Environmental and Social Management System and Policy Pacific Midstream (PM) is a newly founded corporate vehicle established by Pacific Rubiales Energy Corp. (PRE). The Management team is in the process of being recruited and the E&S management system will be developed on the basis of the PRE ESMS and IFC Performance Standards. PRE has an integrated ESMS with ISO 9001, ISO 14000 and OSHA 18000 certification. Their policies and procedures include requirements for contractors on Health, Safety, Environmental and Quality which are part of the contractors? contractual obligations. The company?s contractors and suppliers are subject to a third party compliance verification that encompasses monitoring of legal, financial, labor and environmental, health, community and safety aspects and also includes periodic reporting by E&S consultants (interventores) embedded in the operational teams of the contractors. PRE has a Social Management system led by the Corporate Social Responsibility Group (CSR) which focuses on stakeholder engagement, grievance management, impact management, social project development and compensation as well as community investments. The Social Responsibility Policy addresses the obligations to stakeholders, mainly focused onlabor conditions, local recruitment, local procurement and social investments. The Social Policy is guided by the Principles of the Global Compact and is reported in their Sustainability Report using GRI standards, which has allowed recognistion by the Dow Jones Sustainability Index. This Social Policy is part of the?Commitments that are established in the Company?s Sustainability Policy, which groups all material and relevant aspects that the Company promotes in its Operations. Contractors are required to comply with a Labor, Environmental, Social, security and technical annexes for any and all services, which have a positive direct impact on all stakeholders?. There is a close coordination between the CSR team and the environmental and real estate teams (responsible for land acquisition and easement) , as well as with core operational teams such as Projects, Exploration, Drilling and Production. As part of the Corporate Policy, the Social Investments are being channeled through Shared Value Programs, which allow local communities to develop commercially feasible companies to be linked to the Company?s value chain and the regional commercial activities promoting Local Procurement. PEL has an ESMS fully aligned with the environmental and social standards of PRE covering all project related activities including contractors? management. CT: EXMAR Shipmanagement has a suite of corporate policies and procedures governing environmental, health, safety, and quality issues, including a certified safety management system for Shipmanagement operations, in accordance with the International Safety Management (ISM) Code, the international standard for safe management and operation of ships. EXMAR Shipmanagement is ISO 14001 certified for environment, OHSAS 18001 for occupational health and safety, ISO 9001 for quality and is in the process of incorporating ISO 29001 (specific to the oil and gas industry) into its quality system. For the onshore pipeline the PRE ESMS will apply. ODL has an integrated ESMS. Through ISO 31000 (Risk Management) communication with key stakeholders identifies, monitors and mitigates the most important risks to the project. An audit plan is developed on a yearly basis including regular independent audits. The project has an ethical telephone line which covers both staff and contractors. The pipeline is monitored by walkovers as well as an optical fiber cable which is sensitive to any intrusions. The people conducting the walkovers also record any grievances from affected communities. As part of the project, 1% of the project costs are invested in environmental projects as well as compensation for land disturbed by building the pipeline. ODL has not had any security incidents since it became operational in 2008. ODL has agreements (Convenios) with armed public forces to provide peripheral protection for the pipeline. These agreements are limited to providing logistical support and are developed in line with the requirements of the Voluntary Principles. ODL has developed a Human Rights Policy to ensure that their business activities and the work implemented for them by contractors are aligned with the principles of human rights. OB has a comprehensive social policy and management system for their operations and a dedicated team for their implementation. The Social policy commits to identifying social risks and addressing them through the mitigation hierarchy. A key component is the grievance mechanism which is disseminated among affected communities and fully integrated into the overall management system to address root causes for grievances. OB has a policy for local recruitment which they effectively implemented through the contractors during the construction phase, employment opportunities included opportunities for women. Consultation with affected communities initiated during the ESIA process continued throughout the construction and operational phase. Community representatives (Presidentes de Juntas de Accion Comunal, personeros) are involved in monthly meetings with contractors, company representatives and to discuss the implementation of the social management plans and address any community concerns. All staff and contractors receive training on the social policy and management plans on a regular basis including as part of induction. In addition OB has made agreements (Convenios) with the armed forces for peripheral protection. All agreements are made in line with the requirements of the Voluntary Standards. Private security personnel in the field are not armed. During the construction period OB worked closely with Fundacion Pais Libre, a Colombian NGO focused onpreventing kidnappings and extortion, and who assisted in resolving all 19 kidnappings that took place during the construction phase. For current and future assets where PM holds majority interest PM has committed to implement the requirement of IFC Performance Standards and the relevant World Bank Group Guidelines through their corporate-level environmental, social and health and safety management system (ESMS ) which will contain, at a minimum, the following elements: -Policy: PM will develop an overarching Policy statement of the E&S objectives and principles. consistent with IFC Performance Standards, including principles of FPIC when Indigenous Peoples (IPs) are affected. -Risks and Impacts Identification Process and Management: The corporate ESMS will define PM?s social and environmental risk and impact identification process. This process will include all the necessary steps and methods that are required to screen, identify, analyze, measure, or assess, in quantitative terms, to the extent possible, the potential risks and impacts (including environmental, social, health, and safety, labor and security) associated with the activities to be developed and assure that the mitigation hierarchy is applied to manage all identified impacts and risks. When applicable, this process will involve an Environmental and Social Impact Assessments (ESIAs) process in line with IFC?s Performance Standards. EPC contracts for each project will incorporate the relevant project-specific mitigation measures and actions identified during the assessment process to ensure compliance with Colombian requirements, as well as IFC PS. Project-specific mitigation measures will include management of impacts and risks addressed in PS2 through PS8. In addition as part of the corporate management system, PM will develop an environmental and social risk screening procedure, which considers the capacity of the operators of prospective assets to manage risks and impacts in meeting PM corporate E&S policy requirements. This procedure will provide inputs to the decision whether to pursue the opportunity in consultation with IFC. The corporate management system will also include procedures for continuous monitoring of the existing portfolio. All assets/projects will have their independent ESMS which will be overseen and monitored by PM to ensure compliance with PM policies and procedures. For assets where PM holds minority interest PM will assess new acquisitions through the risk screening procedures and monitor portfolio projects as described above. Ensuring implementation of the corporate policies at asset level will be on a best effort basis. Identification of Risks and Impacts and Management Programs A key component of identifying risks and impacts of prospective projects and developing adequate mitigation measures includes the development of ESIAs. Prior to the formation of PM in 2014 ESIAs were submitted to the environmental authorities and the required licenses granted for PEL, ODL and OB.CT is in the process of finalizing the ESIAs (one for onshore and one for off shore activities) for submission to the local authorities approval is expected by June 2014 while construction is planned to be initiated by September 2014. PM will be involved in the monitoring of the construction phase of PEL. IFC reviewed the ESIAs for PEL (2010), CT (2014), ODL (2001-2014) and OB (2010) all of which were developed in accordance with Colombian requirements by competent independent consultants. The ESIAs have solid baseline data, comprehensive assessments of risks and impacts and the framework for establishing effective management plans and are overall of high quality. For the two assets with minority interest (ODL and OB) it is concluded through the review of available documentation that they have been developed and are managed in line with Good International Industry Practice (GIIP). PEL: The ESIA was approved in February 2012 by the competent national authority (Autoridad Nacional de Licencias Ambientales ? ANLA). The ESIA identified key impacts during the construction phase related to the construction of access roads, workers? accommodation and storage areas with potential impacts of erosion, landslides, sediments runoffs to water bodies and dust. Impact on fauna and flora are mainly caused by adjustments to vegetation throughout the RoW (Right-of-Way) corridor to avoid interference with power conductors. The RoW corridor runs through savanna and low grasslands but also through more sensitive areas such as gallery forest and ?morichales?. The ESIA concludes that impacts are generally moderate and can be adequately managed through the implementation of management plans. Loss of vegetation is compensated depending on level of sensitivity from a ratio of 1:3 to 1:6 and a program was developed to rescue the epiphytes (such as orchids ) impacted throughout the RoW. 19,300 epiphytes were rescued from the trees that were cut along the right of way. A program to relocate the epiphytes was established and will be monitored for 4 years. PEL is still in the process of identifying off set locations for impacted forest (compensated at a ratio of 1:5). Alternative analyses for the RoW were conducted and the preferred route was approved by the environmental authority and refined to minimize potential environmental and social impacts. The 230-kV transmission line with 552 towers was constructed within a 32-meter wide RoW that extends for nearly 260 km. The preferred route runs parallel to the existing ODL oil pipeline to take advantage of an existing linear corridor in part of its trajectory. The base of the towers consists of 12x12 meter concrete pads. The transmission line corridor was realigned to avoid impact on protected areas such as national parks and the land of vulnerable communities (displaced communities granted land under the national land-restitution scheme). The RoW easements were negotiated with 260 landowners and did not result in any physical or economic displacement but the process resulted in 20 cases that had to be resolved by the authorities (impositions). Impacts during the construction phase were minimized by using existing roads, placing towers away from the margins and riparian vegetation to protect surface water bodies, and minimizing vegetation suppression, where possible. PEL has an agreement with the public armed forces to provide peripheral protection of the towers. The agreements are drafted in line with the requirements of the Voluntary Principles. A security assessment was conducted prior to the construction phase and updated for the operational phase. To date no security incidents have taken place. It has been certified by the Minister of Interior that the development and operation of infrastructure for PEL has not affected any Indigenous Peoples. CT: A comprehensive ESIA containing a baseline, impact assessment, economic rationale, management, mitigation, monitoring and contingency plans was prepared for both the onshore and offshore projects by the ANTEA Group. Each project identifies the inherent impacts and risks associated with project activities, and provides a comprehensive and well documented account of the engagement strategy used to map, inform and consult with affected stakeholders, in a timely, open, participatory and culturally sensitive manner, including the process of Prior Consultation (Consulta Previa) carried out with five (5) IP communities located in the area of influence of the onshore pipeline. Offshore The general area of influence of the offshore project is the Gulf of Morrosquillo. The direct area of influence was narrowed down to the areas directly impacted by construction, operations, and closure and abandonment activities. For safety purposes, in the area of the offshore platform there will be an implementation of a maritime traffic management plan. The ESIA concluded that the project will result in impacts (deemed moderate) on artisanal fishermen operating in the area although they will still have access to other fishing grounds in the area. The towns of Santiago de Tolu and Palo Blanco are the nearest and most directly affected communities by the project. The ESIA includes a thorough assessment of the main environmental, social, health, safety, and security risks and impacts of the project per activity and phase of project development. Stakeholders were mapped at the early stages of the assessment and regularly informed and consulted on the project, its impacts, proposed mitigation and management measures. Consultations were documented and concerns were used to inform the mitigation and management process. During the construction phase development impacts are largely associated with disturbances caused by increased road traffic, movement of large and heavy vehicles and machinery, high dust and noise levels, potential interactions and risk of conflict between the workers with community members, high expectations for jobs and social benefits, visual impacts from boats, cranes and other heavy machinery offshore. Impacts are considered to be temporary in nature, reversible and mitigated with the implementation ofGIIP during civil works. The area of the gulf is characterized as an important port and shipping town with some artisanal fishing and seasonal tourism activity. Due to the deterioration of the marine environment and the depletion of corals and fish stocks in the gulf, commercial fishing is not feasible. Fishing is done on a subsistence basis by individual fishermen with access to small boats. During the construction phase there will be some restriction on fishing activities, and the usual marine traffic in the area, however, once operational people will have free access to navigate inside gulf waters according to the General Maritime Directorate?s (DIMAR) definition . Coastal communities in the gulf area are accustomed to co-exist with offshore activities, which play an important role in the economy of the area through the long-term presence of the COMPAS and Ecopetrol who maintains export shipping activities further east. The project is not expected to generate adverse impacts on the overall quality of life of local people, nor the marine environment. The project will have a policy for hiring local peoples for technical and non-skilled jobs which will reduce workers coming from outside the local area. The offshore personnel are expected to be accommodated on board vessels and also use local hotels. The number of international workers into the area will be kept to the minimum and will mainly consist of skilled labor. This will not adversely impact the social dynamic in the area as the numbers of foreigners to enter the area will be small due to the limited size of the project and the area is already exposed to influx of non-locals and foreigners for the port/shipping activities and for tourism. The visual impacts will be higher during the construction phase due to the volume of construction related boats and machinery. Once operational, the remnant impacts of the project will be the visual impact caused by the vessels docked and navigating offshore, as well as the permanent fixture of the associated platform facilities which can be seen at a distance on a clear day and in dim lights during the night. The offshore facilities will be continuously monitored by security personnel, which will receive training on how to handle interactions with fishermen and other civilians.. Onshore The onshore pipeline will extend a total of 80 km with a diameter of 18 in, and a Right-of-way (RoW) of 20 meter across 8 municipalities San Pedro, San Luis de Since, San Juan de Betulia, Corozal, Morroa, Sincelejo, San Antonio de Palmito and Santiago de Tolu. , all within the Department of Sucre. Portions of the Right-of-Way (ROW) will run parallel to existing pipelines operated by Ecopetrol and Promigas . The width of the trench will be 1.5 m with a depth of 1.5 m. During the construction phase it is expected that impacts related to dust, increased heavy traffic, potential disturbances on local communities, potential impacts on local infrastructure and residential property, clearing of land/easements, potential contamination of waterways and soils, temporary and permanent loss of crops and trees and other small structures, the generation of solid and hazardous waste, and effluents, will be , mitigated and managed with the use of GIIP, the project has management plans in place to mitigate the above impacts and has committed to implement the PS and the World Bank Group Environmental, Health and Safety Guidelines (WBG EHS). It is the responsibility of the Ministry of Environment and Sustainable Development to make a determination with respect to the approval of the ESIA?s and ESMP?s and grant the licenses. CARSUCRE, the Regional Autonomous Corporation of Sucre, is the environmental authority responsible for ensuring the protection and conservation of natural resources in the Department of Sucre, where the projects are located in their entirety. DIMAR will review and approve the navigation routes and maritime traffic and signaling, while the National Infrastructure Agency (ANI), through Resolution 1526 of December 2013, will establish the conditions for the FLSU, Puerto Gas Licuado del Caribe (PGLC) concession. ODL: The areas traversed by the selected RoW have sparse vegetation, are predominantly flat with relatively cohesive soils which prevents severe erosive processes. Soils have a thin organic layer and are relatively shallow, and as a consequence they have been assessed to have a low ecological productivity. The area crossed by ODL was qualified by the ESIA as of low environmental sensitivity. The ODL?s route alternative analysis has taken into consideration the existence of roads to minimize the need to open new accesses to the pipeline and have considered sensitive areas to minimize impacts. Specific provisions for offsets are included in ODL?s environmental license. Offsets vary from 1 up to 7 times the size of the area of intervention, depending on the sensitivity of the site. For this reason the RoW has been kept as narrow as possible ranging from 30 meters to 10 meters in sensitive areas. The project received as part of the ESIA process a certification from the Ministry of the Interior (MI)that there were not Indigenous Peoples present in the project area of influence. However, in 2009 the group of Indigenous Peoples, Humapo opened a case against the MI, Minstry of Envrionment and Metapetroleum (who was the license holder) among others as the Humapo community consider that they should be granted the right to participate in a consultation process considering the proximity of the pipeline to their community. In 2011 the constitutional court ordered MI, Ministry of Environment, The mayors? office of Puerto Lopez, Incoder (Instituto Colombiano de Desarrollo Rural) and ODL to initiate the consultation process which was done in 2012. The consultation process resulted in partial agreements aiming at strengthening the cultural identity of the Humapo community. The agreements were documented and submitted to the constitutional court in June 2012 together with an outline of the areas where an agreement was not reached. The response from the constitutional court is still pending. OB: The pipeline runs parallel to an existing road (the national route Carretera Marginal de La Selva) and uses part of the existing ROW. The project lead to the improvement of 180 km of existing roads but did not require opening any new access roads. Although the pipeline route was selected to avoid highly sensitive ecological areas, and to mitigate impacts on epiphytes (including for instance orchids) a rescue program was developed and transplanted epiphytes will be monitored over a 3 year period. The pipeline crosses several rivers with the most important one being Rio Tigre en Arauca. All rivers were crossed underground and construction was done in the dry season to minimize potential impacts from flooding and all river crossings have subsequently been reinstated. Two communities were directly affected by the pipeline route and construction: San Antonio and Carrasto Bajo both located in Casanare. Impacts were temporary and limited to the construction corridor for the pipeline with no economic or physical displacement. OB has an effective contractors? management system which has resulted in very low levels of accidents and grievances during construction of the first phase of the OB pipeline. As part of the contractual agreement during the construction phase contractors followed the OB standards on OHS, labor standards, community engagement and E&S. Compliance was monitored on an ongoing basis by independent consultants (interventores) who were assigned to the contractors E&S teams and reported to OB management on a weekly basis. The same approach will be followed for the second and third phase of the pipeline construction when implemented. It has been certified by the Minister of Interior that the development and operation of infrastructure for OB has not affected any Indigenous Peoples. For the development of OBneighboring indigenous communities not located in the project area of influence were included in the general consultation process. PM will develop a consistent corporate Environmental and Social Impact Assessment (ESIA) procedure, according to GIIP, to ensure a comprehensive identification of environmental and social risks and impacts conforming to the requirements of the host country?s laws and regulations, as well as those of IFC?s Performance Standards for any new projects. Organizational Capacity PMs Management team is in the process of being developed and benefits from full support from the PRE environmental and social teams. PM will have a committed Environmental and Social Manager reporting to the CEO of PM with an adequate team of professional and financial resources? to implement the E&S Management Plan. The E&S Manager will be responsible for screening new proposed assets, monitoring the performance of portfolio projects and ensuring that the corporate E&S policy and procedures are fully implemented at the assets with majority PM ownership. In addition, as an integral component of the corporate ESHS-MS, PM will retain an external environmental and social advisory consulting firm (ESAC) with extensive and proven international experience applying IFC Performance Standards to help guide the construction phase of CL, the development of the corporate management system and future developments. The Management teams of PEL, CT, ODL and OB all have competent well-staffed teams to implement the E&S policies and procedures. PEL will ensure that the current and future assets with majority interest will have competent staff and adequate resources commensurate to the E&S risk of the project. Emergency Preparedness and Response PEL: PEL prepared a contingency plan for the 230-kV Chivor-Rubiales Transmission Line. This plan includes a risk analysis that identified potential events that could lead to an emergency incident along the transmission line and the substations. Potential events include natural (e.g., lightning, seismic, flooding, etc.) as well as events that could result from human actions or errors (e.g., terrorism, lack of maintenance, forest fires initiated by local practices, etc.). The contingency plan has identified the level of training and qualification required for brigade members, communication equipment, means of transportation, fire-fighting, first-aid and other pieces of equipment needed for proper response in the event of an emergency. In addition, the contingency plan also includes a list of civil defense, army, and local authorities from the various municipalities and towns located along the 260 km transmission line that need to be contacted during an emergency. Furthermore, in order to comply with conditions of the environmental licenses issued by ANLA, PEL will include provisions for potential contamination of surface water bodies (i.e., morichales) located near the Quifa Substation by potential accidental releases of oils. PEL is also required to conduct drills in coordination with municipal authorities and neighboring communities. It is also recommended that PEL include more site-specific details in the existing contingency plan, such as locations of the brigades and key emergency response equipment along the extension of the project. CT: For the offshore components the project has conducted risk analysis for the submarine pipeline, FSLU and FSU, riser platform and ancillary facilities and based on the assessment determined the mitigation measures as well as a contingency plan. Risk criteria used in the assessment included (i) anthropogenic, sociopolitical or cultural risks with potential impacts to human life; (ii) natural or environmental risks including earth quakes, hurricanes, electrical storms, etc.; and (iii) technical and/or operational risk. The contingency plan has been prepared and include minimization of risks or strategic planning, which will ensure that all emergencies are categorized and responded to in an adequate manner (emergencies are classified as tier 1, 2, and 3), as second component of the plan is an operational plan and the third component include a communication plan to employees as well as other stakeholders including communities in the vicinity of the project. The contingency plans allows for adaptation of the programs and activities resulting from the implementation and/or experience gained during their use. For the onshore pipeline, the project carried out a number of risk assessment studies, including Consequence Analyses and Layer of Protection Analysis to identify and mitigate risks associated with accidental event scenarios along the pipeline infrastructure. The primary cause of a major accidental event is statistically related to external interference with an active line (e.g. digging). Land practices reported along the pipeline easement are pasturing with limited agriculture, and the pipeline route corridor is sparsely populated, which reduce the likelihood of occurrence of external interference. Worst case scenarios were identified and quantified, including areas of greatest impact. The overall risk of a major leak triggering a major event (flash fire, jet fire and vapor cloud explosion) was considered low. Through implementation of GIIP mitigation measures included in the pipeline design, all residual risks were rated as acceptable or as low as reasonably practicable (ALARP). Mitigation measures include, among others, adequate thickness of the pipeline walls, depth of pipeline burial (>=1.5 m), increased burial depth at infrastructure crossing, adequate buffer in under crossing existing active pipelines, block valves and emergency shutdown system, and pipeline integrity monitoring through fiber optic sensing cables and operational procedures for intelligent pigging and line patrolling. Taking into account the proposed preferred route, the presence and location of existing active oil and petroleum product pipelines, the location of households and other public infrastructure in the project area of influence, the Company will review and update, as needed, the studies performed since 2012 and carry out a Quantitative Risk Assessment, with due consideration of pipeline detailed design at crossings with existing active lines and in sections where the proposed pipeline is parallel to other lines, to ensure that risks, including potential domino effects in case of an accident, are mitigated. A Contingency Plan, including emergency preparedness, operational and communication, has already been developed, as presented in the ESIA, and will be reviewed, made operational and kept up-to-date during the Project life. The ODL pipeline has emergency valves (shut-off valves) located every 35 kilometers and pressure indicators every 25 kilometers. A SCADA system monitors key factors (such as volume, pressure, temperature, and valve status) and different alarm systems give early warning to the SCADA controllers. The pipeline is protected from external corrosion by a cathodic protection system. ODL has an alliance with two other companies operating in the area, HOCOL and CEPCOLSA for emergency response and spill contingency plans. The shared spill contingency bases are located in Puerto Gaitan and Tauramena having a capacity of up to 15,000 barrels. Emergency drills are conducted on a yearly basis with the municipalities and the firefighters brigades. OB has emergency preparedness and response plans and oil spill contingency plans for the operational phase of the project. For communities within the area of influence of the pipeline OB has a cooperation with the Colombian Red Cross to implement community emergency response plans. Emergency drills are being conducted at the workplace (monthly), with local authorities and communities (twice a year) and at national level (yearly). For larger emergencies and spills OB has an agreement for support with Varichem an independent contractor with equipment that would support Tier I, II and III. Varichem has a strong presence in Colombia servicing 40% of the oil industry including Ecopetrol and PRE. As part of IFC?s investment, PM will review and update corporate-level procedures for emergency response and oil spill contingency plans including adequate training of employees and contractors to ensure consistent and effective implementation of corporate standards. Monitoring and Review PEL: As condition of the environmental licenses issued by ANLA, PEL prepared Environmental Compliance Reports (Informe de Cumplimiento Ambiental ? ICA) that were submitted to the ANLA every six months during the construction phase. During operations, the ICAs will be submitted on an annual basis. The ICA present results of all monitoring programs included in the Environmental Management Plan. CT: The ESMP includes a monitoring, inspection and audit program with key performance indicators (KPIs) to track construction and operational performance of the project against environmental, social, health, safety, security and quality criteria. Communities, including the IP and fishermen groups, will be given opportunity to work on monitoring activities in relation to impacts on flora, fauna, and other areas. Following approval of the environmental permit, the project will monitor marine conditions on a quarterly basis or as required by the license or regulations. In addition, as an integral component of the corporate ESMS, PM corporate staff will monitor E&S performance of future developments against ESIA based action plans, as well as established monitoring protocols and metrics (e.g. air emissions, air quality). The results of routine monitoring and measurement activities carried out at the project level, as well as any environmental or safety incidents will be recorded. In addition, PM will implement a formal E&S audit program to further ensure environment and safety performance for all its business activities. Non-conformances with established standards and metrics and the related corrective action recommendations will be recorded and tracked. Monitoring thresholds will be consistent with those referenced in the applicable IFC EHS Guidelines and Colombian environmental quality standards. Monthly, quarterly, and annual operations and environmental performance data will be consolidated into reports and made available to PM senior management. The results of E&S monitoring will be evaluated and documented at both individual sub-projects and corporate level. Reports will furnish the information and data needed to determine compliance with the corporate E&S Policy and ESMS. The format of these reports will include a summary of findings and recommendations. In addition, as an integral component of the corporate ESMS, PM will hire an independent ESAC (Environmental and Social Advisory Consulting Firm) with extensive and proven international experience applying IFC Performance Standards, that will closely supervise PM?s sub-project compliance with IFC PS, supervision focus will be on the construction phase of CT but the scope of the external monitor will depend on the risk profile of the assets. This supervision will include periodic site visits as well as documentation review, and the development of corrective action plans if any breaches are encountered during supervision activities.