Environmental and Social Policies: Since its split from Noble Group, Noble Agri has been re-designing its sustainability vision, principles and strategy so as to ensure it is tailored to an agriculture company. Specifically, its sustainability approach is driven by the following principles: i) contribute to global food security and safety by optimizing production and efficiency; ii) respect human rights, provide safe and productive work conditions for its staff; iii) measure, communicate and pro-actively reduce its environmental impacts; iv) contribute to the economic and social development of communities, to develop the capacity and resilience of suppliers and smallholder farmers; v) cultivate partnerships through collaboration and transparency with key stakeholders to further develop shared goals. These principles have been translated into corporate-level policies (environment, occupational health and safety – including life and fire safety and emergency preparedness plan and response, human (labor) rights policy, stakeholder engagement and community grievance mechanism policy, sustainable sourcing policy, and responsible land acquisition and leasing policy. These updated policies have incorporated the principles and requirements of national legal and regulatory requirements, IFC Performance Standards and Voluntary Agro-Commodity Standards (e.g. Bonsucro, RTRS). Noble Agri’s Board of Directors approved these corporate policies on October 13, 2015. Since their approval, these policies have been translated into five languages and are in the process of being communicated to its stakeholders, including its employees, contractors and consultants. These policies have been disclosed on Noble Agri website (http://www.nobleagri.com) on December 20, 2015. Appropriate training will be conducted over the next months to ensure that all stakeholders are aware of these policies and supporting procedures to promote effective and timely implementation. Copies of the EHSS policies will be shared with every new employee at the time of hiring and through induction training. Specific operationally-based QEHS policies have been adopted at numerous operations, as part of ISO 9001, ISO 14001, OHSAS 18001, and HACCP/ISO 22000 management system preparation and certification process.Noble Agri is signatory to the UN Global Compact since 2008, the Carbon Disclosure Project since 2010 (as part of the Noble Group, Noble Agri achieved the “Best Climate Disclosure Score” for the last 2 years), pro-actively participated in sustainable/responsible sourcing initiatives in coffee (Rainforest Alliance, 4C, Organic, UTZ and responsible sourcing code with all coffee suppliers worldwide), sugar (Bonsucro certification at one of its sugar mill) and is member of the Roundtable on Responsible Soy (RTRS) and the Soy Moratorium. Going forward, and as set forth in the Environmental and Social Action Plan (ESAP), Noble Agri will provide supporting evidence of its EHS policies communication across Noble Agri operations, including its employees, contractors and consultants. Environmental and Social Assessment: Noble Agri’s identification of environmental and social risks and impacts is defined by nationally and locally applicable environmental and social assessment regulatory requirements. Since IFC’s investment in October 2014, Noble Agri also follows IFC’s Performance Standards requirements in its EHS risk assessment and management process. For example, in Brazil and China, Noble Agri identifies risks and impacts associated with its operations that include both normal operations and those from non-routine or emergency situations. For example, risks and impact assessments have included hexane used in soybean oil extraction, ethanol storage and transport, air emissions, effluents, and solids waste generation. OHS risk assessments are included as part of the Risk Prevention Plan (e.g. Plano de Prevenção de Riscos Ambientais – PPRA in Brazil). While greenfield developments are typically required to complete a full environmental and social impact assessment (ESIA) process according to Chinese and Brazilian environmental licensing requirements, the extent of assessment requirements applicable to the expansion of existing plants can range from a full ESIA to a more simplified Rapid Environmental Assessment, depending on the nature of the expansion, its potential E&S impacts, and the judgment of the local environmental authority. Noble Agri has completed both. For example, a full ESIA was undertaken for its Sugar Mill in Meridiano as well as for its soy crushing and combined Biodiesel facilities in Rondonópolis (Brazil) and Timbues (Argentina); Rapid Impact Assessments were completed for Votuporanga and Catanduva Mills expansions (Brazil). Completion of a full ESIA for its soybean crushing plants in China (Qinzhou and Fuling) also took place and was validated in a recent IFC supervision. In Brazil, the suitability of land for the production of various crops, and specifically for sugarcane production, is assessed following Brazil’s CTC (Centro de Tecnologia Cana) framework, which includes soil type and fertility, erosion risk, topography, rain fall, sun light, temperature, and other factors which determine sugarcane productivity. Noble Agri has recently developed a comprehensive questionnaire for early EHS risk screening of its processing and plantation operations. Going forward, and as set forth in the ESAP, Noble Agri will develop and implement a corporate level procedure for the assessment of environmental and social impacts, applicable to any future expansion of commodity sourcing, own plantations, processing facilities, and logistics activities. This practice will refer to applicable country-level legal and regulatory requirements, the IFC Performance Standards and Voluntary Agro-Commodity Standards (e.g. RTRS, Bonsucro, Rainforest Alliance, BCI). For existing assets or those to be acquired over time, the assessment process will consist of an audit of operations against applicable national laws and regulations, IFC’s Performance Standards requirements and relevant requirements of the World Bank Group’s general and sector-based Environmental, Health and Safety (EHS) Guidelines (e.g. annual crop production, perennial crop production (sugar), sugar manufacturing and vegetable oil production and processing). Noble Agri’s grains and oilseed operations maintain a legal and regulatory registry in order to pro-actively and timely ensure permit and license renewal process. This practice will be expanded to all 39 Noble Agri operational units in the near future. Environmental and Social Management Programs: Noble Agri’s management programs are defined at the corporate, regional or local level depending on a number of factors which include size and structure and type of operating activity of the respective business lines (mainly grains and oilseeds – G&O, and sugar). Regional management programs for environmental, health, and safety (EHS) are complemented by locally defined or plant level requirements. For example, the sugar cane mills in Brazil as well as the soybean crushing plants in China have detailed, plant-specific, EHS plans and procedures whose scope is defined in the ESIAs during the environmental licensing phase and which consists of E&S management programs spelling out prevention, control, mitigation, and monitoring requirements for each of the identified impacts (e.g. in Brazil, this E&S management program is referred to as PBA, or Plano Básico de Ação in Portuguese). These plans include aspects related to both construction and operational phases of these facilities. The agriculture division from sugarcane mills also has an annual sugarcane plantation and harvesting management program that includes specific procedures for soil conservation, use of fertilizers and integrated pest management program. In Brazil and Argentina, similar programs have been developed to cover occupational health and safety (OHS) aspects, as further described in the respective section below under PS2, Labor and Working Conditions. As a matter of corporate policy commitment, Noble Agri attempts to pursue applicable industry certifications of owned assets including in many cases specific environmental, health, safety and social (EHSS) management plans and procedures. Below is a list of EHSS certifications currently held by Noble Agri’s assets and subsidiaries: Commodity Asset Country Asset Type Current Certification Coffee Casa Nobre Coffee Processing and Storage Facility, Alfenas, Minas Gerais Brazil Processing Facility, Storage Facility TN-CC 020, ISO 14064 Sugar & Ethanol Catanduva Sugar Mill and Ethanol Production Facility Brazil Processing Facility Ethanol Verde, Labour Cert., ISO 14064 Sugar & Ethanol Meridiano Sugar Mill and Ethanol Production Facility Brazil Processing Facility Ethanol Verde, Labour Cert., ISO 14064 Sugar & Ethanol Potirendaba Sugar Mill and Ethanol Production Facility Brazil Processing Facility Ethanol Verde, Labour Cert., ISO 14064 Sugar & Ethanol Votuporanga Sugar Mill and Ethanol Production Facility Brazil Processing Facility Ethanol Verde, Labour Cert., ISO 14064 Sugar Santos, Dry Bulk Export Terminal Brazil Port ISO 14001, ISO 9001, OHSAS 18001, OCP 0044, Vessels Oil Spill Emergency Plan, ISO 14064, US FDA Grains & Oilseeds Jordan Grain Handling Co. (JOGCO), Amman Jordan Storage Facility GIPSA, GAFTA, ISO 14064 Grains & Oilseeds Fuling Oilseed Processing Complex China Processing Facility HACCP, ISO 9001, ISO 14001, ISO 14064 Grains & Oilseeds Timbúes Oilseed processing facility,River Port Grain Terminal & Biodiesel Production Plant Argentina Harbor Terminal & Processing Facility GMP+ B2 (includes guidelines HACCP+ISO 9001), ISO 14001, OSHAS 18001, 2BSvs, RFS2 individual scheme (EPA), ISO 14064, US FDA, KOSHER. Grains & Oilseeds Longkou Shandong Oilseed Processing Complex China Processing Facility HACCP, ISO 14064 Grains & Oilseeds Mingfa Taixing China Processing Facility HACCP, ISO 14064 Grains & Oilseeds Qinzhou Oilseed Processing Complex China Processing Facility HACCP, ISO 14064 Grains & Oilseeds Nantong Oilseed Processing Complex China Processing Facility HACCP, ISO 9001, ISO1 7025, ISO 14064 Grains & Oilseeds Terminal Graneleras Uruguayas (TGU) Uruguay Port ISO 9001, ISO 14064 Animal Feedstuffs Noble Resources South Africa (Pty) Ltd South Africa Business Entity AFMA, ISO 14064 Grains and Oilseeds Corpus Christi silos Paraguay Storage Facility 2BSvs; ISO 14064 Grains and Oilseeds Katuete silos Paraguay Storage Facility 2BSvs; ISO 14064 Grains and Oilseeds La Paloma silos Paraguay Storage Facility 2BSvs; ISO 14064 Grains and Oilseeds Maganini silos Paraguay Storage Facility 2BSvs: ISO 14064 Grains and Oilsseds Troncal 3 silos Paraguay Storage Facility 2BSvs: ISO 14064 Going forward, and as set forth in the ESAP, in order to ensure greater consistency of its EHS performance-based requirements and management practices across its business lines and its operations, Noble Agri will develop and implement a corporate Environmental, Health and Safety, and Social (EHSS) Management System (MS) in accordance with IFC PS1 – and consistent with ISO 14001 and OHSAS 18001, applicable to the development, construction and operational phases of business activities globally. The EHSS Management System shall include EHSS management plans and procedures applicable to the company’s business activities in order to comply with applicable national laws and regulations, IFC’s Performance Standards requirements and applicable WBG’s general and sector-specific Environmental, Health and Safety (EHS) Guidelines. The new global EHSS plans and procedures shall be communicated to all company operations, including employees, contractors and consultants. Noble Agri shall make available supporting evidence of complete and effective implementation of the EHSS Management System (MS) at the regional, country, and local operational level (e.g. final documentation of the EHSS MS, including policies, plans, manual of procedures and programs, e.g. training logs, monitoring records, minutes of progress reviews). Noble Agri’s G&O division is scheduled to launch an internal ISO 14001 and OHSAS 18001 audit for all its soybean crushing plants and oil refineries in Asia (China), India, Central Europe and South Africa in December 2015. Findings and corrective actions will be available by March 2016. Organizational structure and management capacity: Accountability of sustainability and EHS issues in Noble Agri is managed, at the corporate level, by two recently hired co-Directors who are leading the grains and oilseeds (or G&O, Mr. Kevin Brassington) and sugar (Mr. Marcelo de Andrade) business lines. These co-Directors report directly to Noble Agri CEO (Matt Jansen) who has been recruited in May 2015. The company has nominated a number of thematic champions to support the effective and timely implementation of Noble Agri’s EHS Policies and procedures. In September 2015, Noble Agri formalized the establishment of a corporate sustainable/EHS team consisting of three professionals and strengthened the EHS accountability for the existing three Regional Technical Directors for the G&O Division, and Commodity E&S Coordinators for coffee, sugar and cotton. Noble Agri recruited in November 2015 (as specified in the ESAP of #34738), a Sustainability Manager for Latin America. At the plant-level, EHS managers and/or coordinators are officially assigned and explicitly identified in the plant organigram. For example, the Noble Bioenergy division in Brazil has an EHS manager that is also supporting soy operations in Latin America and who is further supported by the following typical arrangement: Environmental Monitoring is under the responsibility of quality assurance (QA); OHS management is part of the Human Resources (HR) department; and the management of environmental control equipment/ facilities is under the responsibility of plant or site operations. The sugar mills operations in Brazil have a dedicated environmental analyst and a team of OHS professionals (OHS engineers, OHS technicians, doctors and nurses) reporting to the Environmental and OHS Coordinators respectively. The same structure was seen in operation at the two soybean crushing facilities in China. Training: The definition of EHS training requirements takes place at the regional and local level and depends on the structure and nature of the operations as well as being responsive to local regulatory requirements. For example, Noble’s operations in Brazil and China have structured annual training programs that include an EHS induction for new employee’s (and contractors), as well as specific trainings, as needed for the job in industrial or field operations, such as obligatory safety precautions (e.g. working in heights, working in confined spaces), emergency and fire drills, machine operators, boiler operators, pesticides use and handling, vinasse irrigation, and general environmental best practices, among others. Going forward, and as set forth in the ESAP, Noble Agri will develop and implement a management system procedure and provide evidence of the implementation of the staff training, at corporate (and for each business lines, e.g. G&O, sugar, and supply chain) and plant-level, including mainstreaming into corporate, business line and plant-level training manual, addressing the company’s EHSS and Sustainability Sourcing policies, IFC’s PS requirements (direct operations and supply chain) and WBG’s EHS Guidelines (for direct operations). Monitoring and Reporting: EHS monitoring, internal, and external reporting practices at Noble Agri are defined by the respective business units at the global, regional, and local levels and depend on the respective business unit practice defined by experience and local regulatory requirements. For example, within the G&O Division, Noble Agri monitors key performance indicators (KPIs) pertaining to OHS matters of its employees and contractors, such as Medical Aid Frequency Rate, Lost-Time Injury Frequency Rates, Accident Severity Rate, Decreasing Failure Rate, Safety Index, and Fatalities at all its operations. The G&O Division also monitors training hours and overall safety performance of each site which are recorded in a monthly operational safety report compiled for the whole G&O Division. Brazilian operations are further monitored to comply with local regulatory requirements such as work related injuries, air emissions, watershed quality, field application of vinasse wastewater, pesticides consumption, water consumption and solid wastes generation and disposal. In the State of Sao Paulo, Brazil, the sugar mills report indicators defined by state environmental regulator CETESB (Companhia de Tecnologia de Saneamento Ambiental) and federal environmental regulator IBAMA (Instituto Brasileiro de Meio Ambiente), on an annual basis. Brazilian soy crushing facilities and combined biodiesel plants also have their own EHS monitoring plans, which include air emissions and wastewater monitoring, OHS accident and severity rates, waste production and disposal, and environmental noise monitoring. OHS exposure to hazardous agents such as noise, dust and heat is also monitored at all sites. Noble Agri also has an OHS health monitoring program (PCMSO – Plano Medico de Controle da Saúde Ocupacional) that includes periodic clinical assessment as well as specific tests and exams such as audiometry, eye testing, blood pressure, diabetes, urine and blood testing for specific chemical contamination indicators. Environmental data collected at all owned facilities include energy consumption, including carbon emissions, water consumption, waste generation and management and characterization of wastewater effluents before and after on-site treatment. Such baseline data have allowed some facilities and port terminals (16 out of the 39 facilities) to establish environmental and/or resource efficiency targets for electricity, steam, natural gas, water, and hexane consumption. As an example, for its sugar mills, Noble Agri has set a target to consume 0.7 tons of water consumption per ton of sugar processed, which is within industry benchmark as defined under WBG’s EHS guidelines for sugar manufacturing. Carbon intensity has also been monitored at all facilities for the last 5 years. Noble Agri’s facilities are subject to various third party certifications (previously summarized in this report) and are further audited as part of the certification renewal process. As part of the ESAP requirements of the IFC equity investment in October 2014 (#34738), Noble Agri undertook a gap analysis of its existing KPIs monitoring system and began expanding them for each facility, including establishing key KPIs that would help enhance its overall EHSS management, monitoring and performance. Further standardization and formalization of environmental KPIs (carbon, water, energy, wastewater and air emissions) and safety KPIs, such as retention and training, at all Noble Agri facilities are planned. As set forth in the ESAP, Noble Agri will, for its direct operations (e.g. plantations and processing facilities), continue to review and expand its existing Key Performance Indicators (KPIs) to mainstream EHSS parameters, including a) Safety – Lost Time Incidence Frequency Rate (LTIFR - Number of injuries per million of hours worked); Accident Free Days ( Number of Days since last Lost Time Incident); b) Sustainability – Carbon (kg/ton - CO2 emitted / tons produced); Water Usage (kiloliters/ton) and Efficiency - Consumed versus tons produced; Energy Usage (kWh/ton) - Energy consumed/tons produced; Wastewater monitoring effluents and air emissions parameters (including VOC); c) Staff - Retention - Number of full time equivalents leaving in the period /Avg. full time equivalents - and Training days - Number of training days provided to new and existing employees. Noble Agri will further prepare an integrated annual EHSS report format based on critical EHSS KPIs (e.g. compliance with legal and regulatory requirements, EHSS management system progress report and audit covering aspects such as facility and commodity certification initiatives; energy and water consumption and efficiency; air emissions (NOx, SOx, particulates), including GHG emissions; noise levels and management, solid and hazardous waste management and disposal, effluent discharges from on-site WWT unit, compliance with national OHS requirements, including accident rates (lost-time accidents); customers complaints, supplier performance and community engagement activities). A summary of the EHSS report shall be publicly disclosed annually following a format equivalent to the Global Reporting Initiative (GRI). Noble Agri commit itself to report its Sustainability/EHS performance using the Global Reporting Initiative (GRI) G4 Guidelines by June 2017 and to disclose its report on its website (http://www.nobleagri.com/en/). Emergency Preparedness and Response. Noble Agri has updated a corporate Plant Emergency Preparedness Policy and Procedures which has been implemented at all its industrial facilities having fire and explosion risks. As an example, from a normative standpoint, Noble Agri’s crushing operations in Argentina are required to meet the National Fire Protection Standards (NFPA, #36) specifically applying to industrial plants using hexane in chemical oil extraction. Verification of compliance with NFPA is undertaken by insurance company while local fire authorities approve fire prevention and fighting systems for the other plants. In Brazil, Noble Agri sites have obtained the required emergency response plans covering scenarios of typically applicable emergency situations such as fires, explosions, and leaks to the environment as well as fire brigade, evacuation and communication plan. During the recent supervision of Noble Agri’s soy crushing facilities in Qinzhou and Fuling in China, IFC confirmed the effective implementation of such policy and procedures. Fire brigades exist at all plants and for the sugar and soybean crushing plants; each member of the fire brigade has received specialized training from local fire authorities, including quarterly internal fire drills and annual joint fire drills with local authorities. 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 of all workers. During recent IFC supervision at Noble Agri soy crushing plants in China, verification of effective implementation of the hexane storage, boiler operations, and thermal oil heaters and vaporizers, including 47 safety critical instruments, has been validated. Stakeholder Engagement Plan. The consultation process inherent in the preparation of ESIA Studies include interaction with surrounding communities. As an example, new project developments have to be disclosed in public hearings and ESIA reports, following Brazilian and Argentinean licensing procedures. In general, however, Noble Agri’s industrial operations are located in industrial areas and/or port terminals with no immediate surrounding communities. As such, due to this limited interface, Noble Agri has yet to develop a comprehensive stakeholder engagement plan for all its operations. A community grievance mechanism has been fully operational in Brazil since August 2013 and will shortly be expanded to Colombia (http://www.ouvidorianoblebrasil.com.br). In order to harmonize such mechanism across all countries of operations, and in accordance with ESAP under #34738, Noble Agri has adopted in October 2015 a Stakeholder Engagement and Community Grievance Mechanism Policy. The procedures for the effective implementation of this policy are presently under development and will consist of the development of a Stakeholder Engagement Plan (only for the sites having exposure to surrounding communities) and a dedicated community grievance mechanism through a dedicated platform (http://www.navexglobal.com/) scheduled to be available online by August 2016.