PPC is establishing a new company in the DRC to develop and operate its greenfield limestone quarry and cement processing plant in the Kimpese area. To build up its systems for the DRC, PPC is relying on its expertise at the corporate level in South Africa, experience from its other operations as a regional cement player in Zimbabwe, Botswana, Mozambique, Ethiopia, Rwanda, and from consultants, and the company will develop its environmental and social management system (ESMS) in accordance with DRC and South African law, IFC Performance Standards, and its existing corporate policies, systems, and procedures. Policy At the corporate level, PPC has a clear commitment to sustainable environmental and social performance, which is articulated primarily through the PPC Group?s Environmental Policy approved in January 2013. This policy states that PPC is committed to understanding and managing any potential environmental impacts of its activities by integrating environmental management into its business functions and monitoring environmental performance systematically. Specific elements of this policy include the following: Establishing clear accountability for environmental performance Seeking continual improvement of environmental management through customized frameworks for engaging with stakeholders, identifying significant environmental impacts, and setting and reviewing progress against objectives and targets Complying with environmental laws and regulations applicable to PPC?s activities Identifying and implementing efforts to manage natural resources sustainably and optimally, including through resource optimization strategies and cleaner technologies Preventing pollution and reducing waste Working with stakeholders to communicate transparently, to develop effective stakeholder forums, and to develop capacity among them to identify, report, and act on opportunities to minimize negative environmental impacts and to promote sustainable use of PPC?s products Managing PPC?s land assets to maintain biodiversity and to rehabilitate degraded areas PPC currently does not have a comprehensive corporate policy on social performance; however, it has sought to adopt a proactive and inclusive approach to stakeholder engagement, including through formalized stakeholder engagement forums. This approach does not yet comprise a systematic, company-wide process for receiving and resolving grievances raised by stakeholders, for example, but it seeks to open channels for communication and dialogue with key groups through stakeholder forums at the corporate and operational levels. At the corporate level, PPC has reinforced its commitment to equal opportunity and empowerment by becoming a signatory to the United Nations initiative ?Women?s Empowerment Principles ? Equality Means Business,? produced and disseminated by UN Women and the UN Global Compact. While not a formal member of the Cement Sustainability Initiative of the World Business Council for Sustainable Development, PPC does cooperate with it on data collection. As defined in the project's Environmental and Social Action Plan, PPC is required to develop a clear social performance policy, approved by its Board at the corporate level, to supplement its company-wide Environmental Policy as well as an overall environmental and social policy for its DRC operations, approved at the country board level. Both are due by 31 December 2014. Identification of Risks and Impacts At the corporate level PPC has sought to analyze material issues and risks related to its environmental and social performance, though this process has yet to encompass all relevant material issues and risks on a company-wide basis. The 2012 annual report indicates that three higher-order environmental and social issues were examined from a risk perspective: (1) safety, including lost-time injuries, (2) labor unrest, and (3) carbon footprint. Response strategies were developed in relation to all three. In the 2013 annual report, the first two issues were maintained as ?material,? while PPC?s carbon footprint was dropped from this list but nonetheless analyzed in detail as a separate issue. At the project level, PPC?s local DRC partner was required under the DRC?s Mining Code of 2002 to develop and submit an Etude d?Impact Environnemental (or Environmental Impact Assessment, EIA) and a Plan de Gestion Environnemental du Projet (PGEP, or Environmental Management Plan) as part of the process for gaining the concession and securing relevant permits. The original EIA was carried out in 2010. As a result of limitations noted in the EIA, PPC has contracted SRK Consulting, a specialized environmental and social consultancy well-versed in IFC?s Performance Standards to supplement this information. A framework Environment and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP) were prepared in January 2014, and a comprehensive ESIA and ESMP will be completed by October 2014. In addition, detailed baseline specialist work is being carried out for air quality, surface, and groundwater resources and on socio-economic issues. These studies will inform the Comprehensive ESIA and ESMP, to be completed by October 2014. Although the comprehensive ESIA might reveal additional risks or change the estimation of severity of impact, the framework ESIA conservatively identified the following risks in need of mitigation as part of the ESMP: Air quality (to ensure low particulate and gas emissions during operations) Greenhouse gas emissions during the operational phase Biodiversity impacts including potential loss of flora and wetlands needs management Management of surface and groundwater impacts to reduce the risk to water availability for other users Loss of soil resources and change in land capability, including risk of soil contamination caused by vehicle operations Noise and vibration impact in Malanga and Zamba villages during construction, operations, and blasting needs management Visual impact of large constructions and landscape changes Traffic and transport impacts, including accident risks and road damage, caused by increased traffic during both construction and operations. Stimulation of local development and local investment in infrastructure and skills training during operations Social impacts with an increased risk of social tensions, health and social impacts, and impacts on community health services associated with migrant worker influx Land acquisition and economic displacement of Zamba and Malanga residents and potential impacts on ecosystem services In light of these anticipated risks and impacts, the following key plans and procedures containing specific management and mitigation measures will be included in the ESMP: Environmental and Social Management System (ESMS) Framework Environmental Awareness Plan Construction Management Plan Construction Control Plan Traffic Safety Plan Emergency Preparedness and Response Plan Greenhouse Gases (GHG) Management Plan Cultural Heritage Management Plan, including Chance Find Procedure Stakeholder Engagement Plan Community Development Plan Influx Management Plan Contractor Management Plan Employment and Capacity Plan Draft Land Acquisition and Compensation Framework Preliminary Closure Plan An action item in the ESAP is for PPC to complete and publicly disclose the comprehensive ESIA and ESMP by 31 October 2014, and the new power line and specifically the proposed route will also be assessed in the supplementary assessment work to be undertaken. The latter will include identification of mitigation measures to be addressed by management, where required. The closest other significant industrial project is also a proposed cement plant that is located more than 20 kilometers away and that will follow the same stringent emission requirements as the PPC project. A potential positive cumulative impact effect could potentially be achieved if the full implementation of an upgrade project for the Matadi to Kinshasa rail line would allow the cement plant to use this transport option for coal from the port and cement to Kinshasa i.e., negating the use of road. However, this possibility is not a real option at this time. There are additional cumulative impacts as a result of these two cement operations that are likely, including those related to increased traffic and negative effects of population influx, such as additional strains on available social infrastructure and public services. The effects will be mitigated principally through measures (described in greater detail below and in the ESAP) related to managing truck traffic at/near the plant and a Community Development Plan that should encompass assistance on urban planning for the nearby towns of Kimpese and, if appropriate, Songololo. The Community Health and Safety Plan should similarly take into account the increased demands on local health services and infrastructures on these nearby towns as well. Management Programs At the corporate level PPC has well-established corporate-level environmental, health, safety and social (EHSS) management programs with a detailed set of standard operating procedures applicable to existing manufacturing operations in South Africa and elsewhere. These will be applied in the DRC as well, taking into account whatever relevant practices that DRC law or the IFC Performance Standards might require that go above and beyond existing management approaches. It is PPC?s intention that management systems and operating procedures for the DRC project be equally stringent as for PPC operations in South Africa, or elsewhere. The environmental management programs in PPC?s existing manufacturing assets in its South African operations are certified under the ISO 14001 international certification program. At the project level, PPC is developing a comprehensive environmental and social management system (ESMS) for its DRC project covering labor, environment, health and safety, land acquisition and involuntary resettlement, cultural heritage, stakeholder engagement (including grievance management and public reporting), and strategic community investment. It is being assisted by experienced consultants in these fields. See above under ?Risks and Impacts? for the full list of management plans that PPC is developing and intends to implement for this project. An action item of the ESAP is for PPC to finalize and begin implementing a comprehensive ESMS for its DRC project, including those management plans and programs specified above, by 31 December 2014. Organizational Capacity and Competency Corporate oversight of environmental, health, safety and social (EHSS) issues is handled at the board level by a committee on risk and compliance and a social and ethics committee, whose chairperson reports to the full board. The committees? tasks are to evaluate and manage risks, to assist the board in monitoring PPC?s activities against relevant legislation, other legal requirements, or prevailing codes of best practice, and to ensure compliance with legislation and other commitments. Within the boards of country-level operating companies under the PPC Group, there are similar committees tasked with oversight of these issues within the country in question. Responsibility for the day-to-day management of EHSS issues is formally assigned at the corporate level to three different groups. The Group Risk Manager covers all non-safety and non-health issues and reports to the Executive: Secretariat and Governance, who in turn reports to the CEO. The Group Safety and Health Manager reports to the Executive: Technical, who in turn reports to the CEO. The Group Sustainability and Environmental Manager reports to the Head: Technical, who reports to the Executive: Technical. Day-to-day managerial responsibility for EHSS issues is further devolved to the project level. During the construction phase of the DRC project, PPC will hire a Risk Manager and an Environmental and Sustainability Manager; these positions are envisioned to continue during the operations phase. Both will report to the senior on-site manager. During construction and operations, the Risk and E&S Managers will have the support of technical officers responsible for health, safety, security, environment, and community development. Training At a corporate level, PPC has a well-developed program for training staff in occupational health and safety and an across-the-board procedure for contractor site induction, including training on relevant health and safety issues for contractors and subcontractors. PPC will adopt a similar approach to its DRC project, including requiring its EPC contractor to develop and maintain a mandatory induction training program for all construction workers. In addition, PPC?s project management of the EPC contractor includes its own oversight of how the contractor is training its construction workers and applying OHS requirements, especially for hazardous types of work. For more information on the specific areas of training in and oversight of such hazardous work for PPC and its contractors and subcontractors, see the sub-section below on Occupational Health and Safety under Performance Standard 2. Emergency Preparedness and Response (EPR) PPC?s operations will have emergency risks that will mainly be limited to impacts on their own site. To handle these risks, the organization will include the necessary emergency response team on site and health clinic facilities to provide emergency room services. For the initial phase this will be achieved by having the EPC contractor bring in its own medical doctor and clinic. Entering the operational phase, the emergency response facilities will include on-site clinic, ambulance, and staff on all shifts trained for emergency response. Monitoring and Review PPC has established a basic structure for monitoring and reporting on its environmental and social performance. At the corporate level, the company has begun using Global Reporting Initiative (GRI) indicators, version G3.1, as well as guidelines on corporate governance in South Africa set out in King III and the Listings Requirements of the Johannesburg Stock Exchange to report on its environmental and social performance. In 2012 and 2013, PPC reported that its annual report met a self-declared C+ classification under GRI (which requires reporting on at least ten GRI indicators across different categories). Under an action item of the ESAP (strengthening of a comprehensive environmental and social management system), PPC is required to expand and reinforce its monitoring and reporting system with special regard to its DRC operations. External Communications and Grievance Mechanisms As a publicly listed company with a century of history of operations in South Africa, PPC has a strong commitment to inclusive and proactive stakeholder engagement, including through formal stakeholder engagement forums at the corporate and operational level. This includes the exchange of relevant information and creation of channels for dialogue at the operational level. The company, however, does not currently have a comprehensive stakeholder engagement methodology that orients all of its international operations in a systematic fashion, for example in establishing standardized approaches to identifying stakeholders, consulting with affected communities about risks and benefits, establishing external grievance mechanisms, and reporting to communities on environmental and social performance. For example, PPC does not report having a systematic, company-wide process for receiving and resolving grievances raised by stakeholders, but it seeks to open up communication and dialogue with key groups through appropriate stakeholder forums at the corporate and operational levels. As part of an action item (strengthening of a comprehensive environmental and social management system), PPC will be required to implement an effective external grievance mechanism in DRC. On-going Reporting to Affected Communities PPC?s approach to stakeholder engagement in South Africa involves creating formal forums that are convened on a regular basis. These forums, in addition to the publication and dissemination of annual reports and other reports to broader audiences, constitute the principal modalities for conveying information to affected communities. PPC does not currently have a well-defined approach for reporting to affected communities in the DRC. The Stakeholder Engagement Plan ? required as part of the comprehensive environmental and social management system (ESMS)? will include provisions on reporting regularly to communities and other key stakeholders on how risks are identified, analyzed, and mitigated and the progress (or lack thereof) that the company is achieving with regard to mitigating negative impacts and enhancing positive project benefits.