Environmental and Social Policies. At Nidera, social and environmental responsibility is part of everything the Companies does. It is a combination of developing its activities in an ethical manner, treating peoples fairly, with dignity and respect, constructing stable relationships with its supply chain, preserving the environment, and assuming strong community engagement. In order to operationalize its corporate values of integrity, efficiency, commitment, respect and accountability, Nidera has adopted a series of corporate policies, procedures and programs under five pillars: 1) for its corporate governance, a Social Responsibility Policy, a Code of Conduct (under review in 2014) and an Employee Grievance Mechanism (under review in 2014); 2) for its direct and contractual employees, a Human Right Policy, a Human Rights Due diligence procedure and a corporate Workplace Health and Safety Policy; 3) for its value chain, Standards for business partners; 4) for the environment, a corporate Environmental Policy; and, 5) for communities neighboring its operations, a School of Values Program, a Talented Youth Program and a Rural Values Program. Nidera?s values, pillars, business principles, and policies fit into its integrated approach to CSR, which is based on acquired knowledge, experience, the recommendations of international standards, such as ISO 26000 and the OECD Guidelines for Multinational Enterprises, and the Global Reporting Initiative (GRI) Guidelines. The policies have been approved by Nidera?s Management Board and Supervisory Board in June 2011 and updated in January 2013. Performance based requirements of these policies commit Nidera toward compliance with legal regulations in countries of operations, as well as standards to which Nidera subscribes, including the IFC?s Performance Standards and the RTRS. In addition, plant-level?s environmental and occupational health and safety (EHS) policies have been subscribed by Nidera?s Argentina president as part of the ISO 14001 and OHSAS 18001 certification process. 

As mentioned above, the corporate Code of Conduct for its employees and the accompanying Employee Grievance Mechanism is currently being updated. It has been recently re-launch through two road shows, the first one held in Rotterdam targeting Nidera? senior managers in Europe, US and Asian operations, and the second held in Buenos Aires for Brazil, Uruguay, Paraguay and Argentinian senior managers. These documents have been recently endorsed by the Corporate Management Team. The updated Code of Conduct and grievance mechanism are already available in Nidera?s webpage and will be soon accessible on Nidera?s intranet and translated in 8 languages. Nidera has established in 2011 an internal CSR unit, advised by a CSR Action Committee in Rotterdam, which is identified in its corporate organogram and accountable for the effective implementation of the CSR?s corporate policies and annual action plan, including ensuring a communication strategy to all employees (specific CSR training reached more than 1,400 employees since Nov. 2011), suppliers and stakeholders through CSR training sessions, development and publication of Nidera?s Corporate Responsibility Report since 2011, including meeting newest Global Reporting Initiative 4 requirements (comprehensive GRI quantitative performance indicators). 

Environmental and Social Assessment and Management System. In accordance with applicable country and/or state legal and regulatory requirements, Nidera commissioned, as needed, the preparation of Environmental and Social Impact Assessment Reports for its industrial facilities (Argentina, Saforcada, PGSM, - crushing plants, Terfe Necochea ? unloading & fertilizer plant, Valentin  Alsina ? oil refinery plant; Brazil, castor oil & derivatives production plant and Canoas port terminal in Rio Grande do Sul), its seed facilities (Argentina, Venado Tuerto, La Ballenera and Chacabuco); and its elevators (Argentina: Victoria, Bayauca, Granda, Balcarce and Intendente Alvear). The main EHS impacts and risks associated with these facilities include mostly air emissions, effluents management, solid and hazardous waste management and OHS risks and nuisance to communities due to truck traffic. The port terminal operations also include impacts to aquatic species due to dredging activities and impacts to artisanal fishing, when it does exist. Samples of Environmental Certificates for Argentinean and Brazilian operations have been provided during appraisal, including ISO 1400 and OHSAS 18000 certificates of Santos Port terminal in Brazil. 

In addition to this plant-level EHS risk assessment and management process required by country/state requirements, Nidera demonstrated leadership in further formalizing its corporate policies commitment on environment and occupational health and safety and supporting procedures through the implementation of Integrated Environmental, Occupational Health and Safety, Social and Quality Management System in accordance with ISO 14001, OHSAS 18001, ISO 9001 standards and IFC?s Performance Standards, especially for its facilities representing the highest EHS risks, namely the industrial and seed facilities. In 2013, certification obtained included ISO 14001 and OHSAS 18001 for Nidera Argentina?s Seed Division (Venado Tuerto, La Ballenera, and Chacabuco), ISO 9001 and ISO14001 at Nidera?s elevator in Mercedes, TSCC certification for Nidera?s grain terminal in Ipswich and ISO 14001 certification for its trading, storage, and grain management operations; vessel loading and discharge activities, and its haulage fleet operations, which include a grain terminal in Ipswich and an elevator in Barmby Moor, Pocklington. In total, 9 ISO 14001 certifications have been granted so far at the following facilities: Venado Tuerto, La Ballenera, Chacabuco, Saforcada, and Valentin Alsina (all of which implemented IFC PSs requirements), Montevideo, Mercedes, and the Ipswich grain terminal elevator in Barmby Moor and Santos Port Terminal in Brazil; 4 OHSAS 18001 certifications in Venado Tuerto, La Ballenera, Chacabuco, and Valentin Alsina; 4 ISO 9001 certifications for quality management in Valentin Alsina, BOM, Montevideo, Mercedes, and Santos Port Terminal in Brazil; 1 ISO 22001 certification for Valetin Alsina; Dutch?s GMP + FSA certifications for food safety management for Saforcada and PGSM; 1 TASCC certification for Ipswich grain terminal. Copies of all these certifications have been provided during appraisal. Nidera plans to achieve ISO 14001 and OHSAS 18001 certification for PGSM in August 2014 while reaching OHSAS 18001 certification in 2016 for Saforcada. 
 
For its farm productions operations, Nidera has gained its membership with the Round Table on Responsible Soy (RTRS). The company met 96 out of the existing 98 requirements related to the RTRS?s five main principles, namely legal compliance and good business practices, responsible labor conditions, responsible community relations, environmental responsibility, and adequate farming practices. The company has presently more than 50,000 ha which are under its direct farming management control (through land lease). Out of these, more than 27,000ha are used for soybean cultivation which 13,000 ha are RTRS certified. Nidera is committed to progressively increase, on an annual basis, this certified production by 15-20%.  

Worthwhile to underline that Nidera received in 2011 financial support for its operations in Argentina from a Development Financial Institution (DFI) applying IFC?s Performance Standards and WBG EHS Guidelines. This explained the performance based reference to PS requirements in Nidera?s corporate and plant-level EHS management systems, including its corporate policies and procedures. E&S action plan?s items completed as of March 31, 2013 included, among others, i) full compliance with Argentinean?s EHS legislation and document registration, ii) Nidera and Argentinean plant-level EHS management systems, development of supporting EHS procedures, comprehensive EHS training and monitoring/reporting framework, including capturing IFC?s DOTS related indicators (OHS, water and energy efficiency) and worker and community grievance mechanism, etc. 

In Brazil Nidera operates mainly through third parties (regional cooperatives and small traders) assets in which they have long term contract but no management role. At its own facilities, Nidera manages EHS aspects of its operations seeking compliance with local legal requirements and based on their own experience. Going forward, as set forth in ESAP, Nidera will further develop and implement formal ESMS procedures applicable for all owned sites, commensurate with the level of the environmental and social risks and impacts, which may include, for example aspects/impacts and hazards/risks identification and gap analysis; internal reporting; training, workplace risk assessment, inspection and internal auditing; non compliance and deviation treatment; EHS monitoring; stakeholder communication and engagement. In addition, and for leased assets not related to purchase contracts, Nidera will also develop an EHS checklist for its long term partners covering main legal and regulatory requirements and, based on results, Nidera will rank and work with their long-term partners to improve EHS performance and reduce operational risk.

As part of its expansion program in Brazil, Nidera is/will be constructing several new plants, including warehouses and port terminals. As set forth in ESAP, while constructing these plants Nidera will include in EPC contracts provisions to ensure adherence to E&S requirements (EHS, Labor and Community), including those defined in EISAs and respective Environmental licenses and the right to audit EPC contractors (construction firms) concerned as part of daily business. 

EHS Management Programs. Nidera has demonstrated high-level management commitment to establish the foundation of a comprehensive corporate CSR agenda and an integrated environmental, OHS and social management system applying to its operations since the last three years with priorities defined on a risk-based approach (ref. targeting industrial facilities and seed processing plants). In addition to the corporate EHS policies mentioned above and the systematic risk identification and impact assessment at plant level (done through the national/state environmental assessment process and the ISO related management system), Nidera?s CSR and country-level EHS team has been developing management programs to ensure continuous EHS performance improvement. At CSR level, an annual action plan is developed and discussed with Nidera?s CEO and then reviewed and approved by Management Team and Supervisory Boards. For FY 2014, main action items on the CSR agenda was: i) update and re-launching the Code of Conduct and Grievance Mechanism, ii) undertaking a materiality sustainability analysis as required by GRI 4 (external consultant has been recruited to assess CSR risks and impacts of Nidera?s operations, ref. the scope of the analysis will include stakeholder dialogue and internal review of EHS reports (corporate and plant-level), iii) increasing global compliance with CSR policies and procedures in all countries of operations through CSR training, iv) supporting the rolling-out of the Standards for Business Partners (a two-pager document requesting all Nidera?s business partners to comply with applicable laws and regulations, respect human and labor rights throughout their own supply chains, and adopt appropriate E&S principles all along their own value chains). The principles and standards laid out in this document are based on those contained in the Nidera?s Social Responsibility Policy and its Code of Conduct applicable to its own employee. To date, more than 2,074 Nidera customers and suppliers worldwide have received this document and more than 62% returned a signed copy; v) completion of the EHS performance tracking at all operations (from 86% in 2013 to 100% in 2014) and strengthening EHS standardization monitoring program; vi) increase CSR training to all employees from a baseline of 45% in 2013. 

From a specific EHS standpoint, annual action plan agreed upon in 2014 was to i) standardize tracking of EHS indicators, with the objective in 2015 to establish EHS and resource efficiencies benchmark for similar type of plants; ii) strengthen implementation effectiveness of integrated EHS management at industrial and seed facilities through further capacity building of EHS officers and technicians; iii) further reduction of OHS incidents through OHS program to change worker behavioral change. 

In Brazil, on an operational level, Nidera has specific OHS mandatory programs such as workplace risk prevention plan (PPRA ? Programa de Preven??o de Riscos Ambientais, in Portuguese); Worker?s health and monitoring program (PCMSO ? Plano de Controle M?dico e Sa?de Ocupacional, in Portuguese), Emergency plans, Hazardous work procedure, including working at heights, confined spaces, working with heat and hazardous materials; machinery protection; Electrical systems safety, including explosive atmospheres and grounding. Going forward, as set forth in ESAP, Nidera will further develop OHS related programs such as Respiratory Protection Program (Programa de prote??o respirat?ria, in Portuguese), Hearing protection Program (Programa de prote??o Auditiva, in Portuguese) and Ergonomic Program (Programa de Ergonomia, in Portuguese). Nidera?s sites also have solid and hazardous wastes management program that includes proper segregation and disposal of wastes. 

Organizational structure and technical capacity. At corporate level, Nidera has established a five-member CSR team, that reports directly to the CEO (Chairman of the Corporate Management Team). This team is responsible for: i) developing and implementing CSR policies, ii) developing and implementing Nidera?s annual CSR action plan, as outlined above, iii) coordinating CSR activities at all international locations and monitoring their implementation, carrying out CSR reporting to management and external stakeholders, including quarterly progress report on the company?s CSR Action Plan and main achievement and priorities. In addition, 15 CSR coordinators work with Nidera?s offices worldwide in raising awareness about Nidera?s corporate EHS policies. Finally, a CSR Action Committee and local representatives in key facilities actively participates in the design, development, launch, and implementation of CSR initiatives and programs. 

In Argentina and Brazil, where existence of industrial operations represent the highest EHS risks, Nidera has established two positions of EHS managers in its country-level organogram. Specifically, in Argentina, Mr. Julio Ruffa reports to the General Industrial Director (Mr. Alejandro Figueroa) who reports to the Country Manager (Mr. Jorge Correa), and Marcos Pepe Bertoni who has shared responsibilities as new project manager and EHS. All seed and industrial facilities in Argentina have EHS professionals (industrial facilities) and technicians (seed plants) in charge who report directly to the plant managers and the EHS manager. The EHS coordinators in the elevators are the plant managers given their small organizational structure. These report EHS issues, if any, to the country-level EHS manager. In Brazil, seed facilities have a Quality & EHS manager (Ms. Luciana Apparecida Marques) who reports directly to the Global Operations Director (Mr. Hernan Forte) who is part of the Seed Global Management Board. Reporting to the EHS manager is an OHS engineer (Mr. Marcelo Pires) who has OHS oversight of the two seed plants (Patos de Minas and Cristalina). All associated EHS issues in seed facilities are being directly reported by the plant managers to the OHS engineer. Elevators in Brazil have EHS coordinators reporting directly to plant managers and OHS coordinator (Mr. Leandro Neves), who reports directly to a project manager (Mr. Marcos Pepe Bertoni) whom reports directly to the Country Manager (Mr. Brandon Scott). EHS committees exist in all industrial and seed plants, as per legal, ISO 14001 and OHSAS 18001 requirements. Going forward, as set forth in ESAP, Nidera will hire a dedicated Corporate Social Responsibility / Sustainability Officer for Brazil, full-time functioning, within Nidera?s (corporate) CSR team and organization, among others consolidating and coordinating EHS, CSR, sustainable soy production and supply chain management under its direct responsibility. 

Training. Training employees is an integral part of Nidera in order to manage OHS risks, its environmental impacts and good stewardship of natural resources. At corporate-level, more than 1,400 employees (45% of Nidera?s global workforce) have followed the CRS training program which focused on Nidera values and corporate EHS policies and procedures. To date, Nidera has provided a total of 186 hours of employee CSR training. In order to reduce accidents at its operations, employees at 80% of Nidera?s industrial facilities and at 60% of its seed facilities were given 50% more hours on health, safety and environmental training during 2013 than in 2012. Main topics covered in the training session were: use of personal protection equipment, safety for employees working at heights, general overview of environmental management system concepts and IFC Performance Standards, squad training, forklift handling, operating procedures, use of fire extinguishers and how to respond to different types of fires, hygiene, safety and environmental laws, identification, handling and control of hazardous materials, hand and respiratory protection, communications procedures and incident-investigation procedures and behavior-based management. 

Finally, as more than 400 employees used Nidera?s Argentina?s fleet of 287 vehicles on a regular basis during the course of their work, driver training workshop have been provided, in cooperation with the Argentine Center for Experimentation and Road Safety (CESVI). In addition, using in-house surveys on employee?s driving skills, results of these were used to plan multimedia safety activities focusing on the perils of driver distraction. Significant reduction of number of road accidents suffered by Nidera employees per 100 vehicles over the last three years is noticeable.  

In Brazil, Nidera has mandatory EHS induction for all staff and contractor?s before starting to work at its facilities. Nidera provides mandatory EHS training for its staff (e.g. working at heights, working in confined spaces, machinery operators, safety in electrical systems, etc.) as well as requires certificate of completion from contractor?s staff. As set forth in the ESAP, Nidera will further develop OHS related programs for its on-site and field staff in Brazil. 

Monitoring and Reporting. Since 2011, Nidera has significantly consolidated its corporate and country monitoring and reporting framework. From a corporate and Argentinean standpoint, Nidera has completed in September 2013 its fourth annual Corporate Responsibility Report following the Global Reporting Initiative (GRI) guidelines. Its corporate report has achieved first position in the ?trading companies? category based on the Dutch ?Transparency Benchmark?. Nidera Argentina received a Good Corporate Citizen Award from the U.S. Chamber of Commerce in Argentina for being one of the country?s top 10 corporate sustainability leaders. Building on this reporting, Nidera has strengthened in 2013 the standardization of environmental indicators for energy and water consumption and waste output at all 28 of the seed facilities, elevators, and industrial facilities located globally that are wholly owned or controlled by Nidera. Employees at 10 of these facilities (36%) were trained how to properly implement standardized measurement procedures for the company?s environmental performance. Standardization of EHS indicators have paved the way for the eventual development of Key Performance Indicators (KPIs) that will enable Nidera to establish clear resource efficiency goals for reducing the environmental impact of its operations worldwide. Specifically, Nidera? standardization program has allowed to release environmental impact statements for 24 operational units (86%) in 2013. Data on absolute and relative water and energy consumption, hazardous and solid waste, and effluents volume have been shared with IFC for Saforcada? crushing plant, the seed facilities and elevators in Argentina. Resource efficiency benchmarks (KPIs) for water and energy consumption have been established in 2014 for Valentin Alsina (crude oil refinery). These are within the benchmark required by the WBG?s EHS guidelines (ref. Table 3 on Resource and Energy Consumption in the sector specific Guidelines for Vegetable Oil production and processing). Nidera?s operations are also audited by end-customers (e.g. Nestle and Walt-Mart) for current status of its legal compliance and overall EHS performance.  Based on information provided during appraisal, Nidera did not incur over the last two years any material regulatory penalties, fines or sanctions for contraventions or non-compliance with statutory obligations. Two fatalities (January 2012 and May 2013) have been reported respectively at its operations at Venado Tuerto?s seed facility and at PGSM crushing plant.  

In Brazil Nidera reports internally meaningful EHS performance indicators, such as OHS accident rates and severity, water and energy consumption, wastes volumes and disposal, air emissions from grain dryers and labor ergonomics.

Emergency Preparedness and Response. All industrial and seed facilities in Argentina and Brazil have developed and implemented an Emergency Preparedness Plan, in accordance with local OHS legal standards and OHSAS 18001 requirements, which cover risks due to fire and explosion as well numerous other dangers (e.g. CCP spill at seed facilities). From a normative standpoint, Nidera? crushing operations (PGSM and Saforcada) are required to meet the National (Argentinean) Fire Protection Standard (re. NFPA 36) specifically applying for industrial plants using hexane in chemical oil extraction. Verification of compliance with NFPA 36 is undertaken by insurance company while local fire authorities approved fire prevention and fighting system for the other plants. Fire brigades exist at all plants and for the crushing plants, each member of the fire brigade received specialized training from the ?Centro Argentina de lucha contra incendio?. As mentioned above (see training section under PS1), use of fire extinguishers and how to respond to different types of fires is included within the annual EHS training curriculum of all workers. Fire drill also takes place bi-annually. 

Stakeholder Engagement Plan. Aside from the consultation process inherent in the preparation of EIS Studies with surrounding communities, Nidera?s industrial and seed operations are located in industrial areas with no surroundings communities. Same applies for its farming operations under its direct control. As such, due to this limited interface, Nidera has not developed a comprehensive stakeholder engagement plan for its operations. This being said, Nidera has established a "Nidera Channel" (http://www.canalnidera.kpmg.com.ar/) which is a company-wide grievance mechanism following the recommendations of the OECD?s Guidelines for Multinational Enterprises. In Argentina, they have also developed a Community Grievance Procedure, mainly for their facilities and their RTRS soybean certification process. In addition, every year, following the official release of its CSR, Nidera undertakes structured consultation with key stakeholders through dialogues and surveys. A guideline for stakeholder dialogue was shared with IFC during appraisal. Main recommendations from this consultation process are outlined in the CSR. This overall process ensures Nidera to improve its EHS accountability and quality of reporting process. IFC appraisal findings considered that the overall stakeholder engagement demonstrated by Nidera has thus far been appropriate considering the risks and impacts of its operations, including identification of stakeholders, determination of level of interest and influence (by importance and relevance), establishment of appropriate methods for engaging each group, and identifying strategic and forward looking programs and activities to support and partner with affected communities.