Identification of Risks and Impacts:

As per regulatory requirements set out by the Yangon City Development Committee (?YCDC?), the Company is required to submit an Environmental Impact Assessment (?EIA?) for the Project. The Company is working with a consultant and a first draft of the EIA is expected in early 2014. 

Demolition of the GMER building is expected to commence by first half of 2014 and will be implemented in two phases. The demolition processes will not involve the use of explosives. Yoma will require demolition contractors to strictly observe requirements and procedures related to dust and noise control, and to health and safety impacts. 

The Company has commissioned a consultant firm to undertake a hazardous materials assessment of the Project site. The scope included identifying hazardous materials (HAZMAT) on site (including asbestos which were commonly used in older buildings in Myanmar) to compile an updated HAZMAT register, and to make recommendations regarding ongoing HAZMAT management. The HAZMAT assessment has found limited quantities of asbestos in the GMER and FMI Center buildings. During demolition, contractors will be required to strictly follow Yoma procedures to curtail any potential spread of asbestos dust and to prevent workers? exposure to asbestos dust. The Company will undertake monitoring to ensure compliance ? refer to the ESAP for details.

Organizational Capacity, Monitoring and Review:

Yoma which will be a major shareholder in the Company has developed and implemented an Enterprise Risk Manual (?ERM?) framework in order to identify, assess, treat and monitor potential risks.  At Yoma?s corporate level, the Director of Risk Management and Assurance, who reports to the Chief Executive Officer of Yoma, is responsible for overall risk management and oversight as well as conducting risk based reviews across the Yoma group (otherwise known as Risk Based Internal Auditing) to provide assurance to the board that risk management processes are managing risks effectively, in relation to the risk appetite (or identify exceptions when it is not). 

The Director of Risk Management and Assurance reports the improvement opportunities identified during the reviews and provide recommended action plans to management members including the CEO of Yoma.  As part of this process, Standard Operating Procedures (?SOP?) are developed to address improvement opportunities identified in the report.

In addition, Yoma is in the process of developing an Environmental and Social Management System (ESMS) Manual in accordance with relevant IFC Performance Standards which will be endorsed by the CEO and adopted at working entity level.The Manual will include: 

a) an E&S policy and mission statement; b) specific Standard Operating Procedures on but not limited to the following: E&S screening and due diligence of potential projects; labor and working conditions; key occupational health and safety risks; land acquisition, resettlement, and livelihood restoration; stakeholder engagement and community grievance mechanisms; emergency preparedness and response; E&S requirements on contractors, sub-contractors, and primary suppliers; biodiversity management; resource efficiency and waste management; c) relevant key performance indicators, training programs, and corporate monitoring and reporting programs; d) mechanisms to regularly review ESMS implementation effectiveness by internal (and external as needed) experts; e) assignment of an appropriately qualified staff member as overall E&S coordinator at the Yoma group level.

Refer to the ESAP for details.

External Communications:

The Group office at FMI Centre and security station at the front entrance of the Project site are the key local public interfaces to receive external communications including grievances from the public. At each of the Group?s business or real estate sites, the main office or project management office and the front entrance security stations serve as the point of contact to receive public enquiries.