procedures and criteria for assessing the past performance of potential EPC contractors (with regard to employment and occupational health and safety), a procedure to include legal covenants for tenders and contracts, procedures for subcontractor verification and auditing, a permitting register for the Project listing all permits required for construction and operation, a community grievance mechanism, a commitment to decommissioning phase management planning and the project specific C-ESMP and O-ESMP, with fully completed sub-plans and contractor management plan which will include (i) a waste management plan (ii) a hazardous materials management plan (iii) a labor management plan, including influx management and local hiring policy and monitoring and evaluation principles (iv) occupational health & safety management plans (v) a worker accommodation plan (vi) an influx management plan (vii) a wastewater management plan (viii) a soil management plan (ix) a pollution prevention and control plan covering spill prevention, noise, glare and air quality (x) a resource efficiency management plan (xi) a biodiversity management plan (BMP) (xii) a cultural heritage management plan (CHMP), including a chance find procedure (xiii) a traffic management plan (xiv) an emergency preparedness and response plan (EPRP) and (xv) a security management plan.

To support the full implementation of the project specific ESMS, the Sponsor will put in place a team of suitably qualified E&S specialists. In accordance with ESAP #4, the Sponsor will establish an organogram clearly showing the key ESHS roles including i) a suitably qualified ESG manager to support effective implementation of the ESMS and in alignment with group level expectations, national regulatory requirements and IFC Performance Standards and requirements (ii) A Health and Safety Manager (iii) a biodiversity specialist, (iv) A CLO to serve as a point of contact for stakeholders, the community and manage the community grievance mechanism and (v) A Labor Compliance Officer. Both the ESG Manager and a CLO have been appointed. The remaining roles are to be filled and in accordance with ESAP #4.

The Project construction activities will be led by the respective contractors, with discrete specialist tasks carried out by different sub-contractors. Each primary contractor will be required to prepare and submit to the Sponsor for approval its C-ESMP, which must provide a detailed explanation of how the respective contractor will comply with the Project’s requirements stated in Sponsor’s C-ESMP and ESMS. In accordance with ESAP #5 the Sponsor will submit each primary contractor’s C-ESMP for review and demonstrate that this meets the requirements of good international industry practice (GIIP) and the IFC Performance Standards, and prior to the mobilization of any primary contractor. Additionally, the Sponsor will also require the contractor to develop site-specific Operation Environmental and Social Management Plans (O-ESMPs) before commencement of the operational phase (ESAP #5) and covering the same breadth of topics as the C-ESMPs. The requirement for ongoing implementation of the C-ESMP and O-ESMP is to be included as a contractual obligation on each respective contractor organization and their on-site personnel. An assessment of climate resilience has been included in the ESIA. Potential adverse impacts from increased temperatures will be managed by implementing relevant measures within its occupational health and safety protocols which should be included in the Contractor’s C-ESMP and the O-ESMP for the project (ESAP #5).

The Sponsor has included a set of Employers’ Environmental and Social Requirements into the bidding documents and for the contract bidding entities to incorporate into their proposal and approach. The Employer’s Environmental and Social Requirements have been reviewed and largely found to be comprehensive and aligned with IFC Performance Standards, however during appraisal it was identified that the existing Partner (supplier) Code of Conduct required strengthening. Therefore in accordance with ESAP #6 the Sponsor will explicitly include provisions on (i) prohibition of child labor with clearly defined minimum age for employment and minimum age for hazardous work (ii) a defined list or clear reference to prohibited hazardous tasks for underage workers (iii) prevention of gender-based violence, harassment, and abuse (including sexual harassment) (iv) and protection of workers’ health and safety and prevention of harm to workers.

Furthermore, and in accordance with ESAP #7, the Sponsor will include in the EPC contracts, BoP and HV electricals construction contract, the O&M contracts, the balance of plant and HV electricals O&M contract and PV panel supplier contracts, requirements for alignment with national legislation, applicable standards, IFC Performance Standards, the Rezolv Policies, the ESMS and the revised version of Partner (supplier) Code of Conduct Standards and before each is formally executed. The Sponsor will require that these same requirements cascade to subcontractors through contracting provisions.

The Sponsor has developed a project specific SEP. This includes a comprehensive summary of all relevant stakeholders, a description of the tools for engaging, and methods for capturing and reporting on engagement activities. Notwithstanding, in accordance with ESAP #8, the Sponsor will update the Stakeholder Engagement Plan (SEP) to document the ESIA disclosure and consultation process, the feedback received, and how the Project has addressed or will address stakeholders’ comments.

PS2: Labor and Working Conditions

The construction phase is expected to commence in Q3 2026 and the total duration for all project phases will be approximately 14 months. It is estimated that the peak construction workforce will be approximately 1000 workers with an average of 500 workers across the construction phase. It is expected that the majority of the workforce will be Romanian nationals, with the Sponsor prioritizing local hiring where possible. Up to 50 people will be required to provide O&M services to the PV Plant, post construction.

The Sponsor has prepared a Labor Management Plan (LMP) which is aligned with national legislation, international standards (including International Labor Organization (ILO) conventions) and IFC Performance Standards, but is not currently Project specific, it includes (i) A Code of Conduct for general workers (ii) a Code of Conduct specifically for security guards (iii) a Labor Commitment Policy (iv) a Local Content Policy (v) an Accommodation Management Policy (vi) and Worker Grievance Mechanism. This plan covers equal employment opportunities, non-discrimination, and broadly addresses harassment prevention for all categories of workers. The Sponsor’s policies state the workers’ rights to associate and form and join workers' organizations. The Sponsor will be required to appoint a Labor Compliance Officer to supervise all primary contractors and sub-contractors’ compliance with IFC PS2.

All primary contractors and sub-contractors will be required to adopt the HR policy and LMP of the Sponsor and apply them to all categories of workers (ESAP #5). The Sponsor will develop a Terms of Employment Handbook, and a Workers’ Grievance Mechanism (WGM), which will provide a dedicated procedure for handling sensitive cases (discrimination, SEAH and child protection) as well as referral pathways accessible to all workers. These will be finalized and disseminated among all workers in alignment with the requirements set out by the Sponsor in the Project LMP (ESAP #9).

The project's accommodation strategy for non-local workers is under development. Workers that are not local are expected to be accommodated in local community lodgings, rather than in an accommodation camp. Potential locations have been identified, for workers to be accommodated, and a Worker Accommodation Plan to set minimum standards for accommodation will be prepared in accordance with ESAP #5. ESAP #10 provides for the monitoring of labor and working conditions through the implementation of a stand-alone audit prior to peak construction to confirm alignment with IFC PS2.

The Sponsor has developed a health and safety management plan, which provides instructions on the management of the range of hazards and risks identified as part of construction planning. Every primary contractor will be required to prepare its own Occupational Health and Safety Management Plan which meets the minimum requirements of the Sponsor’s policies and procedures, prior to issuing NTP.

The Sponsor has an existing Partner (supplier) Code of Conduct which covers supply chain companies. In accordance with ESAP #6 the Sponsor will update the Code of Conduct to explicitly cover IFC PS2 requirements, including: (i) prohibition of child labor with clearly defined minimum age; (ii) a defined list of prohibited hazardous tasks for underage workers; (iii) prevention of SEAH and child abuse; and (iv) protection of workers’ health and safety. Primary suppliers, such as PV module suppliers and EPC contractors, will be contractually required to adhere to the Partner (supplier) Code of Conduct.

To manage E&S risks related to procurement and supply chain, the company has developed formalized processes, including vendor pre-qualification, selection procedures, and a Partner (Supplier) Code of Conduct, which defines the company’s E&S commitments (including commitments relating to labor practices and human rights). The company incorporates these commitments into the contracts it signs with its suppliers. The supply chain includes the procurement of solar modules. A Supply Chain Risk Public Resources Review was carried out by the Sponsor in February 2026 and this review suggests additional steps to improve visibility and understanding of supply chain risks. In accordance with ESAP #11, the Sponsor will develop a Supply Chain Management Plan (SCMP) covering the Project’s full supply chain, and cascade its requirements to all relevant parties, including PV module suppliers, EPC contractor(s) and their subcontractors, as well as other primary suppliers.

PS3: Resource Efficiency and Pollution Prevention

IFC expects this project to result in annual GHG emissions avoidance of approximately 448,427 tonnes of CO2 equivalent per year.
The Project is expected to generate minor emissions concentrations of pollutants to air, water and soil, which are anticipated to be readily mitigated by implementing standard pollution prevention and control measures defined within the project ESMS and C-ESMP (ESAP #3).
Water requirements are expected to be low during construction and operations. Water during Construction will be required for concrete mixing and curing, pilling, equipment cleaning, dust suppression and domestic usage. Each EPC Contractor will be required to obtain water from a legal source, with consumption measurements and reporting in place. During operation, water usage will be negligible, and the Project intends to adopt dry cleaning measures for the PV panels. During construction and operation, drinking water will be bottle-sourced.
The final approach to concrete supply has not yet been determined, but appropriate wastewater management measures will be implemented for compliant wastewater discharge. Sanitary wastewater generated on site will be collected in mobile sanitary units and collected by certified wastewater disposal companies. As stated in ESAP #5, each EPC Contractor will be required to develop both a wastewater plan and a resource efficiency plan as a part of their CESMP.

Noise and glare impact assessments were conducted as part of the ESIA. There nearest sensitive receptor is located 270m to the southwest of the Project boundary. Based on the assessment performed in the ESIA, construction noise from construction activities will be short in duration and is not expected to be a significant issue for this project with the implementation of mitigation measures aligned with GIIP, nevertheless the ESIA recommends that noise monitoring is carried out when construction activities are occurring in the southwest area and this will be included in the C-ESMP (ESAP #3). The glare impact assessment demonstrates that impacts on residents and road receptors is generally considered to be minor. Nevertheless, the Project will implement targeted vegetative screening along sections of the project boundary and it is considered that this will reduce the potential residual impact to a negligible status. Relevant mitigants identified in the ESIA and SLIP, including those to reduce glare impacts will be included as part of the ESMS (ESAP #3).

Regarding soil and groundwater, the ESIA and SLIP identified potential impacts including increased surface runoff, localized water accumulation and sediment mobilization. Identified mitigation measures include phased construction, rapid stabilization of disturbed areas, maintenance of vegetative cover, and implementation of erosion control measures around stockpiles and drainage lines. Implementation of the mitigation measures will likely result in the residual impact on soil and groundwater contamination to be of minor significance. As a result, the Sponsor will include the appropriate mitigation measures in the C-ESMP and as part of the soil management plan (ESAP #3).

Regarding waste management, the Project will generate non-hazardous waste streams during the construction phase and, to a limited extent, during operation. These include construction and demolition waste such as mixed concrete and masonry, excavated soil and stones, metal waste and cables, as well as packaging waste and household-type waste generated by site workers. Waste will be collected selectively and temporarily stored within designated areas of the site, using containers and storage areas suitable for each waste type. Reuse and recovery are prioritized where technically feasible. The Sponsor will be required to develop a waste management plan and as part of the C-ESMP and O-ESMP (ESAP #3).

Specific controls for pollution prevention and control and resource efficiency will be required to be put in place, particularly during the construction phase. In accordance with ESAP #5, the Sponsor shall submit the EPC Contractor’s C-ESMP for review, and the O-ESMP (at the appropriate time). With the implementation of GIIP, residual impacts are generally expected to be minor or negligible.
The Sponsor will also be required to commit to developing a decommissioning plan (ESAP #3), and which will need to cover procedures for site restoration and be aligned with current GIIP and the requirements of the Waste Electronic and Equipment (WEEE) Directive (2012/19/EU).
PS4: Community Health, Safety and Security

The Project is located in a rural area and relatively far from major urban areas. The distance to the nearest neighboring residential structure is located approximately 270m to southwest of the Project boundary and within the settlement of Graniceri which has an approximate population 2500. Other communities located in the vicinity of the Project include Pilu (2.5km northwest), Siclau (2km southeast) and Socodor (2.7km east).

Risks and impacts to the Project's host communities and the public were assessed during the ESIA and SLIP process. Based on the findings, as per ESAP#3, the Sponsor will develop a labor management plan, including influx management and local hiring policy and monitoring and evaluation principles, an worker accommodation plan, an Emergency Preparedness and Response Plan (EPRP), and a security management plan to manage such risks and impacts effectively, including appropriate mitigation measures to be implemented by its contractors and subcontractors.

A revised existing Partner (supplier) Code of Conduct will be established (ESAP#6), clearly defining project commitments and individual work responsibilities, including specific measures to address GBVH risks. This will define the expected behavior of workers beyond project premises and working hours, including SEAH and child protection in local communities, rules for interactions with local communities, and disciplinary procedures. The company will integrate this into induction training for employees and contractors (including security guards) and in communication campaigns in the workplace and within at-risk communities.

As agreed in ESAP #3, the company will develop and implement an emergency preparedness and response plan (EPRP) for each site in consultation with responsible authorities and communities to cover at least fire, flood response, spills, severe injuries and fatalities, as well as other events that may occur and will require that primary contractors similarly do the same (ESAP #5). The EPRP will also consider the nature by which any emergency scenarios (and associated planning) may need to be adapted to account for the effects and impact of climate change.

The main road traffic risk associated with the project is related to the transport of the equipment to the site from the Port of Constanta to the Project location near Graniceri, Arad County. Additional risks relate to transporting site workers and other construction-related suppliers. The indicative transport corridor follows national and motorway infrastructure, however an initial traffic route has been assessed and sensitive social receptors identified. Furthermore, the Sponsor is required to prepare a project specific traffic management plan as part of the ESMS (ESAP #3) and cascade the requirements to the primary contractors, sub-contractors and suppliers (ESAP #5).

Each EPC contractor will engage a security contractor to provide unarmed security personnel during the construction and operational phases of the project. The perimeter of the boundary will be controlled using a physical steel fence with a single point of entry and access control point. The number of security personnel required to be engaged is yet to be determined. The company will supervise security contractors' personnel are appropriately screened, trained, and competent for their scope of work. As part of the ESMS (ESAP #3), the Sponsor will develop and implement a security management plan aligned with IFC PS4, which will be applicable to the Sponsor and its contractors (and their sub-contractors). Security management will include security selection and evaluation procedures and a security code of conduct to guide the interactions between security personnel, workers, and community members. The plan will include provisions for systematic training regarding GBV and the use of force. All security incidents will be recorded and investigated, and corrective actions will be implemented. The project's community grievance mechanism will be available for members of the community or employees in the event of a violation of the code for security personnel or other grievances related to security.

PS5 Land Acquisition and Involuntary Resettlement

The land for the main Project site, and the Project substation has been purchased through willing buyer/willing seller transactions via a commercial transaction with a single entity. The Sponsor does not have the right to expropriate the land, or request expropriation from the Romanian government. The project will not result in any physical displacement with possible temporary access impacts to informal land users.

The grid connection underground cable is to be developed on a limited area of pastureland along the existing agricultural roads, railway and drainage channels crossings and a country road. For the new Substation, a 3.3ha land plot was concessioned for a 49-year period. In addition, 189m2 was purchased from the Commune for the purposes of the grid connection and further 0.5ha were additionally secured via Right of Use and Servitude Agreements.

There are possible access impacts to nearby farmers and agricultural road users who may experience temporary access disruption because of the construction of the underground cable. Two farmers have the potential to be directly affected by restricted access and approximately 20 farmers and road users could be indirectly affected. These impacts result from the use of the road, under which the cable will be placed, to move livestock to their fields. This will primarily be mitigated through avoidance, where construction of the cable will be undertaken during winter months, when the fields are not in use. A Livelihood Restoration Plan (LRP) has been prepared that is in line with IFC PS5 and describes the proposed mitigation it also includes proposed compensation should avoidance not be possible. ESAP# 12 requires that indirectly affected land users are also consulted on alternative transportation routes, should avoidance not be possible, and that the LRP is updated accordingly. The Sponsor will be required to implement the Livelihood Restoration Plan for the 400 kV grid connection works in accordance with IFC PS5, using an avoidance-first approach to scheduling construction on agricultural land (e.g. carry out works after harvest where possible).

A Community Grievance Mechanism will made accessible to all community members including affected land users. A CLO for the Project has been appointed and is actively working in the local community.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project is located in Pannonian mixed forests ecoregion of the temperate broadleaf and mixed forests biome. The PV site is in a mix of Natural and Modified Habitat, where the agricultural areas have been extensively drained through drainage canals. The network of ditches that the site crosses support seasonal water bodies and wetland vegetation, where there are also areas of highly fragmented steppes. The most significant type of Natural Habitat is the Pannonic salt steppes and salt marshes, which constitutes less than 2% of the project site. The project overlaps with two Natura 2000 sites, Nadab - Socodor – Varsad Site of Community Importance (SCI) designated under the EU Habitats Directive for the Pannonic salt steppes and marshes, and Campia Crisului Alb si Crisului Negru Special Protection Area (SPA) designated under the EU Birds Directive associated with migratory and resident birds. The SCI and SPA also partially overlap with Campia Crisurilor Key Biodiversity Area (KBA) designated for migratory birds including raptors.

Priority biodiversity values that are associated with the project include the Saker Falcon and Red-footed Falcon (IUCN Red List – Endangered), Eastern Imperial Eagle, Greater Spotted Eagle, Red-breasted Goose, Lesser White-fronted Goose, Turtle Dove (all IUCN Red List – Vulnerable) and other migratory bird species, the European Souslik (IUCN Red List – Endangered), Eurasian Otter (IUCN Red List – Near Threatened), Schreiber’s Bent-winged Bat (IUCN Red List – Vulnerable), Pond Bat (IUCN Red List – Near Threatened), Common Noctule (IUCN Red List – Least Concern), European Pond Turtle (IUCN Red List – Near Threatened), European Fire-bellied Toad and European Tree frog (both IUCN Red List – Least Concern), as well as the Water Shamrock (IUCN Red List – Vulnerable) and the Pannonic salt steppes and salt marshes habitat. The project is not in Critical Habitat (CH) for any of the identified priority biodiversity values as per IFC PS6; however, IFC Natural Habitat No Net Loss (NNL) requirements will apply to all of these priority biodiversity values.

Rezolv Energy has developed a construction-phase Biodiversity Management Plan (BMP), which includes pre-construction check-ins/walkover surveys to be completed prior to the onset of earthworks, specifically for areas of Natural Habitat and associated priority biodiversity values. The BMP describes avoidance and minimization measures relevant to these values during the construction phase. This will include the installation of bird flight diverters (BFDs) along the OHTL following good international industry practice (GIIP) in terms of appropriate BFD model and spacing interval. The Sponsor will appoint a Biodiversity Specialist, with suitable expertise, who will be responsible for the overall management and reporting of all Biodiversity activities relating to the project.

In the operations-phase of the project, Rezolv Energy will implement an operations-phase BMP, which will include a Habitat Restoration Program for Pannonic salt steppes and salt marshes habitat and associated priority biodiversity values (ESAP#13). A qualified expert with international experience will be procured to develop the Habitat Restoration Program, which will, at the minimum, include (i) detailed habitat mapping, (ii) identification of impacts, (iii) recommendations for restoration measures and opportunities to maintain biodiversity on-site and (ii) a clear demonstration of how NNL will be achieved.

In line with the Habitats Directive Resolution 6 requirements, an Appropriate Assessment (AA) was conducted for the project and shared with the National Agency for Natural Protected Areas (ANANP). Rezolv Energy also consulted with conservation organizations in Romania including the Societatea Carpatina Ardeleana – Satu Mare (SCA) and Milvus Group in developing a Biodiversity Action Plan (BAP) to address residual impacts on Natural Habitat and priority biodiversity values, which are also associated with the Natura 2000 sites. The BAP includes a loss/gain assessment and defines offset measures to achieve NNL objectives and additional conservation actions (ACAs) for the Natura 2000 sites and associated biodiversity values.

Per ESAP#14, Rezolv Energy will update and implement the BAP to (i) include the outcomes of the updated Critical Habitat Assessment (CHA), (ii) incorporate a Biodiversity Monitoring and Evaluation Plan (BMEP) with indicators and thresholds for adaptive management, and (iii) demonstrate implementation of the ACAs and continued engagement with relevant stakeholders (e.g. competent authorities, conservation organizations, etc.). The BAP will be updated periodically as the project progresses. For offset measures identified in the BAP, Rezolv Energy will develop and implement a Biodiversity Offset Management Plan (BOMP) commensurate with the residual impacts resulting from the project and based on consultation with key stakeholders. The BOMP will be developed and implemented by qualified experts with international experience on offsets. It will: (i) quantify residual impacts on Natural Habitat, (ii) define offset criteria and options, (iii) assess the feasibility of proposed offsets (iv) establish a monitoring framework to assess the deliver measurable conservation outcomes, and (v) include budgets for implementation and monitoring (ESAP#15).

PS8: Cultural Heritage

The ESIA and subsequent SLIP includes a baseline cultural heritage review and impact assessment. There are fourteen cultural heritage features that have been identified within the Project area that will be directly impacted by construction works. Arad County Directorate for Culture has issued a favorable cultural heritage permit for construction, to the Project, recognizing the archaeological sensitivity of the site and defining approved construction parameters. The start of works is approved on the condition that the following actions are completed (i) preventive archaeological investigations (rescue excavations) are completed, (ii) issuance of an archaeological discharge certificate is approved at the national level, (iii) archaeological supervision is implemented where required, and (iv) there is prior notification and ongoing coordination with the authority.

The Sponsor will be required to complete all necessary archaeological investigations and obtain clearances before construction activities in affected areas (ESAP #16), and it will implement protective measures (e.g. fencing-off or micro-siting to avoid impacts) on cultural heritage sites. No construction shall commence in areas with identified archaeological sites until official clearance (“archaeological discharge”) is obtained. In accordance with ESAP #3 the Sponsor will prepare and implement a Cultural Heritage Management Plan (CHMP) in line with IFC PS8 and national law, in partnership with local heritage authorities and local communities and in accordance with ESAP #5 will cascade its responsibilities to the EPC contractor and subcontractors. The CHMP will cover both tangible and intangible cultural heritage.

The project has developed a Cultural Heritage Chance Find Procedure which is compliant with IFC PS8, to ensure the construction of the Dama project does not lead to adverse impacts on, as yet unidentified sites of Cultural Heritage.

To further strengthen and formalize its stakeholder engagement, the Sponsor has prepared a documented Stakeholder Engagement Plan (SEP) in line with PS 1 requirements. A Community Grievance Mechanism is to be developed (ESAP #3) and will be implemented to address community grievances arising out of the project’s construction and operations activities. Community concerns and grievances about the Sponsor’s and any contractors’ E&S performance, including gender-based violence and harassment aspects, shall be resolved using such mechanism. The Sponsor will integrate specialized channels for reporting sensitive cases, such as discrimination, harassment, and SEAH, and clear referral pathways will be established to connect complainants with necessary support services. A Community Liaison Officer (CLO) has been designated by the Sponsor to manage implementation of the project SEPs and the community grievance mechanism and is currently fulfilling the role.

Contact Person: Oana Iuga
Company Name: : West Power Investments SRL
Address: Piata Charles De Gaulle 15 E. Sectorul 1, Bucuresti, Republic of Romania
Phone: +40 735 513690

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	West Power Investments SRL will revise the Environmental and Social (E&S) Policy to incorporate (i) commitments on climate-related risk and resilience (ii) prevention of gender-based violence and harassment (GBVH) (iii) explicit adoption of Rezolv’s corporate Contract and Procurement Policy operationalizing the Partner (Supplier) Code of Conduct, for compliance with its labor requirements.	06/14/2026
2	West Power Investments SRL will develop a Human Resources (HR) Policy covering the following (i) Non-discrimination, equal rights, equal pay; (ii) Prohibition of all forms of child labor and forced labor (iii) Workers’ rights and obligations (including reference to the revised Partner (supplier) Code of Conduct) (iv) Freedom of association and right to collective bargaining (v) Informing workers about their rights, obligations, liabilities, and entitlements (vi) Working relationships and Terms of employment including recruitment, hours of work, overtime arrangements and overtime compensation, rights to refuse overtime request (vii) Contractor management (viii) Workers accommodation (ix) Occupational health and safety (x) GBVH, and sexual exploitation abuse and harassment (SEAH) (xi) Collective dismissals.	06/14/2026
3	West Power Investments SRL will develop and implement the ESMS for the Project to include, but not limited to a) Reference to the revised E&S Policy and HR Policyb) All necessary plans and procedures to address mitigation measures identified in the ESIA and SLIP to be developed and executed, including criteria for assessing the past performance of potential Engineering, Procurement and Construction (EPC) contractors with regard to employment and occupational health and safety c) A change control procedured) A procedure to include E&S legal covenants for tenders and contracts, e) Procedures for subcontractor verification and auditing f) A permitting register for the Project listing all permits required for construction and operation g) A community grievance mechanism h) A C-ESMP and O-ESMP, with fully completed sub-plans as follows, (i) a waste management plan (ii) a hazardous materials management plan (iii) a labor management plan, including influx management and local hiring policy and monitoring and evaluation principles (iv) occupational health & safety management plans (v) a worker accommodation plan (vi) a wastewater management plan (vii) a soil management plan (viii) a pollution prevention and control plan covering spill prevention, noise and air quality (ix) a resource efficiency management plan (x) a biodiversity management plan (BMP) and to include pre-construction surveys for targeted species (xi) a cultural heritage management plan (CHMP), including a chance find procedure (xii) a traffic management plan (xiii) an emergency preparedness and response plan (EPRP) (xiv) a security management plani) A commitment to decommissioning phase management planning	07/01/2026
4	West Power Investments SRL will establish an organogram clearly showing the key ESHS roles in construction and operation, including an ESG Manager, a Health & Safety Manager, a biodiversity specialist, a CLO and a suitably qualified Labor Compliance Officer to monitor all labor related issues including in the supply chain.	06/14/2026
5	West Power Investments SRL will a) Require all primary contractors and suppliers to develop C-ESMPs, as part of their ESMS, and commensurate with their activities to include as a minimum (i) a waste management plan (ii) a hazardous materials management plan (iii) a labor management plan, including influx management and local hiring policy and monitoring and evaluation principles (iv) occupational health & safety management plans (v) a worker accommodation plan (vi) a wastewater management plan (vii) a soil management plan (viii) a pollution prevention and control plan covering spill prevention, noise and air quality (ix) a resource efficiency management plan (x) demonstrate their adherence to the biodiversity management plan (BMP) (xi) a cultural heritage management plan (CHMP), including a chance find procedure (xii) a traffic management plan (xiii) an emergency preparedness and response plan (EPRP) (xiv) a security management plan. All plans shall comply with the applicable National requirements, IFC Performance Standards, good international industry practice (GIIP), include relevant considerations due to the impacts of climate change, and include measurable performance indicators (KPIs) to track progress towards the defined objectives and targets.b) Require all primary O&M contractors to develop O-ESMPs, as part of their ESMS, and commensurate with their activities, covering the same suite of plans and principles as the C-ESMPs, but with the appropriate operational phase focus.	07/01/2026
6	West Power Investments SRL will revise the existing Partner (supplier) Code of Conduct to explicitly include provisions on (i) prohibition of child labor with clearly defined minimum age for employment and minimum age for hazardous work (ii) a defined list or clear reference to prohibited hazardous tasks for underage workers (iii) prevention of gender-based violence, harassment, and abuse (including sexual harassment) SEAH and child protection (iv) and protection of workers’ health and safety and prevention of harm to workers. Training on the revised Partner (supplier) Code of Conduct will be provided to all workers during their initial induction and periodically thereafter, and to communities through awareness campaigns.	06/01/2026
7	West Power Investments SRL will include in the tender documentation and all EPC Contractor’s, BOP and HV electricals contractor, O&M, the balance of plant and HV electricals O&M contract and PV panel supplier contracts, a provision on full compliance with national legislation, applicable standards, IFC Performance Standards, the Rezolv Policies, the ESMS, the SCMP, and the revised version of Partner (supplier) Code of Conduct. West Power Investments SRL will require that these same requirements cascade to subcontractors through contracting provisions.	06/01/2026
8	West Power Investments SRL will update the Stakeholder Engagement Plan (SEP) to document the ESIA disclosure and consultation process, the feedback received, and how the Project has addressed or will address stakeholders’ comments.	06/14/2026
9	West Power Investments SRL will develop A Terms of Employment Handbook, including details of the Workers’ Grievance Mechanism (WGM) which will be finalized and disseminated to all workers, including sub-contractors. These will include specific protocols, procedures and referral pathways to address sensitive cases (such as discrimination, SEAH and child protection) and handling any associated grievances.	07/01/2026
10	West Power Investments SRL will conduct a stand-alone labor and working conditions audit, as part of the E&S monitoring process. This will include a readiness audit prior to mobilization and a follow-up audit at the peak of construction. The audit will assess compliance with national labor legislation, and IFC Performance Standard 2. It will include direct, contracted and subcontracted workers	07/01/2026
11	West Power Investments SRL will develop a Supply Chain Management Plan (SCMP) covering the Project’s full supply chain, and cascade its requirements to all relevant parties, including PV module suppliers, EPC contractor(s) and their subcontractors, as well as other primary suppliers.	07/01/2026
12	West Power Investments SRL will conduct additional consultations with indirectly affected land users and road users who may experience indirect or temporary impacts (such as temporary access restrictions to fields) during construction. Update the Livelihood Restoration Plan (LRP) accordingly to include the consultation findings, the agreed alternative access arrangements (routes), and reflect these in the Entitlement Matrix as applicable. The final LRP will be disclosed to all affected people and will include information on the project grievance mechanism so concerns regarding the land access and livelihood restoration process can be submitted.Implement the Livelihood Restoration Plan for the 400 kV grid connection works in accordance with IFC PS5. Use an avoidance-first approach to scheduling construction on agricultural land (e.g. carry out works after harvest where possible). If temporary land use restrictions or damage to assets (crops, grazing land) cannot be avoided, provide compensation at full replacement cost before starting work on each affected segment.	07/01/2026
13	West Power Investments SRL will develop and implement an operation phase BMP, which will include a Habitat Restoration Program for Pannonic salt steppes and salt marshes habitat and associated priority biodiversity values. A qualified expert with international experience will be procured to develop the Habitat Restoration Program, which will, at the minimum, include (i) detailed habitat mapping, (ii) identification of impacts, (iii) recommendations for restoration measures and opportunities to maintain biodiversity on-site and (ii) a clear demonstration of how NNL will be achieved.	06/30/2027
14	West Power Investments SRL will update the BAP to (i) Include the outcomes of the updated Critical Habitat Assessment (CHA), (ii) Incorporate a Biodiversity Monitoring and Evaluation Plan (BMEP) with indicators and thresholds for adaptive management, and (iii) demonstrate implementation of the ACAs and continued engagement with relevant stakeholders (e.g. competent authorities conservation organizations, etc.). The BAP will be implemented throughout the project lifecycle and updated periodically as the project progresses.	06/14/2026
15	West Power Investments SRL will develop and implement a Biodiversity Offset Management Plan (BOMP) commensurate with the residual impacts resulting from the project and based on consultation with key stakeholders. The BOMP will be developed and implemented by qualified experts with international experience on offsets. It will: (i) quantify residual impacts on Natural Habitat, (ii) define offset criteria and options, (iii) assess the feasibility of proposed offsets (iv) establish a monitoring framework to assess the deliver measurable conservation outcomes, and (v) include budgets for implementation and monitoring	06/30/2027
16	For known archaeological sites within the project footprint, West Power Investments SRL will conduct the required pre-construction field surveys or rescue excavations in coordination with the Arad County Directorate for Culture. Protective measures including fencing off and micro-siting to avoid impacts for heritage sites to be preserved in situ shall be included in the cultural heritage management plan (CHMP).	07/01/2026