Environmental and Social Assessment According to the IFC ... - EKN

Environmental and Social AssessmentAccording to the IFC PerformanceStandards and EHS GuidelinesEldorado BrasilReference: 0152083www.erm.comDelivering sustainable solutions in a more competitive world

TABLE OF CONTENTS1 PROJECT SUMMARY 21.1 INTRODUCTION 21.2 OVERVIEW OF THE PROJECT 21.3 METHODOLOGY OF ASSESSMENT 191.4 LIMITATIONS AND EXCEPTIONS 251.5 USE OF THIS REPORT 262 ENVIRONMENTAL AND SOCIAL BASELINE FOR THE PROJECT 263 DESCRIPTION OF COMPANY, ACTIVITIES AND PROJECT 383.1 OVERVIEW OF INDUSTRIAL SITE AND CURRENT STATUS 403.2 OVERVIEW OF FORESTRY OPERATIONS AND CURRENT STATUS 493.3 OVERVIEW OF THE LOGISTICS PROJECT 533.4 ENVIRONMENTAL LICENSING PROCESS 573.5 FOREST CERTIFICATION AND SOCIAL PROGRAMS 594 PROJECT CATEGORIZATION AND APPLICABLE IFC PERFORMANCESTANDARDS 754.1 BACKGROUND TO CATEGORIZATION 754.2 BASIS FOR CATEGORIZATION 764.3 APPLICABLE IFC PERFORMANCE STANDARDS 764.4 ALIGNMENT WITH EQUATOR PRINCIPLES 775 BENCHMARK OF THE PROJECT - ALIGNMENT WITH BRAZILIANLEGAL REQUIREMENTS AND IFC PERFORMANCE STANDARDS 806 FINAL OBSERVATIONS AND RECOMMENDATION 108ANNEX AANNEX BANNEX CANNEX DANNEX EANNEX FLIST OF DOCUMENTS REVIEWED AND PERSONS INTERVIEWEDBRAZILIAN ENVIRONMENTAL LICENSING PROCESS DESCRIPTIONGAP ANALYSIS TABLE – PULP AND PAPER INDUSTRIAL PROJECTGAP ANALYSIS TABLE – FORESTRY OPERATIONSGAP ANALYSIS TABLE – LOGISTICS PROJECTPHOTOLOGENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012

1 PROJECT SUMMARY1.1 INTRODUCTIONERM Brazil Ltda. (ERM) was commissioned by ELDORADO BRASIL(ELDORADO) to perform a Social and Environmental Assessment of its pulpand paper plant project that is being installed in Três Lagoas, State of MatoGrosso do Sul/Brazil and logistics operations destined to the transportation ofpulp produced in the industrial complex under construction, until the port ofSantos in the State of São Paulo, with the objective of providing technicalinformation for the financing process with FINNVERA, EKN and OeKB.The assessment was based on the Equator Principles and the Environmental andSocial Performance Standards – PS, as well as the Environmental Health and Safety- EHS Guidelines, both from the International Finance Corporation – IFC.1.2 OVERVIEW OF THE PROJECTELDORADO BRASIL is engaged in the production of pulp and paper, beingone of the major global players in this sector. It is composed of the followingassets/activities: industrial, forest and logistics. The main characteristics ofeach one are: Industrial site: the industrial complex is being installed in Três Lagoas,State of Mato Grosso do Sul. The startup is estimated as November/2012and the total installed capacity will be 4.5 MM tons, divided into 3 (three)lines: Line 1: 1.5 MM tons (2012); Line 2: 1.5 MM tons (2017); and Line 3: 1.5 MM tons (2021).The industrial production will be based on the Kraft process and on theconcept of having the BAT – Best Available Technology. The industrialprocess is described in Section 3.1.The workforce in the industrial project is currently composed by: Employees directly hired by ELDORADO: 186 (36 women and 150 men); Contractors (workers engaged by third parties, who are performing workfor the construction phase of the project): 7,750 (total workers, estimated),out of which approximately 6,195 are workers that are not originally fromENVIRONMENTAL RESOURCES MANAGEMENT 2ELDORADO - APRIL, 2012

the area.Figure 1.1 shows the industrial site location and layout.ENVIRONMENTAL RESOURCES MANAGEMENT 3ELDORADO - APRIL, 2012

Figure 1.1Industrial Site Location and LayoutENVIRONMENTAL RESOURCES MANAGEMENT 4ELDORADO - APRIL, 2012

NWSWNWSWNESENESEBRASILNWNNEEWNSEWSWSSEAcreAmazonasRondôniaParáMato GrossoMaranhãoPiauíTocantinsBahiaCearáRNPBPEALSergipeGoiásMinas GeraisMato Grossodo SulSão PauloRio de JaneiroParanáRio Grandedo SulSta. CatarinaMATO GROSSO DO SUL NWES SOURCE:Google Earth Pro - 2004.0 150 300 450kmSCALE 1:15.000kmCLIENTEldorado BrasilPROJECTEnvironmental and Social Assessment of Industrial,Forest and Logistics Projects, According to the IFCPerformance Standards and EHS GuidelinesDESCRIPTIONIndustrial Plant LocationEDITION CONTROLTHIS DOCUMENT IS PROPERTY OFERM BRASIL LTDA. AND CANNOT BE COPIED,04/19/2012 04/19/2012 REPRODUCED OR TRANSMITTED BY ANY OTHEREDITION REVISIONMEANS, OR USED FOR PURPOSES DIFFERENTOF THOSE FOR WHICH IT WAS DONE.WORK ORDER0152083FIGURE / ANNEXFIGURE 1.1EDITOR / DESIGNERCARLOS ROBERTOTECHNICAL RESPONSABLELEONARDO GONÇALVES0152083-1-Plant LoCIPSIZE A3 - FRAME 386 x 279 mm

Forestry Operations: currently covers 134 farms, of which approximately10% is owned by ELDORADO, and 90% belongs to third party companieswith whom ELDORADO has established leasing contracts or partnershiparrangements. The total managed area will be:2012: 137,000 hectares;2017: 361,000 hectares; and2021: 413,000 hectares.Currently, the planted area corresponds to 80,000 hectares (December, 2011)and an estimated 26,000 hectares will be planted annually.The workforce in the Forestry Operations is composed of: Employees directly hired by ELDORADO: 1,515 (327 women and 1,188men); and Contractors (workers engaged by third parties): 577 (50 women and 527men).Table 1.1 presents the list of the farms that will be used to supply wood for theproject. The table also presents information of available area for plantation,existing planted area, type of contract (owned, leased or partnership), status ofthe activity (planted, planting or available for planting) and localization ofeach farm.ENVIRONMENTAL RESOURCES MANAGEMENT5ELDORADO - APRIL, 2012

Table 1.1Farms dataMap nº Name of the Farm 1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State1 4F** - 202,00 202,00 Partnership Available forplanting Selvíria Mato Grossodo Sul2 08 de Dezembro 588,85 - 588,85 Partnership Planted Selvíria Mato Grossodo Sul3 Água Azul 918,20 - 918,20 Partnership Planted Três Lagoas Mato Grossodo Sul4 Água Sumida** - 808,00 808,00 Leased Available forplantingAparecida doTaboadoMato Grossodo Sul5 Alvorada 149,87 - 149,87 Leased Planted Selvíria Mato Grossodo Sul6 Araça 214,99 - 214,99 Partnership Planted Selvíria Mato Grossodo Sul7 Barra Mansa 2.184,92 - 2.184,92 Leased Planted Água Clara Mato Grossodo Sul8 Barraca 3.420,57 288,74 3.709,31 Owned Planting Aparecida doTaboado/Inocência9 BarrancoVermelhoMato Grossodo Sul2.251,31 - 2.251,31 Partnership Planted Água Clara Mato Grossodo Sul10 Bebedouro 190,74 - 190,74 Leased Planted Três Lagoas Mato Grossodo Sul11 Beira Rio** - 540,00 540,00 Partnership Available forplanting12 Bela Vista-Otoboni**- 706,00 706,00 Leased Available forplanting13 Belezura** - 204,00 204,00 Leased Available forplanting Selvíria Mato Grossodo Sul Inocência Mato Grossodo SulAparecida doTaboadoMato Grossodo Sul14 Boa Esperança 453,62 - 453,62 Partnership Planted Anastácio Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 20126

Map nº Name of the Farm 1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State15 Boa Vista 1.356,11 - 1.356,11 Partnership Planted Três Lagoas Mato Grossodo Sul16 Bonito 6.515,54 12.768,66 19.284,20 Owned Planting Água Clara Mato Grossodo Sul17 Brasília I e II** - 560,00 560,00 Leased Available forplanting18 Buba 755,80 - 755,80 Partnership Planted Dois Irmãos doBuriti Três Lagoas Mato Grossodo SulMato Grossodo Sul19 Buriti 602,77 - 602,77 Partnership Planted Selvíria Mato Grossodo Sul20 Buriti da Véstia 356,56 - 356,56 Partnership Planted Selvíria Mato Grossodo Sul21 Buriti doCerrado299,08 - 299,08 Leased Planted Selvíria Mato Grossodo Sul22 Buriti-Aleudo** - 590,00 590,00 Leased Available forplantingAparecida doTaboadoMato Grossodo Sul23 Cabeceira Bonita 1.490,56 - 1.490,56 Partnership Planted Três Lagoas Mato Grossodo Sul24 Cabeceira daEstrada83,69 - 83,69 Partnership Planted Selvíria Mato Grossodo Sul25 Cabeceirão** - 182,00 182,00 Leased Available forplantingAparecida doTaboadoMato Grossodo Sul26 Cachoeira 1.252,94 - 1.252,94 Partnership Planted Selvíria Mato Grossodo Sul27 Campo Limpo I 1.483,89 - 1.483,89 Partnership Planted Selvíria/TrêsLagoasMato Grossodo Sul28 Campo Limpo II 752,33 - 752,33 Partnership Planted Selvíria Mato Grossodo Sul29 Canoas 3.717,68 - 3.717,68 Owned Planted Selvíria Mato Grossodo Sul30 Celina 54,41 - 54,41 Leased Planted Três Lagoas Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 20127

Map nº Name of the Farm 1 - PlantedArea (ha)32 Conquista TrêsPoderes33/342 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State229,74 - 229,74 Partnership Planted Três Lagoas Mato Grossodo Sul Correntes I e II 3.017,81 - 3.017,81 Owned Planted Dois Irmãos doBuriti35 Correntes III** - - - Owned Dois Irmãos doBuriti36 Cristiane** - 436,00 436,00 Leased Available forplantingAparecida doTaboadoMato Grossodo SulMato Grossodo SulMato Grossodo Sul37 Cristo Rei 1.219,00 - 1.219,00 Partnership Planted Inocência Mato Grossodo Sul38 Da Mina** - 444,00 444,00 Leased Available forplanting39 Diogo** - 300,00 300,00 Leased Available forplanting40 DoisCoqueiros**- 157,00 157,00 Leased Available forplantingAparecida doTaboadoMato Grossodo Sul Selvíria Mato Grossodo SulAparecida doTaboadoMato Grossodo Sul41 Dois Irmãos 1.041,74 - 1.041,74 Partnership Planted Selvíria Mato Grossodo Sul42 Farinazo 526,41 - 526,41 Partnership Planted Selvíria Mato Grossodo Sul43 Douradinha 132,13 - 132,13 Leased Planted Santa Rita do Pardo Mato Grossodo Sul44 Eldorado II 800,62 - 800,62 Partnership Planted Três Lagoas Mato Grossodo Sul45 Esperança** - 330,00 330,00 Leased Available forplanting46 Estrela daMina**- 406,00 406,00 Leased Available forplantingAparecida doTaboadoAparecida doTaboadoMato Grossodo SulMato Grossodo Sul47 FJE 144,77 - 144,77 Partnership Planted Três Lagoas Mato Grossodo Sul48 Flor de Liz 576,86 - 576,86 Leased Planted Três Lagoas Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 20128

Map nº Name of the Farm 1 - Planted 2 -Available Total Land Contract Status Municipality StateArea (ha) Area forPlanting (ha)(1+2)49 Floresta 557,93 138,26 696,19 Partnership Planting Selvíria Mato Grossodo Sul50 Gramadão 1.225,59 - 1.225,59 Partnership Planted Selvíria Mato Grossodo Sul51 Guri I 461,99 - 461,99 Partnership Planted Três Lagoas Mato Grossodo Sul52 Guri III 117,02 - 117,02 Partnership Planted Três Lagoas Mato Grossodo Sul53 Iracema 781,45 - 781,45 Leased Planting Ribas do Rio Pardo Mato Grossodo Sul54 Jandaia** - 652,00 652,00 Leased Available forplanting Aparecida doTaboado Mato Grossodo Sul55 Jataí 252,09 - 252,09 Owned Planted Selvíria Mato Grossodo Sul56 Jatiúca 51,82 - 51,82 Owned Planted Anastácio Mato Grossodo Sul57 Jatobá 575,28 - 575,28 Partnership Planted Três Lagoas Mato Grossodo Sul58 JBS 63,34 - 63,34 No Contract Planted Andradina São Paulo59 Kokets** - - Leased Available forplanting Três Lagoas Mato Grossodo Sul60 Labor 286,08 - 286,08 Leased Planted Três Lagoas Mato Grossodo Sul61/62 Laranja 1 e 2 1.471,77 - 1.471,77 Partnership Planted Três Lagoas Mato Grossodo Sul63 Lyder 744,10 - 744,10 Leased Planted Ribas do Rio Pardo Mato Grossodo Sul64 Madeiropólis** - 140,00 140,00 Leased Available forplanting Selvíria Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 20129

Map nº Name of the Farm 1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State65 Malela** - 240,00 240,00 Leased Available forplanting Três Lagoas Mato Grossodo Sul66 Morro Vermelho 157,51 - 157,51 Partnership Planted Selvíria Mato Grossodo Sul67 Mutum 1.756,69 - 1.756,69 Partnership Planted Ribas do Rio Pardo Mato Grossodo Sul68 Mutum-Otoboni**- 112,00 112,00 Leased Available forplanting Inocência Mato Grossodo Sul69 Mutum Piuva - Owned Corumbá Mato Grossodo Sul70 Nambú 375,75 - 375,75 Partnership Planted Selvíria Mato Grossodo Sul71 Nevada** - 1.430,00 1.430,00 Partnership Available forplanting72 Nossa SenhoraAparecida Três Lagoas Mato Grossodo Sul444,25 - 444,25 Partnership Planted Selvíria Mato Grossodo Sul73 Nova Olinda** - 504,00 504,00 Leased Available forplanting74 Palmeira** - 647,00 647,00 Leased Available forplanting75 Panorama** - 242,00 242,00 Leased Available forplanting Selvíria Mato Grossodo SulSelvíria/Aparecidado TaboadoMato Grossodo Sul Três Lagoas Mato Grossodo Sul76 Pantano 2.531,00 285,82 2.816,82 Partnership Planting Selvíria Mato Grossodo Sul77 Papagaio 1.100,19 - 1.100,19 Partnership Planted Aparecida doTaboadoMato Grossodo Sul78 Prata 480,61 - 480,61 Leased Planted Três Lagoas Mato Grossodo Sul79 Prata 01** - 906,00 Partnership Available forplanting80 Progresso 351,11 - 351,11 Partnership Planted Aparecida doTaboado Três Lagoas Mato Grossodo SulMato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201210

Map nº Name of the Farm 1 - PlantedArea (ha)81 Quatro Irmãos-Lauro Vasques**2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State- 317,00 Leased Available forplanting82 Queixada** - 1.053,00 Leased Available forplanting83 Queixada-Sandra Rahal**- 420,00 Leased Available forplanting85 Rancharia 687,23 - 687,23 Leased Planted Aparecida doTaboado Três Lagoas Mato Grossodo Sul Inocência Mato Grossodo Sul Selvíria Mato Grossodo SulMato Grossodo Sul86 Recanto 107,44 - 107,44 Partnership Planted Três Lagoas Mato Grossodo Sul87 Recanto do Lobo 761,22 - 761,22 Partnership Planted Água Clara Mato Grossodo Sul88 Retirinho 347,26 - 347,26 Leased Planted Selvíria Mato Grossodo Sul89 Rosana** - 886,00 886,00 Leased Available forplanting90 Rosana II** - 367,00 367,00 Leased Available forplantingAparecida doTaboadoAparecida doTaboadoMato Grossodo SulMato Grossodo Sul91 Santa Adélia 464,59 - 464,59 Leased Planted Três Lagoas Mato Grossodo Sul92 Santa Helena 1.212,74 - 1.212,74 Partnership Planted Inocência Mato Grossodo Sul93 Santa Iracema 328,90 - 328,90 Partnership Planted Três Lagoas Mato Grossodo Sul94 Santa Isabel 686,17 - 686,17 Leased Planted Três Lagoas Mato Grossodo Sul95 Santa Izabel 3.706,36 - 3.706,36 Owned Planted Pontal do Araguaia Mato Grosso96 Santa Livia 43,27 - 43,27 Partnership Planted Três Lagoas Mato Grossodo Sul97 Santa Lourdes 924,40 - 924,40 Partnership Planted Selvíria Mato Grossodo Sul98 Santa Lúcia doSucuriu**- 4.150,00 Leased Available forplanting Três Lagoas Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201211

Map nº Name of the Farm 1 - PlantedArea (ha)99 Santa Luzia-Dalila Soares**100 Santa Luzia-Durval**2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State- 130,00 130,00 Leased Available forplanting- 288,00 288,00 Leased Available forplanting101 Santa Maria 1.279,19 - 1.279,19 Partnership/Leased Selvíria Mato Grossodo Sul Três Lagoas Mato Grossodo Sul Planted Três Lagoas Mato Grossodo Sul102 Santa Marina 640,37 317,01 957,38 Leased Planting Três Lagoas Mato Grossodo Sul103 SantaMercedes**- 509,00 Leased Available forplanting Três Lagoas Mato Grossodo Sul104 Santa Rita 356,09 - 356,09 Partnership Planted Inocência Mato Grossodo Sul105 Santa Rosa 799,76 - 799,76 Partnership Planted Selvíria Mato Grossodo Sul106 Santa Terezinha 1.132,57 - 1.132,57 Partnership Planted Selvíria Mato Grossodo Sul107 Santa Terezinha 998,48 - 998,48 Leased Planted Aparecida doTaboado108 Santa Terezinha1Mato Grossodo Sul754,61 - 754,61 Leased Planted Três Lagoas Mato Grossodo Sul109 Santo Antonio** - 626,00 626,00 Leased Available forplanting Três Lagoas Mato Grossodo Sul110 Santo Expedito 111,55 133,00 244,55 Partnership Planting Inocência Mato Grossodo Sul111 Santo André 1.659,89 - 1.659,89 Partnership Planted Ribas do Rio Pardo Mato Grossodo Sul112 São João 852,24 - 852,24 Leased Planted Ribas do Rio Pardo Mato Grossodo Sul113 São João daVestia619,73 - 619,73 Partnership Planted Selvíria Mato Grossodo Sul114 São Jorge 776,22 - 776,22 Leased Planted Três Lagoas Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201212

Map nº Name of the Farm 1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State115 São José 256,17 - 256,17 Partnership Planted Três Lagoas Mato Grossodo Sul116 São Judas Tadeu 4.179,24 - 4.179,24 Partnership Planted Santa Rita do Pardo Mato Grossodo Sul117 São Judas Tadeu 233,45 - 233,45 Leased Planted Água Clara Mato Grossodo Sul118 São Lourenço 434,94 - 434,94 Partnership Planted Selvíria Mato Grossodo Sul119 São Manoel 898,35 - 898,35 Partnership Planted Aparecida doTaboadoMato Grossodo Sul120 São Paulo - Owned Alto Araguaia Mato Grosso121 São Pedro-HumbertoJacob**- 630,00 Leased Available forplanting Selvíria Mato Grossodo Sul122 São Vicente VII 2.747,99 - 2.747,99 Partnership Planted Água Clara Mato Grossodo Sul123 Savana 5.265,39 - 5.265,39 Partnership Planted Santa Rita do Pardo Mato Grossodo Sul124 Serrinha 319,64 - 319,64 Partnership Planted Três Lagoas Mato Grossodo Sul125 Shestese** - 256,00 Partnership Available forplanting126 Sítio Favú** - 47,00 47,00 Leased Available forplanting127 Sítio SantaRita**- 110,00 Leased Available forplanting Três Lagoas Mato Grossodo SulAparecida doTaboadoAparecida doTaboado128 Sobradinho 152,14 - 152,14 Leased Planted Aparecida doTaboado129 Sobradinho I** - 578,30 Owned Available forplantingMato Grossodo SulMato Grossodo SulMato Grossodo Sul Inocência Mato Grossodo Sul130 Tanaka 139,33 - 139,33 Leased Planted Selvíria Mato Grossodo SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201213

Map nº Name of the Farm 1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total(1+2)Land Contract Status Municipality State131 Taruana 1.365,90 - 1.365,90 Owned Planted Dois Irmãos doBuriti132 Traipu** - 189,00 Leased Available forplanting133 Três Amigos** - 370,00 370,00 Leased Available forplantingMato Grossodo Sul Três Lagoas Mato Grossodo Sul Inocência Mato Grossodo Sul134 Três Irmãos 150,98 - 150,98 Partnership Planted Selvíria Mato Grossodo Sul135 Três Meninas** - 1.134,00 Leased Available forplantingAparecida doTaboadoMato Grossodo Sul136 Uere Mirim 389,18 - 389,18 Leased Planted Santa Rita do Pardo Mato Grossodo Sul137 Vo Fiorindo 842,01 - 842,01 Partnership Planted Dois Irmãos doBuritiMato Grossodo Sul138 Vo Nhonho 709,18 - 709,18 Leased Planted Três Lagoas Mato Grossodo Sul** Estimated area of plantation, contract in process of formalization.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201214

The Forestry Operations are described in item 3.2. Figure 1.2 shows thelocation map of the farms described in table 1.1.ENVIRONMENTAL RESOURCES MANAGEMENT15ELDORADO - APRIL, 2012

Figure 1.2Location Map of the FarmsENVIRONMENTAL RESOURCES MANAGEMENT16ELDORADO - APRIL, 2012

.Mato GrossoGoiasBoíiviaMinas Gerais!5Aparecida do TaboadoMato Grosso do Sul!5Campo Grande!5Três LagoasSao Paulo!5ParaguaiParanaLegend!5 CitiesMain RiversLocation of FarmsConservation UnitsIndigenous AreasBiomeCerradoMata AtlânticaPantanal0 45.000 90.000MetersCLIENT DESCRIPTION PROJECT NUMBERPROJECTEldorado BrasilEnvironmental and Social Assessment of Industrial,Forest and Logistics Projects, According to the IFCPerformance Standards and EHS GuidelinesEDITION CONTROL04/19/2012EDITION04/19/2012REVISIONLocation of the FarmsTHIS DOCUMENT IS PROPERTY OFERM BRASIL LTDA. AND CANNOT BE COPIED,REPRODUCED OR TRANSMITTED BY ANY OTHERMEANS, OR USED FOR PURPOSES DIFFERENTOF THOSE FOR WHICH IT WAS DONE.0152083FIGURE / ANNEXFIGURE 1.2EDITOR / GRAPHIC DESIGNERTECHNICAL RESPONSIBLECIP

Logistics project: described in section 3.3, will guarantee the productiontransportation to clients. The majority of production will be exportedthrough Santos Port and, to accomplish that the Project establishes thatELDORADO will be responsible for the construction of 2 (two) multimodalterminals only, making use of third-party’s railway and roads, as the 2(two) models described below: Model 1: road transportation from the industrial plant to Aparecida doTaboado (90km) multimodal terminal, to be built by the Company and,then, railroad transportation to Santos Port (900 km), where the productwill be loaded into ships for exportation. ELDORADO will improve aterminal at the existing Santos Port for its needs; and Model 2: transportation from the industrial plant to Pederneirasmultimodal terminal (to be built by the Company) by barges throughTietê river (350 km) and, then, using a third party railway (MRS) toSantos Port (520 km), where the product will be loaded into ships forexportation.Exportation of pulp will be mainly to Europe (45%) and China (45%), witha minor part destined to America (10%). Figure 1.3 shows the location ofthe logistics projects and related infrastructure.ENVIRONMENTAL RESOURCES MANAGEMENT17ELDORADO - APRIL, 2012

Figure 1.3Logistics Project Location MapENVIRONMENTAL RESOURCES MANAGEMENT18ELDORADO - APRIL, 2012

MS - 316&:.BR - 158SP - 320&:Três LagoasSP - 310MINAS GERAISMATO GROSSODO SULSÃO PAULO&:PederneirasRIO DEJANEIROPARANÁ&:São Paulo&:SantosAtlantic OceanSource: Bing Maps.Legend&:CitiesPossible Railway PathsHighwayHydrographyCLIENT DESCRIPTION PROJECT NUMBERPROJECTEldorado BrasilEnvironmental and Social Assessment of Industrial,Forest and Logistics Projects, According to the IFCPerformance Standards and EHS GuidelinesEDITION CONTROL04/19/2012EDITIONLogistics Project Location04/19/2012REVISIONTHIS DOCUMENT IS PROPERTY OFERM BRASIL LTDA. AND CANNOT BE COPIED,REPRODUCED OR TRANSMITTED BY ANY OTHERMEANS, OR USED FOR PURPOSES DIFFERENTOF THOSE FOR WHICH IT WAS DONE.0152083FIGURE / ANNEXFIGURE 1.3EDITOR / GRAPHIC DESIGNERTECHNICAL RESPONSIBLELogistics Project LocationCIP

1.3 METHODOLOGY OF ASSESSMENTTo develop the assessment according to the scope of work proposed, ERMadopted the following methodology: Preliminary desk review of the environmental studies (such asEnvironmental Impact Assessment and its report - EIA/RIMA) and/orsupporting documents used in their preparation, made available and sentin advance by ELDORADO; Preliminary desk review of the environmental licenses made available byELDORADO; Analysis of actions performed by ELDORADO, such as plans andprograms, to comply with the conditions of the environmental licensespertinent to the Project; Preliminary desk review of secondary data about the company, consideringpublicly available documents with respect to the environmental and socialthemes; Visit to ELDORADO’s industrial site, from January 17 th to 20 th , 2012, wherethe plant is being installed, in Três Lagoas and interviews with corporateand industrial technicians representatives, responsible for EHS and Socialmanagement, workers and one neighbor related to the items covered by theIFC PSs; Visit to a sampling of farms (31 farms at total), from April 9 th to 13 th , 2012,and interviews with corporate and forest technicians’ representatives,responsible for EHS and Social management; Visit to Santos Port Terminal, on February 10 th , 2012, already in operation,where one of the ELDORADO’s terminals will be constructed (TerminalElmar); Visit to 3 (three) accommodation sites for forestry workers, located in ÁguaClara and Inocência municipalities, State of Mato Grosso do Sul; and Visit to the accommodation site for industry workers, located in TrêsLagoas, State of Mato Grosso do Sul; Visit to one wood supplier farm: Mutum Group Farm (Fazenda do GrupoMutum), in Ribas do Rio Pardo municipality; Evaluation of potential environmental, health, safety and social impactsand risks associated to the Project;ENVIRONMENTAL RESOURCES MANAGEMENT19ELDORADO - APRIL, 2012

Identification of legal parameters and applicable regulations toELDORADO’s Project; and Identification of gaps and recommendations for improvement, against theapplicable standards and regulations.The following ERM professionals were involved in the site visits: José Virgílio Lembo Duarte, Senior EHS Expert; Fernanda Rodrigues Britto, Social Consultant; Helena Capparelli, Environmental Licensing Consultant; Fernando Fahl, Senior Environmental Consultant; Gil Bindi, Senior Social Consultant; Milene Navarro, Social Consultant; and Alessandro Lopes, Environmental Consultant.Note 1: Other areas of the logistics project were not visited by ERM as part ofthis assessment, given that they are still in the project detailing phase and noconstruction activities is being carried out at those sites.Note 2: Due to the quantity of farms that are subject of the forest operationsand limitations of time, and costs in this assessment, ERM developed a samplecriterion for the site visits at the farms. The following items were consideredduring the selection of the farms: Types of contract (owned, leased or partnership); Status of the area (planted, planting or available for planting); Companies working on the land: third party companies (JS, Plantar orRuah) or Eldorado; Proximity to communities (for example, indigenous people); Proximity to different biomes (for example: Cerrado and Pantanal); and Size of the planted area.ERM visited 31 farms (23,1% of the total), and the sampling result is presentedbelow:ENVIRONMENTAL RESOURCES MANAGEMENT20ELDORADO - APRIL, 2012

Status of the land From the total of 45 available for planting, ERM visited 4 (8.9%); From the total of 7 planting, ERM visited 4 (57.1%); and From the total of 82 planted, ERM visited 23 (28%).Types of contract/ownership From the total of 12 owned by Eldorado, ERM visited 6 (50%); From the total of 61 leased lands, ERM visited 8 (13%); From the total of 59 partnership agreements, ERM visited 16 (27%); and From the total of 1 partnership and leased agreement, ERM visited 1(100%).Observation: There is one farm in the list, 58 – JBS, that belongs toELDORADO´s owner, and will not be used for pulp production.Companies working on the land From the total of 4 areas visited with companies working on the land, ERMvisited 1 from JS, 1 from Plantar and 2 operated by Eldorado; and From the total of 23 planted areas visited, 1 had maintenance activitiesperformed by Ruah.Communities and biomesERM managed to perform the visits to farms located next to indigenous areas(Municipalities of Aquidauana and Anastácio).According to the information on location of the farms provided byELDORADO, ERM verified that only two farms are located outside theCerrado biome. One of these is located in the Pantanal biome and the other inthe Mata Atlântica biome. These farms were not visited because the farmlocated in the Pantanal biome is not planted and the farm located in the MataAtlântica biome belongs to one of ELDORADO´s owner and as informed itwill not be used for pulp production.Table 1.2 presents the information on the 31 farms visited by ERM, whileFigure 1.4 shows the location map of the farms visited by ERM during thevisits. This map also includes information about the biome and the location ofindigenous areas.ENVIRONMENTAL RESOURCES MANAGEMENT21ELDORADO - APRIL, 2012

Table 1.2Visited FarmsMap nº Name of the Farm1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total (1+2) Land Contract Status Municipality State4Água Sumida**- 808,00808,00 LeasedAvailable forplanting Aparecida do Taboado Mato Grosso do Sul78Barra MansaBarraca2.184,92 -3.420,57 288,742.184,92 Leased Planted Água Clara Mato Grosso do Sul3.709,31 Owned PlantingAparecida doTaboado/InocênciaMato Grosso do Sul9Barranco Vermelho2.251,31 -2.251,31 Partnership Planted Água Clara Mato Grosso do Sul15-1.356,11Boa Vista1.356,11 Partnership Planted Três Lagoas Mato Grosso do Sul18-755,80Buba755,80 Partnership Planted Dois Irmãos do Buriti Mato Grosso do Sul21-299,08Buriti do Cerrado299,08 Leased Planted Selvíria Mato Grosso do Sul26/84-1.252,94Cachoeira1.252,94 Partnership Planted Selvíria Mato Grosso do Sul33/34-3.017,81Correntes I e II3.017,81 Owned Planted Dois Irmãos do Buriti Mato Grosso do Sul35 Correntes III** - - - Owned Dois Irmãos do Buriti Mato Grosso do Sul48-576,86Flor de Liz576,86 Leased Planted Três Lagoas Mato Grosso do Sul49Floresta557,93138,26 696,19 Partnership Planting Selvíria Mato Grosso do Sul50Gramadão1.225,59 -1.225,59 Partnership Planted Selvíria Mato Grosso do Sul56Jatiúca51,82 -51,82 Owned Planted Anastácio Mato Grosso do Sul57Jatobá575,28 -575,28 Partnership Planted Três Lagoas Mato Grosso do SulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201222

Map nº Name of the Farm1 - PlantedArea (ha)2 -AvailableArea forPlanting (ha)Total (1+2) Land Contract Status Municipality State67778087899093101102107110119122129131137MutumPapagaioProgressoRecanto do LoboRosana**Rosana II**Santa IracemaSanta MariaSanta MarinaSanta TerezinhaSanto ExpeditoSão ManoelSão Vicente VIISobradinho I**TaruanaVo Fiorindo1.756,69 - 1.756,69 Partnership Planted Ribas do Rio PardoMato Grosso doSul1.100,19 - 1.100,19 Partnership Planted Aparecida do TaboadoMato Grosso doSul351,11 - 351,11 Partnership Planted Aparecida do TaboadoMato Grosso doSul761,22 - 761,22 Partnership Planted Água ClaraMato Grosso doSul--886,00367,00886,00 LeasedAvailable forplanting367,00 LeasedAvailable forplantingAparecida do TaboadoAparecida do TaboadoMato Grosso doSulMato Grosso doSul328,90 - 328,90 Partnership Planted Três LagoasMato Grosso doSul1.279,19 - 1.279,19 Partnership/Leased Planted Três Lagoas640,37317,01Mato Grosso doSul957,38 Leased Planting Três LagoasMato Grosso doSul998,48 - 998,48 Leased Planted Aparecida do TaboadoMato Grosso doSul111,55133,00244,55 Partnership Planting InocênciaMato Grosso doSul898,35 - 898,35 Partnership Planted Aparecida do TaboadoMato Grosso doSul2.747,99 - 2.747,99 Partnership Planted Água ClaraMato Grosso doSul- 578,30 OwnedAvailable forplantingInocênciaMato Grosso doSul1.365,90 - 1.365,90 Owned Planted Dois Irmãos do BuritiMato Grosso doSul842,01 - 842,01 Partnership Planted Dois Irmãos do BuritiMato Grosso doSulENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201223

Figure 1.4Farms Visited by ERM During the AssessmentENVIRONMENTAL RESOURCES MANAGEMENT24ELDORADO - APRIL, 2012

.Map 1..Map 1MATO GROSSO DO SUL120Aparecida do Taboado !5!5!5Campo GrandeTrês LagoasMap 2Map 2.12343116136Legend43116120123Douradinha Leased PlantedSão Judas Tadeu Partnership PlantedSão Paulo Owned Not informedSavana Partnership PlantedSource: Bing Maps136 Uere Mirim Leased Planted** Estimated area planted, no formal contract or in the process of formalizingLegendBiome!5 CitiesHighwaysHydrographyLocation of FarmsConservation UnitsIndigenous AreasCerradoMata AtlânticaPantanal0 12.500 25.000MetersCLIENT DESCRIPTION PROJECT NUMBERPROJECTEldorado BrasilEnvironmental and Social Assessment of Industrial,Forest and Logistics Projects, According to the IFCPerformance Standards and EHS GuidelinesEDITION CONTROL04/19/2012EDITION04/19/2012REVISIONVisited FarmsTHIS DOCUMENT IS PROPERTY OFERM BRASIL LTDA. AND CANNOT BE COPIED,REPRODUCED OR TRANSMITTED BY ANY OTHERMEANS, OR USED FOR PURPOSES DIFFERENTOF THOSE FOR WHICH IT WAS DONE.0152083FIGURE / ANNEXFIGURE 1.4AEDITOR / GRAPHIC DESIGNERTECHNICAL RESPONSIBLECIP

Annex A presents the list of documents analyzed during this assessment,provided by ELDORADO and also the list of representatives of ELDORADOthat were interviewed.1.4 LIMITATIONS AND EXCEPTIONSThis report is based upon the application of scientific principles andprofessional judgment to certain facts with resultant subjective interpretations.Professional judgments expressed herein are based on the currently availablefacts within the limits of the existing data, scope of work, budget andschedule.The scope of this evaluation was restricted to the industrial site and asampling of farms (as detailed in item 1.3). The visited farms were selectedusing technical criteria due to the limitations of schedule and budget not allthe farms could be covered during this assessment.The seedling nursery was not visited due to the distance and time constraints.All documents requested by ERM from ELDORADO have been provided,except the following: Sustainability Policy which, reportedly is being discussed at the corporatelevel and is part of the Action Plan to implement the management system.Regarding the logistics project which comprises three port terminals, the siteinspection could only be performed at one of them (Port Elmar, located in themunicipality of Santos). The other two multimodal terminals are yet to beconstructed and no activities were being carried out during the period of thisassessment. Therefore, neither Pederneiras port or Aparecida do Taboado portcould be visited/inspected.The logistics system is in the project feasibility stage and a limited amount ofinformation is available. Eldorado made available to ERM the SimplifiedEnvironmental Report (Relatório Ambiental Simplificado – RAS), required bythe State of Mato Grosso do Sul Environmental Agency – IMASUL as part ofthe licensing process of the Aparecida do Taboado multimodal terminal. Noother documents were available.As for the Pederneiras multimodal terminal, no documents were madeavailable, given that the construction and operation will be responsibility of athird party company with which ELDORADO has established a services’provision contract. Just some sections of the contract were analyzed by ERM.Given the lack of available documents, and that the project is in its initialphase, and that only one port terminal could be visited/inspected, the gapENVIRONMENTAL RESOURCES MANAGEMENT25ELDORADO - APRIL, 2012

analysis against the Equator Principles and the IFC Performance Standards isnot complete. However recommendations of actions to mitigate potentialrisks are included in this report, in order to make the project compliant withthose standards at a later stage.Particularly with regards to Performance Standard 2 (Labor and WorkingConditions) for the Logistics Project, no interviews with employees wereconducted to assess labor and working conditions at construction sites, asthere is no activity there.To the extent that more definitive conclusions are desired by the client thanare warranted by the currently available facts, it is specifically ERM's intentthat the conclusions stated here are understood as guidance and notnecessarily as a firm course of action, except where explicitly stated as such.ERM makes no warranties, expressed or implied, including, withoutlimitation, warranties as to merchantability or fitness for a particular purpose.In addition, the information provided in this report is not to be constructed aslegal advice.1.5 USE OF THIS REPORTThe client agrees that none of its advertising, sales promotion, or otherpublicity matter containing information obtained from this report willmention or imply the name of ERM. The client also acknowledges that thisreport has been prepared to the exclusive use of the client and acknowledgedthird parties.Nothing contained in this report shall be construed as a warranty oraffirmation by ERM that the site and property described in the report aresuitable acquisition of such property by any lender through foreclosure.2 ENVIRONMENTAL AND SOCIAL BASELINE FOR THE PROJECTIndustrial PlantELDORADOs’ pulp and mill facility consist in the installation of a bleachedkraft eucalyptus pulp mill, eucalyptus homogeneous reforestation and relatedinfrastructure such as pier, railway and power transmission lines.In the project planning phase it was decided that the power transmission lines,railway, pier and fuel station would have distinct licensing processes andtherefore would require their own permitting process. An EnvironmentalImpact Assessment Study was developed only for the pulp and mill facility.The other associated infrastructure had simplified environmental permittingprocesses.ENVIRONMENTAL RESOURCES MANAGEMENT26ELDORADO - APRIL, 2012

During the EIA analysis process by the State Environmental Agency(IMASUL), a Public Hearing was conducted on December 3rd, 2009, at 7pm inTrês Lagoas city, in Centro de Eventos Leiloado at Road BR 262, km 11.Forest OperationsFor the forestry activities no Environmental Impact Assessment (EIA) andEnvironmental Basic Plan (PBA) were developed, according to the exemptiongranted by State regulations. The legislation requires ELDORADO to issue toIMASUL a "Planting Informative" of the concerning areas for such activity aswell as the appropriate "environmental clearance for cutting of plantedforests." These documents require proof of preservation of legally protectedareas.Logistics ProjectFor the logistics project, ELDORADO will be responsible for the Aparecida doTaboado licensing process and construction. A Simplified EnvironmentalReport - RAS for the terminal has been developed and submitted for approvalat IMASUL.Adjustments of the railway extension access in Aparecida do Taboado, will beperformed by ELDORADO and the licensing procedures and eventualvegetation suppression with its compensations will be managed by thiscompany.For the Pederneiras Terminal, ELDORADO has hired EGTM Navegação(Torque) which already owns a multimodal terminal and will expand itsboundaries in other to meet the demand. EGTM Navegação will beresponsible for the waterway transportation and permitting process ofterminal and water transportation.Adjustments of the railway extension access in Pederneiras will be performedby MRS LOGÍSTICA S.A and the licensing procedures and eventualvegetation suppression with its compensations will be managed by thiscompany, as reported by ELDORADO.At Santos Port, ELDORADO will have the following activities: Temporary warehouse: owned by Hipercon Terminais de Cargas Ltdawhich currently has installation license according information provided onState Environmental Agency’s (CETESB) website. ELDORADO hasinformed that the area will be operated by this company which will beresponsible for obtaining and maintaining environmental permits andlicenses, as well as for complying with the environmental legislation; Warehouses III, VIII, XIII and XVIII: has been purchased by ELDORADOfrom Rodrimar S/A Transportes Equipamentos Industriais e ArmazénsENVIRONMENTAL RESOURCES MANAGEMENT27ELDORADO - APRIL, 2012

Gerais; and Warehouses IX to XII: ELDORADO has the intention to acquire theseareas.Table 2.1 presents the status of all the infrastructure for the project.ENVIRONMENTAL RESOURCES MANAGEMENT28ELDORADO - APRIL, 2012

Table 2.1Environmental Status of the Project Areas/ InfrastructureProject Area Environmental ProjectResponsibilityBrazilian Environmental LicensePulp and Paper Mill ELDORADO Preliminary License nº 314/2009(IMASUL, 2009);Power TransmissionLine and ElectricalSubstationInstallation License nº 17/2011,(IMASUL, February 24th, 2011);Application for a Installation Permit(plant expansion for sodiumchlorate manufacturing plant):application done on August 31,2011;Application for a CommissioningPermit: done on November 18 th ,2011;Operation License: to be obtainedafter industry construction isfinished.ELDORADO Preliminary License nº 98/2010(IMASUL, July 22th, 2010);Installation License nº 148/2010(IMASUL, (October 27th, 2010);PhaseStatusInconstructionIn operationsince 2011Other informationELDORADO has decided to include a sodiumchlorate manufacturing plant on site, instead oftransporting the sodium chlorate by tanker trucksfrom market suppliers. As a result, it applied foran Installation Permit for the plant expansion onAugust 31, 2011. Additionally, it developed anenvironmental study (EAP – Estudo AmbientalPreliminar) and a risk analysis, considering thepresence of the Chlorate plant to support thelicensing process. The Installation Permit for theChlorate Plant has not been issued to date.ELDORADO also applied for a permit for thecommissioning stage on November 18th, 2011 inorder to include in the Installation Permit thecommissioning of: pulp production, chemicalrecovery, utilities and manufacturing systems forsodium chlorate, chlorine dioxide and oxygenmanufacture.-Operation License nº 83/2011(IMASUL, February 24th, 2011).Preliminary License nº 137/2010(IMASUL, November 4th, 2010).Fuel Station ELDORADO /PETROBRASNoinformationwasprovidedThe concessionaire of the fuel station isPETROBRAS and, reportedly, this company isresponsible for issuing the documentation for theInstallation and Operation License, since they willbe operating the station.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201229

Project AreaPier Mooring close tothe industrial siteInternal railwayextension (insidepulp mill)Environmental Project Brazilian Environmental LicenseResponsibilityELDORADO Preliminary License nº 135/2010(IMASUL, November 4th, 2010).ELDORADO Preliminary License nº 136/2010(IMASUL, November 4th, 2010)Forestry operations ELDORADO Allowed to operate according toEnvironmental regulations.Multimodal Terminal(Aparecida doTaboado)Increase in federalroad traffic (BR 158)between IndustrialPlant and Aparecidado TaboadoELDORADOELDORADOApplication for Preliminary License:Simplified Environmental Report-RAS was submitted to the stateenvironmental agency IMASUL:application done on March/April,2012.Environmental Study included onMultimodal Terminal (Aparecida doTaboado): Simplified EnvironmentalReport - RAS was submitted to thestate environmental agencyIMASUL (application done onMarch/April, 2012).PhaseStatusApplicationforInstallationLicenseApplicationforInstallationLicenseAlready inoperationsince 2010.AwaitingPreliminaryLicenseAwaitingPreliminaryLicenseOther informationELDORADO has submitted to IMASUL a studycalled EAP – Preliminary Environmental Study, tochange in 300m the coordinates of the pier whichwere informed in the EIA.-No Environmental Impact Assessment (EIA) andEnvironmental Basic Plan (PBA) were developed,according to the exemption granted by Stateregulations. The State issued an authorization incase there is the need to cut vegetation foreucalyptus plantation. In case of pasture landconversion there is no need for previousauthorization.Simplified Environmental Report - RAS is beinganalyzed by IMASUL, in order to provide thepreliminary license or request furtherclarifications/complementation before issuingPreliminary License.Simplified Environmental Report-RAS is beinganalyzed by IMASUL, in order to provide thepreliminary license or request furtherclarifications/complementation before issuingPreliminary License.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201230

Project AreaEnvironmental ProjectResponsibilityEGTM Navegação(Torque)andMRS LOGÍSTICABrazilian Environmental LicensePhase Other informationStatus- According to the Service Agreement signed byEldorado and EGTM (December 22th, 2011),EGTM Navegação (Torque) agrees to observe andcomply with environmental legislation, beingresponsible for fines and notices of violation ofactivities directly related to the transportation ofcellulose, and is responsible for obtaining andmaintaining any permits or licenses required bypublic agencies, due to the object of the contract.Multimodal Terminal(Pederneiras)The licensing procedures atMultimodal Terminal will bemanaged by EGTM Navegação(Torque).The licensing procedures at railwayextension will be managed by MRSLOGÍSTICA.Additionally, the adjustments of the railwayextension access in Pederneiras, will be performedby MRS LOGÍSTICA. The licensing procedureswill be managed by this company, as reported byELDORADO.- Temporary warehouse: the licensing proceduresare managed by Hipercon;Construction andadaptation of existingstructures at the Portof SantosELDORADO, HiperconTerminais de CargaLtda andMRS LOGÍSTICATemporary warehouse: installationlicense issued by CETESB. To beoperated by Hipercon.Warehouse III and VIII: operatingpermit under Rodrimar’s name(previous owner) - warehouse IIInº18001394 has been issued on28/12/2009 and is valid until28/12/2013; operating permit forwarehouse VIII nº 18001731 hasbeen issued on 03/10/2011 and isvalid until 13/07/2014.Warehouse III, VIII, XIII and XVIII: futurelicensing procedures will be managed byELDORADO;MRS Logística will be responsible for theadjustments of the railway extension access, andits licensing, as reported by ELDORADO.Warehouse XIII and XVIII: not yetlicensed.Warehouses IX and XII: in processof acquisition.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201231

Project AreaEnvironmental ProjectResponsibilityBrazilian Environmental LicensePhaseStatusOther informationAdjustments of therailway extensionaccess to Aparecidado TaboadoELDORADOMRS Logística will constructadjustment at the temporary areaand the railway extension access.The construction and licensingprocedures will be managed byELDORADO.- Adjustments of the railway extension access inAparecida do Taboado will be performed byELDORADO. The licensing procedures will bemanaged by this company.Existing Waterway –Tiete River (fromIndustrial Plant toPederneiras)ETGM NavegaçãoThe licensing procedures at thewaterway are managed by EGTMNavegação (Torque).Already inoperation.Existing and operating waterway. Specificresponsibilities are covered by a contract.External and existingRailway (MRS)MRS LOGÍSTICAAlready licensed (MRS LOGÍSTICAresponsibility).Already inoperation.Existing and operating railway.External and existingRailway (ALL)ALL (América LatinaLogística)Already licensed (ALLresponsibility).Already inoperation.Existing and operating railway.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201232

Environmental and Social Setting Biome and Land UseELDORADO´s operations are mainly in the Cerrado biome. Thepredominant flora is low vegetation (exotic grasses) and isolated nativetrees. These are typical physiognomy of the Cerrado.The original forest formations, belonging to the Cerrado, were reduced tosmall fragments, resulting in the isolation and habitat fragmentation due tointense agriculture activities.According to information provided during ERM assessment, the land useconversion inside ELDORADO’s properties was mostly from pasture toforest plantation. In the visited sites ERM did not find evidences thatELDORADO is converting native forests into forest plantation.ERM observed the implementation at the visited farms that riparian zonesare respected, the land used was already degraded by human activities(pasture lands) and appropriate techniques are used for erosion control(e.g. stacking of brush and slashes, for instance).Additionally, as reported, due to local meteorological conditions (rainyregion) irrigation is not planned at the planted areas. Social SettingELDORADO industrial site is located in Três Lagoas municipality and theplantations areas are distributed mainly along Mato Grosso do Sul State.The main municipalities of Mato Grosso do Sul State are briefly describedbelow in order to provide a social setting of the project.Três LagoasThe city of Tres Lagoas has over 100,000 inhabitants, according to IBGE,2011, and is the 4th largest population in Mato Grosso do Sul State and 2ndlargest industrial GDP (equal to R$ 397,500,000 according to FIEMS, 2010).The Human Development Index (HDI) is rated 0,748, considered ofmedium human development (between 0.5 and 0.8).Because of its strategic location and availability of energy, water, rawmaterial and labor, it is expected to become the second most important city,in economic and political terms, in the State.The city is the regional center for health care, receiving over 200,000 peoplefrom other municipalities and regions.ENVIRONMENTAL RESOURCES MANAGEMENT33ELDORADO - APRIL, 2012

SelvíriaAgribusiness is the largest activity at Selviria and corresponds to 46.29% ofthe GDP, while 38.48% of the GDP is services, 5.61% industry and 9.6%income from taxes. The HDI is below the state level, 0,736 at 2000.The local infrastructure service has only 6 beds available to the NationalHealth System (SUS). The city depends of Tres Lagoas health infrastructureservice. There are public schools at Selvira, but there isn’t a technicalprofessional course.InocênciaThere are 7,653 inhabitants at Inocência, 64% of them living in urban area.The local government seeks support to construct a hospital to attend 18beds. There is no university available at the city.Água ClaraÁgua Clara has 14,686 inhabitants. The city economic has been improvedby the construction of the São Domingos Hydropower. The main industryof the city is wood extraction, soya and cattle rising. There are around 30wood industry based on reforestation.Consultation ActivitiesELDORADO has the following consultation initiatives: For the purpose of social economic diagnosis, a sample of citizens and localgovernmental authorities were interviewed to identify vulnerability of theregion; For the development of the Inventory of Areas of High Biodiversity study,stakeholders were consulted to identify the areas of high biodiversityimportant to the community and the use of it; As a result of the local vulnerabilities identified at the social economicdiagnosis, local governmental representatives were consulted byELDORADO to identify projects that could be supported by ELDORADO; During PTEAS - Economic, Environmental and Social Technical Project(“Projeto Técnico Econômico, Ambiental e Social”) process, neighbors of thelands where ELDORADO operates receive information about the companyand orientation on how to contact it; Forums and public hearings were held for the purpose of the industrylicense process, where information about the EIA and programs weredisclosure to the public (community leaders, government, police,ENVIRONMENTAL RESOURCES MANAGEMENT34ELDORADO - APRIL, 2012

associations, etc.) and community concerns about the project wereidentified; and A public hearing for the forestry project will be hold for certificationpurpose and the Forest Management Plan will be disclosure.A community relationship plan is being developed.External Communications and Grievance MechanismsELDORADO has the followings communication channels: Internal newspaper to workers; and Disclosure of information at local radios and journal.There are four mechanisms in place for grievance and to registercommunication received from stakeholders.Name of theMechanismStakeholdergroupDescriptionMain complaints receivedOmbudsmanHumanResources inthe fieldIndustrialworkers(employeesandcontractor’sworker)Rural workersGrievances are received through: Directly to the ombudsman representative atthe site; Though each company social assistance at thesite; Written and posted in a box available at thesite and the accommodation; Telephone number; and E-mail.Grievances are registered and are treated by theOmbudsman, analyzed, investigated, andfeedback is provided to the worker by the socialassistant. In case of anonymous grievance, therespond is disclosure on a board available close tothe cafeteria.Information about the ombudsman is disclosureat the Manual for Induction and banners at thesite.A representative from HR visit workers in thefield twice a month to register their demands.ERM reviewed a spreadsheet containing the nameof the worker, complaint, feedback provided, andtime of response.Workers interviewed reported that complains aremade through their field supervisor mostly.Error at payment of contracttermination;Delay in the delivery ofpayroll;Retention of the WorkerRegistration Book for over 48hour (according to theBrazilian legislation, thecompany must retain it toregister work contract detailsand return it in no longer than48 hours);Difficulty of relationshipbetween workers andsupervisors;Error in the overtimepayment; andDelay to reimburse workers oftravel expenses.Access to benefits (healthinsurance and feed fee); andError in salary payments.Complains from contractor’s workers areregistered and directed to the Contract company.None of the complaints registered on thespreadsheet were related to contractor’s workers.ENVIRONMENTAL RESOURCES MANAGEMENT35ELDORADO - APRIL, 2012

Name of theMechanismStakeholdergroupDescriptionMain complaints receivedForm toregisterexternalcommunication from thepublicExternalstakeholders,specially localcommunityand neighborStakeholders might contact ELDORADO’s officein each municipality, a telephone number, thesupervisor of the farm or those responsible toperform rounds on the farms.Contact numbers are provided to neighbors of thefarms during the PTEAS process, but there is nosystematic process to disclosure the informationto general community.The form registers the name of the person,stakeholders category, reason for contact, name ofthe person who receive the contact and actiontaken. Once complete, the form is delivered to oneperson in charge to receive it. The complaint isregistered in a spreadsheet that contains the nameof the person, data, who received the complaint, adescription of the complaint, action taken,feedback and data.request of finance support tosocial programs;neighbor broken fence;measures to combat fire atELDORADO’s site; andworkers performingmaintenance activities in aneighbor land.There is also an e-mail and telephone number on the company’s website thatstakeholders can contact.In the forums and public hearings held for the purpose of the industry licenseprocess, the following concerns were noted: Origin of the eucalyptus for the pulp production, if already planted; Local hiring; Environmental compensation; Programs to support public security; Workers accommodation: where they would be accommodated; Impacts of the use of public roads; and Communication to the public in case of environmental incident andemergency response.Indigenous PeopleAn archeological survey was conducted in December 2011, and identified thatthere was no indigenous groups or traditional people affected byELDORADO’s operation. The study was undertaken on 7 municipalities wereELDORADO operates: Três Lagoas, Selvíria, Aparecida do Taboado,Inocencia, Agua Clara, Santa Rita do Pardo, Ribas do Rio Pardo.This study reports that there is one indigenous group in the municipality ofBrasilandia names Ofayé-Xavante, municipality in which ELDORADO doesENVIRONMENTAL RESOURCES MANAGEMENT36ELDORADO - APRIL, 2012

not operate. ELDORADO reported that this indigenous land is 96 km awayfrom ELDORADO industrial site and 92 km away from farms operated byELDORADO at the municipality of Santa Rita do Pardo.A social territory study was undertaken for the municipalities of Anastacioand Dois Irmãos do Buruti, were ELDORADO possess lands. The study wasundertaken by the previous land owner and identified 7 indigenouscommunities in the region. According to ELDORADO, there are noindigenous or traditional people at ELDORADO’s land and Jatiúca Farm isthe closest to an indigenous land boundary, 22 km away.The lands at Anastacio and Dois Irmãos do Buruti have eucalyptus ready to beharvested and recently planted, maintenance is currently being performed.ELDORADO reported that possible impact on indigenous and traditionalpeople, if any, will be identified through PTEAS that will be carried out beforeharvesting (between June to December 2012). Reportedly ELDORADO do notuse work from indigenous people in its farms. Water ConsumptionThe EIA developed for ELDORADO pulp mill took into account wateravailability as one factor for location alternatives. Water will be abstractedfrom Paraná River and a flow measurement for the period of 22 years wasconsidered. Within this period, the average flow was 7,299 m³/s, with amaximum flow of 28,222 ³/s and minimum of 1,597 m³/s. Thecharacteristic flow (Q95) was 2,070 m³/s (occurring 95% of the time).The design water intake for industrial purposes, used for the dimensioningof the water treatment plant to be installed in ELDORADO pulp mill is7,500 m³/h (2.08 m³/s), what represents 0.1% of Paraná River (Q95) flow.Ambient Air QualityERM reviewed two air quality monitoring reports developed by the hiredconsulting company Storm & Smoke – Consultoria Ambiental e Prestadorade Serviços. Three monitoring points were determined: 24-hour monitoring at Fazenda Santa Vera (where the mill will be located); 24-hour monitoring at Assentamento Pontal do Faia (located approximately6.0 km East from ELDORADO Pulp Mill site); and 24-hour monitoring at one point in the city of Três Lagoas (distantapproximately 22 km southeast of ELDORADO site, straight line).One report refers to monitoring campaigns conducted in March and July,2011. Monitored parameters included particulates (inhalable particles andENVIRONMENTAL RESOURCES MANAGEMENT37ELDORADO - APRIL, 2012

total suspended particles), NO2, ozone, carbon monoxide and SOx. The area isconsidered homogeneous in what refers to air quality.The results indicated that the monitored parameters meet the air qualitystandards established in Brazilian regulations and the WHO Ambient AirQuality Guidelines, except for Particulate Matter PM10, in July, 2011, whichexceeded the guideline value of 50 µg/m³ (24-hour average concentration of52.92µg/m³).The second report refers to a monitoring campaign conducted in September2011. The results show that all the parameters comply with the Brazilianregulations and WHO Ambient Air Quality Guidelines, except for PM10,which exceeded the Interim target 3 value of 75µg/m³ (24-hour averageconcentration of 87.95µG/m³).The PM10 concentrations are apparently related to seasonal variations. Themonitoring campaign conducted in March (rainy season) showed much lowerresult (24-hour average of 8.3 µg/m³) than the campaigns conducted in Julyand September (dry season).3 DESCRIPTION OF COMPANY, ACTIVITIES AND PROJECTELDORADO BRASIL is engaged in the production of pulp and paper, beingone of the major global players in this sector. It is composed by the followingassets/activities: industrial, forest and logistics.Figure 3.1 presents the location of all activities and assets described above.ENVIRONMENTAL RESOURCES MANAGEMENT38ELDORADO - APRIL, 2012

Figure 3.1Project Location Map• Forestry Operations and Industrial Assets: Três Lagoas (MS)• Logistics Terminals: A. Taboado (MS), Pederneira (SP) and Santos (SP)Paraná RiverNovoeste RailwayFerroban RailwayCityMultimodal terminal PortSource: ELDORADO presentation to the banks, December/2011ENVIRONMENTAL RESOURCES MANAGEMENT39ELDORADO - APRIL, 2012

ELDORADO BRASIL has the following shareholders: J&F – 58,4%; MJ Empreendimentos – 25,0%; Petros – 8,2%; Funcef – 8,2%; and Vitória Asset – 0,1%.3.1 OVERVIEW OF INDUSTRIAL SITE AND CURRENT STATUSAccording to management representative of ELDORADO, the constructioninitiated in June 2010. The current status of the implementation is that around70% of the civil infrastructure has been installed and 7,750 contractor’spersonnel are working on-site (estimated). It is expected that, in March 2012,the number of contractors working on site reaches the maximum of 8,000workers, involved mainly in assembling of machines and production lines.ELDORADO reported facing difficulties in local hiring for which around 80%of contractors personnel are migrant workers from the Northeast or CentralWest regions of Brazil. Around 60% of those workers are living inaccommodations provided by ELDORADO, while the other 40% are living inaccommodations provided by contractors.Accommodations under ELDORADO responsibility are managed by a thirdpart company named Meta. This company is also responsible for monitoringconditions of accommodations provided by contractors. The EngineeringDepartment of ELDORADO is responsible for the construction management.The pulp mill operations, when completed, will comprise the following areas: Wood handling: Cooking; Unbleached pulp washing and screening; Oxygen delignification; White liquor oxidation; Pulp bleaching; Pulp drying;ENVIRONMENTAL RESOURCES MANAGEMENT40ELDORADO - APRIL, 2012

Pulp baling and storage; Production handling and storage of chemicals, including: Oxygen production; Hydrogen peroxide handling and storage; Sodium hydroxide handling and storage; Sulfuric acid handling and storage; Methanol handling and storage; Sodium chlorate production, handling and storage; and Chlorine dioxide production. Energy recovery, including: Black liquor evaporation; Recovery boiler; Power boiler (biomass-fueled); and Causticizing and lime kiln.Pulp transport associated facilities, include: Pier for docking of barges that will be used for the produced pulp inlandwater transportation; and Internal railway branch; Energy production in a small power station and distribution through atransmission line.Other auxiliary installations that will be part of the complex include: Water intake and treatment; Boiler water treatment system; Wastewater treatment system; Utilities;ENVIRONMENTAL RESOURCES MANAGEMENT41ELDORADO - APRIL, 2012

Steam and energy generation and distribution; Fuel station; and Industrial/sanitary landfill.Operation of the industrial complex is foreseen to start up in November 2012.The following sections present a brief description of the production areas asare being implemented. Emphasis is given, when appropriate, to theenvironmental controls of each area, associated with effluents generation andatmospheric emissions.3.1.1 Wood Handling3.1.2 CookingWood logs will be received from the forestry areas by trucks and debarkedthrough a dry debarking system (no effluents generation).Debarked logs will be conveyed to a washing station. Water for woodwashing will be kept in closed circuit, thus not generating effluents. Industrialwater will be introduced into the system to compensate for losses.After the washing station the wood logs will be chipped and chips stored in achip pile to be later fed to the digestion system. Prior to be fed to the digestionsystem, chips will be classified and off-specification chips will be sent to thebiomass pile to be used as fuel in the power boiler.The adopted concept of the cooking plant is continuous digester, which is, asreported, the current best available technology, not only associated with pulpproduction itself, but also in what refers to environmental performance, giventhat it allows better chemicals recovery, resulting in lower chemicalsconsumption and efficient energy conservation.Wood chips will be directed to the impregnation, where they are impregnatedwith hot black liquor from the digester cooking zone. Impregnated chips willthen be fed to the top of the digester and flow downwards in controlledtemperature and pressure conditions, for a sufficient time to allow thechemical reaction between the cooking liquor and the wood fibers bondingcomponents, mainly lignin.After the chemical reactions in the digester, the cooking liquor is turned intoblack liquor. The black liquor extracted from the digester is pumped through ablack liquor filter and heat exchanger (to recovery energy for the productionof hot water) before being sent to the weak black liquor tank in theevaporation plant.ENVIRONMENTAL RESOURCES MANAGEMENT42ELDORADO - APRIL, 2012

3.1.3 Pulp Washing and ScreeningThe brown stock (unbleached pulp) washing stage will accomplished usingrecycled filtrates from subsequent stages, thus minimizing chemicalsconsumption and effluent generation.The main purpose is to remove impurities from the pulp prior to thesubsequent processing steps. Separation will mechanically accomplished byscreen plates. The accepted fraction will be conveyed to the washing stagesand the screening rejects will be sent back to the digester.Washed pulp will be stored for subsequent delignification with oxygen.3.1.4 Oxygen DelignificationThe main goal of this stage is to remove residual lignin in the pulp, thusreducing the chemicals consumption in the bleaching stages and the effluentorganic load.In the delignification, the brown stock is mixed with oxidized white liquorproduced in the causticizing area or sodium hydroxide. Brown stock will beconveyed to the delignification feeding tank and subsequently to thedelignification reactor, where oxygen produced in the mill will be injected.The pulp will then be pumped to an additional screening and washing stage,to remove organic and inorganic impurities. Washed pulp will then be storedin the brown stock storage tank.3.1.5 Pulp BleachingPulp bleaching will be accomplished through an elementary chlorine-free(ECF) bleaching system. The ECF process, with the use of chlorine dioxide asthe main bleaching agent, represents the current best available technologyregarding minimization of chlorinated organics (AOX) in the effluent.In the future pulp mill, pulp washing will be accomplished by counter currentwashing systems between the bleaching stages, thus minimizing the effluentsgeneration.3.1.6 Pulp Drying and BalingBleached pulp will be stored in the bleached high-consistency pulp storagetower and from the tower it will be pumped to the drying machine.The drying machine is of the “floating sheet” type, in which the pulp floats ona stem-heated hot-air “mattress”.At the end of the drying machine, the pulp sheet will be cooled, cut and piledENVIRONMENTAL RESOURCES MANAGEMENT43ELDORADO - APRIL, 2012

to form 250-kg pulp bales, which will be transferred to the baling unit to form2.0-ton bale groups. The 2.0-ton pulp bales will then piled and stored in thebleached pulp warehouse prior to transportation to the port facilities forexport.3.1.7 Chemicals Production, Handling and StorageThe chemicals production and handling facilities will include: Oxygen productionOxygen will be produced on site by a third company (White Martins) in acryogenic air separator unit and will include liquid oxygen storage andvaporizers to be used in case of abnormal conditions in the oxygenproduction process, so as to guarantee the oxygen supply to the pulp mill.Oxygen will be used, for example, in the delignification process and in thewhite liquor oxidation. Hydrogen PeroxideHydrogen peroxide will be transported to the pulp mill in tank trucks inconcentrated solution (50 to 60%) and stored in a storage tank. From thestorage tank it will be pumped to the bleaching lines. Sodium Hydroxide Storage and HandlingSodium hydroxide 50% will be transported to the site in tank trucks andtransferred to storage tanks to be used in the liquor systems, oxygendelignification, bleaching and other areas such as the boiler watertreatment and wastewater treatment. Methanol Handling and StorageMethanol will be transported to the site by tank trucks and transferred tothe storage tank. From the storage tank, it will be pumped to the chlorinedioxide plant. Sodium Chlorate Production and StorageOriginally, sodium chlorate was going be acquired in the market andtransported to the plant by tanker trucks.Recently, after technical and economic feasibility studies, ELDORADOdecided to install a chlorate production plant on site. Reportedly,environmental aspects had also a significant weight in the decision,considering that instead of transporting the finished product, the site willreceive sodium chloride by trucks, thus minimizing environmental risks.ENVIRONMENTAL RESOURCES MANAGEMENT44ELDORADO - APRIL, 2012

Sodium chlorate is the main raw material for the production of chlorinedioxide that will be used in the bleaching line. Chlorine Dioxide Production3.1.8 Energy RecoveryChlorine dioxide will be produced on site through the methanol-basedmethod, by the reduction of sodium chlorate in acid media, using methanolas reducing agent, to obtain a chlorine dioxide solution.Chlorine dioxide will be used in the bleaching lines.ELDORADO energy recovery system will include: Black Liquor EvaporationThe main goal of the evaporation is the concentration of the weak blackliquor form the cooking stage to be burned in the recovery boiler.The evaporation system will concentrate the black liquor to a minimumsolids concentration of 80%. The evaporation system to be installed atELDORADO plant will be of the multi-stage indirect-contact type.Evaporation condensates will be segregated in different quality degrees.Cleaner condensates will be reused in the pulp washing processes.Intermediate condensates will be reused in the causticizing plant. Foulcondensate will be treated in a gas/liquid separation column (stripping)also allowing its reuse. Recovery BoilerThe main objective of the recovery boiler is to recover chemicals used in thepulp production process and the generation of steam used in theproduction process and for the generation of energy.The main fuel of the recovery boiler is the concentrated black liquorgenerated in the evaporation system. The organic matter present in theblack liquor provides the required calorific power for combustion and theinorganic content (mainly sodium carbonate and sodium sulfide) thatleaves the boiler as smelt is re-dissolved in the smelt dissolution tankgenerating the green liquor that will be further processed in thecausticizing area.The recovery boiler to be installed at ELDORADO pulp mill will be of thelow-odor emission type, with indirect contact, thus reducing the pollutantemissions to the atmosphere. It will also be equipped with high-efficiencyelectrostatic precipitator to retain particulates.ENVIRONMENTAL RESOURCES MANAGEMENT45ELDORADO - APRIL, 2012

Additionally, the recovery boiler will also be used as the primary control ofconcentrated and diluted non condensable gases, thus minimizing odoremissions. Power Boiler (biomass-fueled)The power boiler will burn eucalyptus bark and wood rejects as fuel andwill work as a backup system for the treatment of concentrated and dilutednon-condensable gases, in case of abnormal operational conditions of therecovery boiler.The boiler capacity is: Burning Biomass only t/h 70; Burning Fuel Oil only t/h 120; and Burning Biomass and Fuel Oil t/h 105.The power boiler will be equipped with a high-efficiency electrostaticprecipitator to retain particulates. Causticizing and Lime KilnThe green liquor produced in the recovery boiler smelting dissolving tankwill be further processed in the causticizing area to produce the cooking(white) liquor, through the reaction of sodium carbonate with sodiumoxide, producing sodium hydroxide and calcium carbonate, which will beseparated by filtration.Green liquor will be fed to the causticizers to be converted into whiteliquor, in one single line. Dregs and grits (inerts from the process) will bedried and will constitute an industrial waste. In the original project,ELDORADO would dispose of this waste in an industrial landfill to beconstructed in the complex. However, ELDORADO is currentlyconsidering sending these wastes to a composting system to be later usedas fertilizer.The calcium carbonate that is formed in the causticizing process will beconverted to calcium oxide to be used in the reaction with green liquor. Theoperation will be achieved in a rotary lime kiln.The lime kiln will be equipped with a high-efficiency electrostaticprecipitator to reduce the particulate emissions. The particulate removedfrom the exhaust gases in the precipitator will return to the lime kiln, thusreducing process losses and waste generation.ENVIRONMENTAL RESOURCES MANAGEMENT46ELDORADO - APRIL, 2012

3.1.9 Pulp Transport and Associated FacilitiesFinished bleached pulp will be transported to port facilities located in the cityof Santos, State of São Paulo, using preferably combined fluvial and railtransportation.An internal railway branch will be constructed providing a connection withthe existing railway system.Similarly, a pier will be constructed at the site, allowing the transportation offinished product by barges using the existing Paraná-Tietê hydro way untilthe municipality of Pederneiras, located in the State of São Paulo(approximately 350 km from the site) and from Pederneiras to the portfacilities via railway.Alternatively, the finished product can be transported by trucks or integratedhighway-railway system, as described in Section 3.0.3.1.10 Water Intake and TreatmentWater will be abstracted from Paraná River, downstream of the effluentdischarge outfall.ELDORADO is authorized to abstract a total flow of 7, 500 m³/h from ParanáRiver.Water intake will include mechanically cleaned bar screens, water pumps anda water pipeline that will convey the water to the treatment system.The treatment system will consist of a parshall flume, where chemicals(coagulant, flocculant, sodium hypochlorite and sodium hydroxide) will beadded. Subsequently the water will be submitted to flocculation, flotation,clarification (with lamellae settlers) and filtration in gravity sand filters.Treated water will be stored in a 30,000 m³ reservoir, including fire-fightingwater reserve (3,000 m³).Clarifier sludge will be conducted to the wastewater treatment system and thefilters backwash water to the beginning of the treatment process.For the construction stage, ELDORADO installed a temporary watertreatment plant, with the same unitary operations and 120-m³ capacity. Boiler Water TreatmentTreated water will be further treated in a reverse osmosis system toproduce demineralized water used for steam production in the boilers.ENVIRONMENTAL RESOURCES MANAGEMENT47ELDORADO - APRIL, 2012

3.1.11 Wastewater Treatment SystemIndustrial effluents will be segregated into two lines: solids-containingeffluents and solids-free (low solids) effluent.High solids effluent will be submitted to screening and primary clarificationprior to joining the low solids effluent in the neutralization tank, where theeffluent will have its pH adjusted. Primary sludge will be dewatered in screwpress and reportedly sold to be used as raw material by low-grade paperproducers or destined to a recycling central.The effluent will then be cooled in a cooling tower to lower the temperature toa suitable level for biological treatment.The biological treatment, which will also treat the sanitary effluents, willconsist of an activated sludge system composed of an aerated selective reactor(to eliminate filamentous organisms), an aeration tank, a secondary clarifierand biological sludge recycle. The excess biological sludge will be dewateredin a centrifuge system. Dewatered sludge will reportedly be treated in acomposting system to be used as fertilizer. It can alternatively be disposed ofin the industrial landfill to be constructed at the site.The effluent treatment system will include an emergency lagoon, which willreceive off-specification effluents from the process areas, to be graduallypumped to the wastewater treatment, in the neutralization tank, so as to avoidoperational disturbances.Treated effluent will be discharged into Paraná River, via an effluent outfall,upstream of ELDORADO’s water intake point.For the construction stage, ELDORADO implemented a sanitary wastewatertreatment system consisting of an aerated lagoon followed by a polishinglagoon. Treated sanitary effluent is being discharged to Paraná River, via atemporary effluent outfall.3.1.12 Waste ManagementELDORADO will construct an industrial landfill, designed to receive nonhazardouswastes (Class IIA and IIB, according to Brazilian classificationestablished in the standard ABNT NBR 10004). This landfill is included in theenvironmental licensing of the industrial project and the current InstallationLicense establishes parameters for groundwater monitoring at the industrialsite, including the land of the future landfill.The landfill will be constructed with compacted soil and will be lined withsynthetic (HDPE) membrane. It will be equipped with leak detection systemconnected to a monitoring sump.ENVIRONMENTAL RESOURCES MANAGEMENT48ELDORADO - APRIL, 2012

Leachate will be collected and pumped to the wastewater treatment system.For the construction stage, ELDORADO is disposing of non-recyclable wastes(mostly sanitary wastes) in a licensed sanitary landfill in Três Lagoas.Concrete debris is currently being piled in an area within the property. Thiswaste is currently being crushed and will be used in the forest areas to coverthe access roads, so as to minimize waste disposal.Hazardous wastes are being managed by a contractor, Podium, and arecurrently being temporarily stored in specific areas near the constructionworks, by each contractor prior to being removed, packed by Podium and sentto their final disposal. Podium is currently constructing a central hazardouswaste temporary storage area.3.2 OVERVIEW OF FORESTRY OPERATIONS AND CURRENT STATUSActivities and exploitation of eucalyptus plantation are being carried out onbehalf of the company Florestal Brasil (Florestal). ELDORADO Industrial andFlorestal have recently merged into one company, ELDORADO.The forest areas will support the operation of the pulp mill. Reportedly, inorder to operate the first production line, an area of 162 thousand hectares ofeucalyptus cultivation will be necessary. Therefore, the goal is to plant 26thousand hectares per year. Until December 2011 the planted area was 80thousand hectares.Regarding wood production it is expected a productivity of 40-50m³/year perhectare, according to soil and zoning studies performed by ELDORADO.Currently, according information provided during the site visit, 23.6% of theland is owned by the company and 76.4% are leased or are object ofpartnership contracts.The operation also involves a seedling nursery, working with six differenteucalyptus clones, in an area of 159,000 m² in the municipality of Andradina inSão Paulo state. ELDORADO directly employs 1,566 people in 6 differentmunicipalities (Três Lagoas, Selvíria, Inocência, Água Clara, Santa Rita doPardo at Mato Grosso do Sul State). 88% of these workers are rural workersand 37% of them are migrant workers from the states of Bahia, Maranhão,Piauí and the municipality of Aquidauana in Mato Grosso do Sul state. Allmigrant workers are men employed in planting and growing activities, whichinclude pesticides application, among other activities.Women are hired in the above mentioned cities and employed at the seedlingnursery, which has 260 workers employed.ENVIRONMENTAL RESOURCES MANAGEMENT49ELDORADO - APRIL, 2012

Besides, there are 534 contractors workers from two different companies:Plantar, JS Florestal and Ruah.The planting and maintenance, including the application of pesticides andherbicides, are held by ELDORADO and contractors, Ruah, JS Florestal andPlantar.3.2.1 Management SystemRegarding management system, the Forestry Operation has software forproject management which includes environmental activities such asprocedures regarding assessment of planting or wood cutting areas. Aprocedure has been recently defined in order to assess economic,environmental and social aspects of the owned, leased or partnership areas.This procedure is called PTEAS – Economic, Environmental and SocialTechnical Project (“Projeto Técnico Econômico, Ambiental e Social”) and it isdeveloped by a multidisciplinary team.The Forestry Operation intends to have by 2017 all the wood used in theproject certified by FSC- Forest Stewardship Council. All the process that theForestry Operation manages will be certified.The certification process will be conducted in phases. The first phase involvesall the existing planted wood and the ones to be planted until July 2012. Preauditis scheduled for March 2012 and final audit in July 2012. After thatELDORADO will include the new plantings in the scope year by year. Moredetails about FSC certification can be obtained in Section 3.5.3.2.2 Forestry Operations DescriptionELDORADO (Forestry Operations) is currently working with 4 models ofland contract: Land owned by ELDORADO; Leased land; Partnership land, and Wood supplier.Land owned by ELDORADO:ELDORADO is responsible for the whole forestry operations, which meansplanting, maintenance, harvesting and transportation of the wood, employingELDORADO’s employees or contractors workers. It is also responsible forcomplying with environmental legislation.ENVIRONMENTAL RESOURCES MANAGEMENT50ELDORADO - APRIL, 2012

Leased Land:ELDORADO rents the land for 14 years, 2 eucalyptus cycles. ELDORADO isresponsible for the whole forest operation, which means planting,maintenance, harvesting and transportation of the wood, employingELDORADO’s employees or contractors workers.Partnership land:For partnership contracts, ELDORADO is in charge of the operation and itscosts, for which it will receive a percentage of wood production (80%). Thepartner, the land owner, can choose to sell his percentage of the wood toELDORADO or others.ELDORADO is also responsible for the whole forestry operations, whichmeans planting, maintenance, harvesting and transportation of the wood,employment and/or contractors workers.There are currently 121 partnership and leased land contracts in 12municipalities: Água Clara/MS, Selvíria/MS, Três Lagoas/MS, Santa Rita doPardo/MS, Pontal do Araguaia/MT, Corumbá/MS, Alto Araguaia/MS,Inocência/MS, Dois Irmãos do Buriti/MS, Ribas do Rio Pardo/MS, Aparecidado Taboado/MS and Anastácio/MS.To sign a contract for leased land and partnership, ELDORADO request theland owner provide several documents to verify that the land is in compliancewith environmental and social legislation.ELDORADO is responsible to operate the land in compliance with Brazilianenvironmental and social Legislation.Wood Supplier:ELDORADO will be in charge of harvesting and transport in the majority ofthe suppliers, while the land owner was in charge of planting and growing.Reportedly, wood supply will be used in the first years of operation, until2016. The wood will arrive from the states of São Paulo, Minas Gerais, MatoGrosso do Sul and Mato Grosso. Wood from São Paulo will be transported byriver and the others by truck. Table 3.1 shows the wood supply program forthe following years.ENVIRONMENTAL RESOURCES MANAGEMENT51ELDORADO - APRIL, 2012

Table 3.1Wood Supply ProgramState Municipality Owner Type of HarvestingHarvesting Volume (Thousend m³sc)2012 2013 2014 2015 2016MS Água Clara Paulo Formigoni Eldorado - 577 839 - - 1.416MSMSMSRibas do RioPardo Grupo Mutum Eldorado 316 - 86 - - 402Ribas do RioPardo N. BIASI Eldorado - - - 357 - 357Três LagoasTotalRODRIGOARRUY Eldorado - - 18 - - 18MS Água Clara Paulo Bentivoglio Eldorado - - 82 - - 82MS Brasilândia Paulo Baldini Eldorado - - 145 - - 145MSRibas do RioPardo Maria Aparecida Eldorado - 55 - - - 55MS Água Clara José Arnaldo Eldorado - - 55 - - 55MSRibas do RioPardo Rinaldo Rocha Eldorado 24 76 - 52 - 152MS Campo Grande Vitório Maronese Eldorado 91 - - - - 91SP Paranapanema PJB Third Part 60 - - - 60SP Paranapanema PJB Third Part 90 - - - 90MS Água Clara João Cancio Eldorado - - 106 72 - 178SPPiedadeProsperi(Alberto) Third Part 48 80 40 40 30 238SP Angatuba DURATEX Eldorado 210 1.178 636 - - 2.024MG Nova Ponte DURATEX Third Part 65 111 - - - 176SP Lençois Lwarcel Eldorado - 52 148 99 - 299SP Cafelandia Bertin Eldorado 203 - 118 - - 321SPPaulistâniaInternationalPaper Eldorado 143 125 - - - 268SP Agudos Paulo Formigoni Eldorado - 296 - - - 296Total SP 664 1.821 942 139 30 3.596Total MS 431 708 1.331 481 - 2.951Total MG 65 111 - - - 176Total Geral 1.160 2.640 2.273 620 30 6.723ELDORADO has a procedure for the Development of Environmental, Socialand Technical Project (PTEAS) which should be applied to every farm 1 or 2months before intervention (planting and harvesting) to support landmanagement. This PTEAS should be developed by a multidisciplinary groupcomposed of representatives of the following areas/departments: social,cartography, environmental, certification, communication (communityrelations), harvesting, agroforestry, health and safety and logistic. Eachrepresentative is responsible to identify the technical features of the farm tosupport the land management planning. This procedure is dated December2011 and PTEAS was not carried out at farms in which planting wasperformed before it.ENVIRONMENTAL RESOURCES MANAGEMENT52ELDORADO - APRIL, 2012

3.3 OVERVIEW OF THE LOGISTICS PROJECTBased on technical, economic and environmental feasibility factors,ELDORADO will construct two multimodal terminals according to twodistinct models, as described below: Model 1: road transportation from the industrial plant to Aparecida doTaboado (90km) multimodal terminal, to be built by the Company and,then, railroad transportation to Santos Port (900 km), where the productwill be loaded into ships for exportation; and Model 2: transportation from the industrial plant to Pederneirasmultimodal terminal by barges through Tietê river (350 km) and, then,using a third party railway (MRS) to Santos Port (520 km), where theproduct will be loaded into ships for exportation. In the port of Santos,ELDORADO will construct and improve two terminals. One of themcomprises existing Warehouses IX, X, XI and XII of the Organized Port ofSantos (Porto Organizado de Santos), hereinafter referred as TerminalEldorado and the other area comprises the warehouses III, VIII, XIII andXVIII, hereinafter referred as Terminal Elmar, as identified byELDORADO.Further information is provided in the sections ahead for each terminal.3.3.1 Aparecida do Taboado Multimodal TerminalIn Aparecida do Taboado, ELDORADO acquired a parcel of land, with 61.7hectares, which was part of a farm (Fazenda Boa Esperança). As informed, inPederneiras a warehouse will be constructed by ELDORADO, withapproximately 6,000-m² covered area. The finished product from the pulp millin Três Lagoas will be transported by trucks through Federal BR-158 highway(Rodovia BR-158) and secondary State road MS-316.Bleached pulp will be unloaded and stored in the warehouse. Stored pulp willthen be loaded to rail compositions and transported to the Santos portterminal by existing railway operated by the concessionaire ALL (AméricaLatina Logística).According to ELDORADO site contacts, the company will be responsible forthe construction of the terminal, but all the operation will be carried out byALL.The terminal is still in project stage and the construction works have not yetstarted. An internal railway branch will also be part of the project and will beconstructed by ELDORADO.ENVIRONMENTAL RESOURCES MANAGEMENT53ELDORADO - APRIL, 2012

3.3.2 Pederneiras Multimodal TerminalThis model considers the transportation of bleached pulp bales by barges fromthe pulp mill to the multimodal terminal located in the municipality ofPederneiras, approximately 350 km from Três Lagoas, in the State of SãoPaulo, using the existing Tietê - Paraná hydro way. In Pederneiras, onewarehouse and one internal railway branch will be constructed.The pulp mill project comprises the construction of a pier at ELDORADO sitein Três Lagoas, which is already included in the pulp mill licensing process.The Pederneiras terminal destined to ELDORADO’s support operationsconsists of the expansion of an existing terminal operated by privatecompanies EPN/Torque. ELDORADO established a contract with thenavigation company EGTM Navegação (Torque), which will be responsible forthe expansion of the existing terminal and the construction of the requiredwarehousing space for pulp storage, as well as will be in charge of obtainingall the required permits. The existing operations at the terminal are mostlyrelated to grains storage and transportation. No further details are availableregarding the expansion.Similarly, a new railway branch will be constructed in the terminal. Therailway lines from Pederneiras to Santos Port are operated by theconcessionaire MRS Logística, which will reportedly be responsible for theconstruction of the railway branch and obtaining all required authorizations.The contract was not provided for analysis.The operation of the Pederneiras multimodal terminal will be responsibility ofthe existing operator EGTM Navegação – Torque.3.3.3 Santos Port TerminalBackgroundSantos Port administration was granted, since 1888 through an imperialdecree, to an economical group (Gaffre, Guinle & Cia.) that won a publictender process. The group constituted a company called Companhia Docas deSantos, which was granted 39 years concession for the port administration,later extended to 90-year concession.In 1980, the legal concession period expired and the Federal governmentconstituted the company Companhia Docas do Estado de São Paulo – CODESP,which is the current port authority in Santos.CODESP delegates the port operation to private operators through publictender processes.ENVIRONMENTAL RESOURCES MANAGEMENT54ELDORADO - APRIL, 2012

ELDORADO intends to construct and operate two port terminals in Santos.However, due to time constraints, two different situations will occur. A brieftimeline of the port operations by ELDORADO is presented herein.First Two Years of Operation – Terminal ElmarERM visited the area of the Terminal Elmar on February 10, 2012 and wasaccompanied in the visit by Mr. Alvaro Bunster, Eldorado’s LogisticsExecutive Manager.ELDORADO acquired part of the shares of a company that already operates aport terminal in the port of Santos. The company operates with solid bulkmaterials and is in conformance with the Santos Port Development andZoning Plan (PDZPS – Plano de Desenvolvimento e Zoneamento do Porto de Santos– CODESP, 2006), which allows the handling and movement of solid bulkmaterials of vegetal or mineral origin, liquids of vegetal origin, containers andgeneral loads at that area. ELDORADO operations will also be in compliancewith this zoning regulation, given that pulp is classified as general load.The concession acquired by ELDORADO comprises two existing warehousescurrently operating (Warehouses III and VIII), one area corresponding to ademolished warehouse (Warehouse XIII) and one warehouse in process ofdemolition (Warehouse XVIII).For the first two years of operation, ELDORADO has also established aservice provision contract to use an area out of the organized port of Santos,which is operated by a company named Hipercon Terminais. According toinformation provided by the company’s contacts, in this area two tarpaulinsheds will be assembled and one internal railway branch will be constructed.The tarpaulin sheds will constitute a buffer for the ships loading. Oneadditional railway branch will also be constructed by the railwayconcessionaire at that area, parallel to existing railway lines, directlyconnecting Hipercon’s area to the port terminal area. Reportedly, ELDORADOwill finance the construction of the required infrastructure in Hipercon’s area,but the operations will remain in the name of that company, which will beresponsible for obtaining all the required permits for construction.Two tarpaulin sheds will also be assembled in the Terminal Elmar, on the areacorresponding to the Warehouse XIII, already demolished and on the areacorresponding to Warehouse XVIII, in process of demolition.In order to be allowed to demolish warehouse XVIII, ELDORADO is requiredto develop a demolition plan and submit it to CODESP, which will issue anauthorization. ELDORADO has already developed the demolition plan andsubmitted to CODESP and is currently waiting for the company’sauthorization. The tarpaulin sheds at Terminal Elmar will also work as abuffer for the ships loading.ENVIRONMENTAL RESOURCES MANAGEMENT55ELDORADO - APRIL, 2012

Initially, the pulp from the industrial complex in Três Lagoas will arrive to thearea operated by Hipercon and will be unloaded at the tarpaulin sheds to beconstructed. Pulp will then be loaded and transported by trucks to the area ofTerminal Elmar, where it will be either unloaded to the tarpaulin sheds in theterminal area or directly to the ships. At the port terminal, the transport ofpulp from the tarpaulin sheds to the mooring berths will initially beaccomplished by trucks.It is expected that the issuance of all the required authorizations, the processof constructing the internal railway branches and assembly of the tarpaulinsheds in Hipercon’s area, the demolition of Warehouse XVIII and the assemblyof the tarpaulin sheds in the Terminal Elmar’s area will take approximately sixmonths, coinciding with the pulp mill startup, thus allowing the initialoperation in the Port of Santos.After this initial operation stage, ELDORADO will demolish Warehouses IIIand VIII and construct new warehouses, which will be specifically designedfor the movement of pulp bales, using cranes (automated operation).ELDORADO also foresees the installation of a conveyor, connecting thewarehouses to the mooring berths (approximately 300 m), thus reducing thetraffic of trucks in the region.ELDORADO expects that the process of obtaining all required authorizations,improving the existing warehouses, construction of the railway branch untilthe Terminal Elmar area and installing the conveyor, will take approximatelytwo years. After this period, ELDORADO will leave Hipercon’s area and willdefinitively operate only in Terminal Elmar’s area.Future Operations – Terminal ELDORADOForeseeing the future expansions of the pulp production industrial complex inTrês Lagoas, ELDORADO will also build one additional terminal,approximately 500 meters north of Terminal Elmar area.This terminal corresponds to the existing warehouses IX, X, XI and XII, whichare currently operating. As the concession granted by CODESP for theoperation of these warehouses is about to expire, a new public tender isongoing. ELDORADO is participating of this public tender process.ELDORADO has already submitted to CODESP the project of the newterminal. Considering that the warehouses are in area of Federal management(area belonging to the Federation), ELDORADO has also submitted theproject to the Federal Environmental Agency – IBAMA.The Terminal Eldorado will consist of four warehouses, whose improvementwill be specifically designed for the movement of pulp bales using cranes(automated operation).ENVIRONMENTAL RESOURCES MANAGEMENT56ELDORADO - APRIL, 2012

Two internal railway branches will be constructed by the railwayconcessionaire at the area, thus releasing the existing railway lines for thetraffic of other compositions and avoiding traffic congestion.The timeline for completion of the second port terminal in Santos is not yetdefined.3.4 ENVIRONMENTAL LICENSING PROCESSAs part of the scope, ERM assessed if the environmental licensing process,which includes the Environmental Impact Assessment (EIA) study, publichearings and the environmental basic programs, was performed incompliance with Brazilian regulations. The Brazilian environmentalpermitting legislation and detailed information of the licensing status processis shown in Annex B.Items 3.4.1 and 3.4.2 present a summary of the licensing status of the project.3.4.1 Industrial and Forest OperationsThe pulp mill has been granted, until the present moment, with Preliminaryand Installation Permits by the State Environment Agency IMASUL – MatoGrosso do Sul Environmental Institute (Instituto de Meio Ambiente do MatoGrosso do Sul). Installation License nº 17/2011 issued on February 24 th , 2011,valid until March 26 th , 2013, refers to the second step of the environmentallicensing process, which includes the approval of the environmental andsocial impact assessment (EIA) and also the proposed environmentalmonitoring plans outlined in the Impact assessment study and then detailedwithin an Environmental Basic Plan - PBA (Plano Básico Ambiental). Therequirements of both licenses are being implemented. The environmentalprograms PBA (Plano Básico Ambiental) Basic Environmental Plans arecurrently being implemented. Therefore, the company is in complianceregarding the environmental licensing process.In addition, ELDORADO has recently decided to include a sodium chloratemanufacturing plant on site, instead of transporting the sodium chlorate bytank trucks from market suppliers. As a result, it applied for an InstallationPermit for the plant expansion on August 31, 2011. Additionally, it developedan environmental study (EAP – Estudo Ambiental Preliminar) and a riskanalysis, considering the presence of the Chlorate plant to subsidize thelicensing process. The Installation Permit for the Chlorate Plant has not beenissued to date.The company foresees the completion of installation in November, 2012.Afterwards it will apply for the Operating Permit. In the meantime,ELDORADO applied for a permit for the commissioning stage on November18 th , 2011 in order to include in the Installation Permit the commissioning of:ENVIRONMENTAL RESOURCES MANAGEMENT57ELDORADO - APRIL, 2012

pulp production, chemical recovery, utilities and manufacturing systems forsodium chlorate, chlorine dioxide and oxygen manufacture.ERM observed, that ancillary installations, such as power transmission lines,railway, pier and fuel station have distinct licensing processes and thereforewould require their own preliminary, installation and operating licenses.The Forestry Operations are not subjected to environmental licensingprocess, according to the Brazilian regulations. According to samples ofdocuments from eucalyptus cultivating areas, provided during site visit, theForestry Operations comply with licensing requirements and procedureswith the state environmental agency.3.4.2 Logistics ProjectThe environmental licensing process differs for each area of the logisticalundertaking.Regarding the intermodal terminal in Aparecida do Taboado-MS, it issubjected to the Mato Grosso do Sul environmental agency (IMASUL). ASimplified Environmental Report- RAS was developed and, reportedly, it hasbeen submitted to the environmental agency in order to be granted with thepreliminary license.As for the Pederneiras site, licensed under São Paulo environmental agency(Cetesb), the area will be operated by a third party company which throughcontract must comply with environmental legislation, obtain and maintain allpermits and licenses required. ELDORADO declares that has no responsibilityregarding permits or licensing of the area, however, a co-responsibilityrelating to environmental and social compliance exists and, therefore, theCompany should ensure that all third parties’ companies comply with theapplicable regulations.Regarding the areas of the Port Terminal in Santos, currently three areas areunder the scope of the logistics undertaking: i)A temporary warehouse,outside the so called organized port, licensed under São Paulo environmentalagency (Cetesb), which is owned by a third company that will also operateand be responsible for all environmental permits and compliance withlegislation; ii)The warehouses III, VIII, XIII and XVIII, inside the “ElmarTerminal”, also licensed under Cetesb, purchased by ELDORADO fromRodrimar S/A Transportes Equipamentos Industriais e Armazéns Gerais.Warehouses XIII are not currently housing any operations. Warehouse XVIIIhas already been demolished and the area is released for the construction of anew warehouse, as intended by Eldorado. Warehouse XVIII is currently inprocess of demolition with the Santos Port Authority (CODESP), to allow thefuture construction of a new warehouse. This area has operating permit (forwarehouses III and VIII according to Cetesb’s site) under the third company’sname and no information has been provided regarding changes in theENVIRONMENTAL RESOURCES MANAGEMENT58ELDORADO - APRIL, 2012

corporate name of these permits; iii) The permanent area of the organizedport, of warehouses IX to XII, which are licensed under FederalEnvironmental Agency (IBAMA), that ELDORADO has submitted a letter ofintroduction of the project in order to start the permit process and require aterm of reference. However, the area is still waiting for bidding from CODESPwhich is the institution that manages the Port of Santos. Again, a coresponsibilityrelationship relating to environmental and social complianceexists and, therefore, the Company should ensure that all third parties’companies comply with the applicable regulations.3.5 FOREST CERTIFICATION AND SOCIAL PROGRAMS Forest Stewardship CouncilThe Forest Stewardship Council (FSC) is an international body whichaccredits certification organizations in order to guarantee the authenticityof their claims. In all cases the process of certification will be initiatedvoluntarily by forest owners and managers who request the services of acertification organization. The goal of FSC is to promote environmentallyresponsible, socially beneficial and economically viable management of theworld's forests, by establishing a worldwide standard of recognized andrespected Principles of Forest Stewardship.The FSC's Principles and Criteria (P&C) apply to all tropical, temperate andboreal forests, as addressed in Principle #9 and the accompanying glossary.Many of these P&C apply also to plantations and partially replantedforests.The FSC is based on internationally-acceptable principles and criteria forsustainable forest management, and include the following principles: Principle #1: Compliance with laws and FSC Principles. Forestmanagement shall respect all applicable laws of the country in which theyoccur, and international treaties and agreements to which the country is asignatory, and comply with all FSC Principles and Criteria. Principle #2: Tenure and use rights and responsibilities. Long-termtenure and use rights to the land and forest resources shall be clearlydefined, documented and legally established. Principle #3: Indigenous peoples' rights. The legal and customary rightsof indigenous peoples to own, use and manage their lands, territories, andresources shall be recognized and respected. Principle #4: Community relations and worker's rights. Forestmanagement operations shall maintain or enhance the long-term social andeconomic well-being of forest workers and local communities.ENVIRONMENTAL RESOURCES MANAGEMENT59ELDORADO - APRIL, 2012

Principle #5: Benefits from the forest. Forest management operations shallencourage the efficient use of the forest's multiple products and services toensure economic viability and a wide range of environmental and socialbenefits. Principle #6: Environmental impact. Forest management shall conservebiological diversity and its associated values, water resources, soils, andunique and fragile ecosystems and landscapes, and, by so doing, maintainthe ecological functions and the integrity of the forest. Principle #7: Management plan. A management plan -- appropriate to thescale and intensity of the operations – shall be written, implemented, andkept up to date. The long term objectives of management, and the means ofachieving them, shall be clearly stated. Principle #8: Monitoring and assessment. Monitoring shall be conducted -- appropriate to the scale and intensity of forest management -- to assessthe condition of the forest, yields of forest products, chain of custody,management activities and their social and environmental impacts. Principle #9: Maintenance of high conservation value forests.Management activities in high conservation value forests shall maintain orenhance the attributes which define such forests. Decisions regarding highconservation value forests shall always be considered in the context of aprecautionary approach. Principle #10: Plantations. Plantations shall be planned and managed inaccordance with Principles and Criteria 1 - 9, and Principle 10 and itsCriteria. While plantations can provide an array of social and economicbenefits, and can contribute to satisfying the world's needs for forestproducts, they should complement the management of, reduce pressureson, and promote the restoration and conservation of natural forests.ELDORADO has been preparing to obtain a FSC (Forest Stewardship Council)certification for 1,5 years. The company intends to certify the forestmanagement (owned and lease lands and partnership agreement) and thewood custody chain.To accomplish this goal, ELDORADO already started to prepare the forestmanagement certification; they undertook training, formed working groups,elaborated and executed an action plan, hired the certification company (SCSFlora) and received their technical visit. They also elaborated the ForestManagement Plan, which first version was verified by the CertificationCompany. This plan does not include the regions of Anastácio and Doisirmãos do Buruti municipalities.The pre-certification audit to the wood process is planned to April/2012 andthe certification audit to August/2012. After that, the company will start theENVIRONMENTAL RESOURCES MANAGEMENT60ELDORADO - APRIL, 2012

process to certify the custody chain. This second certification process goesfrom September/2012 to November/2012, when the custody chaincertification audit is planned to occur.In relation to the actions to attend all FSC requirements, ELDORADO hasdeveloped an action plan to FSC Principles and Criteria implementation. Forcertification purposes, it is not necessary to accomplish 100% of all FSCPrinciples and after the certification it is not necessary to maintain an actionplan, however, regular audits will be performed in order to guarantee that thecompany has been improving its management system and attendance of theprinciples. The updated status of certification, attendance of FSC principlesand actions that need to be implemented are described in the table below:ENVIRONMENTAL RESOURCES MANAGEMENT61ELDORADO - APRIL, 2012

Table 3.2ELDORADO’s FSC Certification StatusPrinciples & Criteria - FSCPrinciple #1: Compliance with laws and FSC PrinciplesForest management shall respect all applicable laws of the country in which theyoccur, and international treaties and agreements to which the country is asignatory, and comply with all FSC Principles and Criteria.1.1 Forest management shall respect all national and local laws and administrativerequirements.1.2 All applicable and legally prescribed fees, royalties, taxes and other chargesshall be paid.1.3 In signatory countries, the provisions of all binding international agreementssuch as CITES, ILO Conventions, ITTA, and Convention on Biological Diversity,shall be respected.1.4 Conflicts between laws, regulations and the FSC Principles and Criteria shall beevaluated for the purposes of certification, on a case by case basis, by the certifiersand the involved or affected parties.1.5 Forest management areas should be protected from illegal harvesting,settlement and other unauthorized activities.1.6 Forest managers shall demonstrate a long-term commitment to adhere to theFSC Principles and Criteria.1.7 The responsible for the Unit of Forest Management (UMF) under certificationmust declare its long-term commitment to the maintenance of representativesamples of existing ecosystems as (P6.c4), from areas such as legally protected (PPAand LR).Principle #2: Tenure and use rights and responsibilitiesLong-term tenure and use rights to the land and forest resources shall be clearlydefined, documented and legally established.ELDORADO selfassessmentStatus (% complete)12/April/2012919186100 -Necessary actions to fully accomplish the criteria of eachprincipleIncrease the sampling of the IVC (Contracts Verification Items).Obtain the collective bargaining agreement (July).Prove fees exemption. This item will become "Not Applicable"until the next evaluation round.75 Create a crisis committee.93 Establish systematic of patrols, recycling, etc.100 -8584If there are PPA or LR areas, the company will have to registerthen. But today no RPPN areas exist in the company's land, sothis item will become "Not Applicable" at the next evaluationstage.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201262

Principles & Criteria - FSC2.1 Clear evidence of long-term forest use rights to the land (e.g. land title,customary rights, or lease agreements) shall be demonstrated.2.2 Local communities with legal or customary tenure or use rights shall maintaincontrol, to the extent necessary to protect their rights or resources, over forestoperations unless they delegate control with free and informed consent to otheragencies.2.3 Appropriate mechanisms shall be employed to resolve disputes over tenureclaims and use rights. The circumstances and status of any outstanding disputeswill be explicitly considered in the certification evaluation. Disputes of substantialmagnitude involving a significant number of interests will normally disqualify anoperation from being certified.2.4 The responsible for the UMF (Unit of Forest Management) should respectcustomary recognized rights of local communities who have no legal rights of landpossession or use, seeking uses mechanisms that help then to legalize their rightsand establishing agreements to ensure the presence of these communities inharmony with the forest management operations, or to promote resettlement, andin last case, fare compensation.ELDORADO selfassessmentStatus (% complete)12/April/201287100 -100 -100 -Necessary actions to fully accomplish the criteria of eachprincipleObtain consent from the owners to allow the inspection ofproperty register (leased lands). Only 80% of owners have giventhis consent until this moment.3 Principle #3: Indigenous peoples' rightsThe legal and customary rights of indigenous peoples to own, use and managetheir lands, territories, and resources shall be recognized and respected.100This principle was considered in compliance during thecertification company technical visit.3.1 Indigenous peoples shall control forest management on their lands andterritories unless they delegate control with free and informed consent to otheragencies.3.2 Forest management shall not threaten or diminish, either directly or indirectly,the resources or tenure rights of indigenous peoples.3.3 Sites of special cultural, ecological, economic or religious significance toindigenous peoples shall be clearly identified in cooperation with such peoples, andrecognized and protected by forest managers.3.4 Indigenous peoples shall be compensated for the application of their traditionalknowledge regarding the use of forest species or management systems in forestoperations. This compensation shall be formally agreed upon with their free andinformed consent before forest operations commence.100 -100 -100 -100 (N/A) -ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201263

Principles & Criteria - FSC3.5 Objective measures should be taken to avoid the negative social impacts offorest management activities in order to contribute to the enhancement of thediversity of indigenous and traditional communities.3.6 The management responsible should provide information on identification,location and population of all indigenous communities, traditional communities inareas under forest management, bordering areas, and areas that have been claimedin relation to customary rights over the area to be certified.3.7 Indigenous communities and / or traditional communities that live in areasunder forest management or bordering areas, should directly control the use oftheir natural resources, they can establishing contracts and partnerships forplanning and implementation of management plans in their territories.Principle #4: Community relations and worker's rightsForest management operations shall maintain or enhance the long-term socialand economic well-being of forest workers and local communities.ELDORADO selfassessmentStatus (% complete)12/April/2012100 -100 -100 -89Necessary actions to fully accomplish the criteria of eachprinciple4.1 The communities within, or adjacent to, the forest management area should begiven opportunities for employment, training, and other services.4.2 Forest management should meet or exceed all applicable laws and/orregulations covering health and safety of employees and their families.4.2A All workers in the forest management unit should have access to health, inobedience of the law.4.2B There must be sanitary and environmental conditions appropriate to theperformance of activities.4.3 The rights of workers to organize and voluntarily negotiate with theiremployers shall be guaranteed as outlined in Conventions 87 and 98 of theInternational Labor Organization (ILO).4.4 Management planning and operations shall incorporate the results ofevaluations of social impact. Consultations shall be maintained with people andgroups (both men and women) directly affected by management operations1.759077899297Do partnerships with the government. Make an agreement towork with Universities.Make the company's health campaigns together / in the sameperiod of the municipal government health campaigns.Make the company's health campaigns together / in the sameperiod of the municipal government health campaigns.Make the company's health campaigns together / in the sameperiod of the municipal government health campaigns.The labor union will be institutionalized in July; the meeting toapprove the collective bargaining agreement will be at the samemonth. After accomplish this task this criteria will be 100% incompliance.Run two more PTEAS during harvest period to validate thesystematic to evaluate social impacts.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201264

Principles & Criteria - FSC4.5 Appropriate mechanisms shall be employed for resolving grievances and forproviding fair compensation in the case of loss or damage affecting the legal orcustomary rights, property, resources, or livelihoods of local peoples. Measuresshall be taken to avoid such loss or damage.4.6 The responsible for forest management should consider the social initiatives thatshould be included in planning and operations of forest management activities.Must be maintained and proven clear information and opportunity of participationfor local community directly affected for forest management operations and theirviews on the aspects that directly affect their quality of life should be considered.ELDORADO selfassessmentStatus (% complete)12/April/2012Necessary actions to fully accomplish the criteria of eachprinciple97 Create a crisis committee.85Increase the amount of PTEAS executed and solve the identifiedproblems.4.7 There should be a mechanism for dialogue and resolution of complaintsbetween the workers and the responsible for the UNIT of forest management,including a person to represent formally the workers, recognized by then.68The company already has an initiative in which the HR teamgoes to the field to collect the field staff claims, but they still lackin give responses to then in relation to their claims.Make minutes of the dialogues between the committee and thecommunity.Create the crisis committee.4.8 The workers must have remuneration at least compatible with the average ofthe market in the region, in accordance with the productive activity performed.4.9 It should not be used child labor against the law on the forest management unit.The work of the appendices is allowed only in activities not considered danger...4.10 The women working during pregnancy and breastfeeding period should beaccompanied of preventive dangers and risk measures inherent to the productiveactivity performed.4.11 In case of substantial changes in the workforce of the Unit of ForestManagement, preventive actions should be taken to minimize the impacts of layoffson workers and local community.4.12 The adoption of programs or strategies to flexibilize work should not result indamage to the rights legally acquired by the workers and the local community.100 -100 (N/A) -100 -93100 -As the company has a lack of local labor, they do not dismissemployees when the activity ends in a certain region; they justrelocate the staff to other Operational Management Unit(Unidade de Gerenciamento Operacional UGO). But they do nothave procedure for demonstrating this guideline, so it will bedemonstrated only during the audit.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201265

Principles & Criteria - FSC4.13 The community's access to management and non-predatory collection of forestproducts, from wood or not, is allowed in the places where such access alreadyexisted for legal or historical reasons, for that the user has to have formalauthorization from the responsible for the forest management unit ,respectingproperty rights.ELDORADO selfassessmentStatus (% complete)12/April/2012100 -Necessary actions to fully accomplish the criteria of eachprinciplePrinciple #5: Benefits from the forestForest management operations shall encourage the efficient use of the forest'smultiple products and services to ensure economic viability and a wide range ofenvironmental and social benefits.100To achieve 100% of attendance in this principle, Eldoradoexecuted initiatives such as conducted a study with Sebrae tomake beekeeping activities at the company's farms to becarried out with local beekeepers.5.1 Forest management should strive toward economic viability, while taking intoaccount the full environmental, social, and operational costs of production, andensuring the investments necessary to maintain the ecological productivity of theforest.5.2 Forest management and marketing operations should encourage the optimaluse and local processing of the forest's diversity of products.5.3 Forest management should minimize waste associated with harvesting and onsiteprocessing operations and avoid damage to other forest resources.5.4 Forest management should strive to strengthen and diversify the local economy,avoiding dependence on a single forest product.5.5 Forest management operations shall recognize, maintain, and, whereappropriate, enhance the value of forest services and resources such as watershedsand fisheries.5.6 The rate of harvest of forest products shall not exceed levels which can bepermanently sustained.Principle #6: Environmental impactForest management shall conserve biological diversity and its associated values,water resources, soils, and unique and fragile ecosystems and landscapes, and,by so doing, maintain the ecological functions and the integrity of the forest.100 -100 -100 -100 -100 -100 -75ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201266

Principles & Criteria - FSC6.1 Assessment of environmental impacts shall be completed -- appropriate to thescale, intensity of forest management and the uniqueness of the affected resources -- and adequately integrated into management systems. Assessments shall includelandscape level considerations as well as the impacts of on-site processing facilities.Environmental impacts shall be assessed prior to commencement of site-disturbingoperations.6.2 Safeguards shall exist which protect rare, threatened and endangered speciesand their habitats (e.g., nesting and feeding areas). Conservation zones andprotection areas shall be established, appropriate to the scale and intensity of forestmanagement and the uniqueness of the affected resources. Inappropriate hunting,fishing, trapping and collecting shall be controlled.6.3 Ecological functions and values shall be maintained intact, enhanced, orrestored, including:a) Forest regeneration and succession.b) Genetic, species, and ecosystem diversity.c) Natural cycles that affect the productivity of the forest ecosystem.6.4 Representative samples of existing ecosystems within the landscape shall beprotected in their natural state and recorded on maps, appropriate to the scale andintensity of operations and the uniqueness of the affected resources.6.5 Written guidelines shall be prepared and implemented to: control erosion;minimize forest damage during harvesting, road construction, and all othermechanical disturbances; and protect water resources.6.6 Management systems shall promote the development and adoption ofenvironmentally friendly non-chemical methods of pest management and strive toavoid the use of chemical pesticides. World Health Organization Type 1A and 1Band chlorinated hydrocarbon pesticides; pesticides that are persistent, toxic orwhose derivatives remain biologically active and accumulate in the food chainbeyond their intended use; as well as any pesticides banned by internationalagreement, shall be prohibited. If chemicals are used, proper equipment andtraining shall be provided to minimize health and environmental risks.6.7 Chemicals, containers, liquid and solid non-organic wastes including fuel andoil shall be disposed of in an environmentally appropriate manner at off-sitelocations.ELDORADO selfassessmentStatus (% complete)12/April/20128892100 -8092Necessary actions to fully accomplish the criteria of eachprincipleThe environmental aspects and impacts have been identified,but the company need to implement the necessary actionsrelated to them.Eldorado needs to make an agreement with the university formonitoring and tracking areas with high conservation value(AAVC).The company needs to spread the emergency response plan(PAE)The environmental aspects and impacts have been identified,but the company need to implement the necessary actionsrelated to them.93 Improve monitoring of handling pesticides.92 Finish the implementation of the waste management procedure.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201267

Principles & Criteria - FSC6.8 Use of biological control agents shall be documented, minimized, monitoredand strictly controlled in accordance with national laws and internationallyaccepted scientific protocols. Use of genetically modified organisms shall beprohibited.6.9 The use of exotic species shall be carefully controlled and actively monitored toavoid adverse ecological impacts.6.10 Forest conversion to plantations or non-forest land uses shall not occur, exceptin circumstances where conversion:a) entails a very limited portion of the forest management unit; andb) does not occur on high conservation value forest areas; andc) will enable clear, substantial, additional, secure, long term conservation benefitsacross the forest management unit.6.11 Information regarding pesticide substances shall be given to all potentiallyaffected, ir order to alert the possible negative impacts in people, hydric resources,fauna, flora and native reserves.ELDORADO selfassessmentStatus (% complete)12/April/2012100 -100 -100 -100 -Necessary actions to fully accomplish the criteria of eachprincipleENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201268

Principles & Criteria - FSCPrinciple #7: Management planA management plan -- appropriate to the scale and intensity of the operations --shall be written, implemented, and kept up to date. The long term objectives ofmanagement, and the means of achieving them, shall be clearly stated.7.1 The management plan and supporting documents shall provide:a) Management objectives.b) Description of the forest resources to be managed, environmental limitations,land use and ownership status, socio-economic conditions, and a profile of adjacentlands.c) Description of silvicultural and/or other management system, based on theecology of the forest in question and information gathered through resourceinventories.d) Rationale for rate of annual harvest and species selection.e) Provisions for monitoring of forest growth and dynamics.f) Environmental safeguards based on environmental assessments.g) Plans for the identification and protection of rare, threatened and endangeredspecies.h) Maps describing the forest resource base including protected areas, plannedmanagement activities and land ownership.i) Description and justification of harvesting techniques and equipment to be used.7.2 The management plan shall be periodically revised to incorporate the results ofmonitoring or new scientific and technical information, as well as to respond tochanging environmental, social and economic circumstances.7.3 Forest workers shall receive adequate training and supervision to ensure properimplementation of the management plan.7.4 While respecting the confidentiality of information, forest managers shall makepublicly available a summary of the primary elements of the management plan,including those listed in Criterion 7.1.ELDORADO selfassessmentStatus (% complete)12/April/20126770100 -100 -67Necessary actions to fully accomplish the criteria of eachprincipleThe management plan is already prepared, but the companyneed to do updates and corrections regarding data from farmsuntil August/2012The overview of the management plan will be made only in July/ 2012.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201269

Principles & Criteria - FSCPrinciple #8: Monitoring and assessmentMonitoring shall be conducted -- appropriate to the scale and intensity of forestmanagement -- to assess the condition of the forest, yields of forest products,chain of custody, management activities and their social and environmentalimpacts.8.1 The frequency and intensity of monitoring should be determined by the scaleand intensity of forest management operations as well as the relative complexityand fragility of the affected environment. Monitoring procedures should beconsistent and replicable over time to allow comparison of results and assessmentof change.ELDORADO selfassessmentStatus (% complete)12/April/201279100 -Necessary actions to fully accomplish the criteria of eachprinciple8.2 Forest management should include the research and data collection needed tomonitor, at a minimum, the following indicators:a) Yield of all forest products harvested.b) Growth rates, regeneration and condition of the forest.c) Composition and observed changes in the flora and fauna.d) Environmental and social impacts of harvesting and other operations.e) Costs, productivity, and efficiency of forest management.51The company needs to develop a plan for monitoring the rate ofthe forest growth (IMA). For achieve this task, Eldorado hashired specialized employees, but it is expected to take some timein order to achieve compliance.8.3 Documentation shall be provided by the forest manager to enable monitoringand certifying organizations to trace each forest product from its origin, a processknown as the "chain of custody."8.4 The results of monitoring shall be incorporated into the implementation andrevision of the management plan.8.5 While respecting the confidentiality of information, forest managers shall makepublicly available a summary of the results of monitoring indicators, includingthosePrinciple #9: Maintenance of high conservation value forestsManagement activities in high conservation value forests shall maintain orenhance the attributes which define such forests. Decisions regarding highconservation value forests shall always be considered in the context of aprecautionary approach.9.1 Assessment to determine the presence of the attributes consistent with HighConservation Value Forests will be completed, appropriate to scale and intensity offorest management.79100 -6780100 -This step will be worked during the custody chain certification,which will begin after the conclusion of the forest managementcertification.The overview of the management plan will be made only in July/ 2012.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201270

Principles & Criteria - FSC9.2 The consultative portion of the certification process must place emphasis on theidentified conservation attributes, and options for the maintenance thereof.9.3 The management plan shall include and implement specific measures thatensure the maintenance and/or enhancement of the applicable conservationattributes consistent with the precautionary approach. These measures shall bespecifically included in the publicly available management plan summary.9.4 Annual monitoring shall be conducted to assess the effectiveness of themeasures employed to maintain or enhance the applicable conservation attributes.Principle #10: PlantationsPlantations shall be planned and managed in accordance with Principles andCriteria 1 - 9, and Principle 10 and its Criteria. While plantations can provide anarray of social and economic benefits, and can contribute to satisfying theworld's needs for forest products, they should complement the management of,reduce pressures on, and promote the restoration and conservation of naturalforests.10.1 The management objectives of the plantation, including natural forestconservation and restoration objectives, shall be explicitly stated in themanagement plan, and clearly demonstrated in the implementation of the plan.10.2 The design and layout of plantations should promote the protection,restoration and conservation of natural forests, and not increase pressures onnatural forests. Wildlife corridors, streamside zones and a mosaic of stands ofdifferent ages and rotation periods shall be used in the layout of the plantation,consistent with the scale of the operation. The scale and layout of plantation blocksshall be consistent with the patterns of forest stands found within the naturallandscape.10.3 Diversity in the composition of plantations is preferred, so as to enhanceeconomic, ecological and social stability. Such diversity may include the size andspatial distribution of management units within the landscape, number and geneticcomposition of species, age classes and structures.ELDORADO selfassessmentStatus (% complete)12/April/201267100 -6783100 -100 -100 -Necessary actions to fully accomplish the criteria of eachprincipleThe company needs to validate the study of high conservationvalue areas to meet this requirement.At the moment this criteria is not applicable. The company willbe able to perform this evaluation just after 1 year ofcertification.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201271

Principles & Criteria - FSC10.4 The selection of species for planting shall be based on their overall suitabilityfor the site and their appropriateness to the management objectives. In order toenhance the conservation of biological diversity, native species are preferred overexotic species in the establishment of plantations and the restoration of degradedecosystems. Exotic species, which shall be used only when their performance isgreater than that of native species, shall be carefully monitored to detect unusualmortality, disease, or insect outbreaks and adverse ecological impacts.10.5 A proportion of the overall forest management area, appropriate to the scale ofthe plantation and to be determined in regional standards, shall be managed so asto restore the site to a natural forest cover.10.6 Measures shall be taken to maintain or improve soil structure, fertility, andbiological activity. The techniques and rate of harvesting, road and trailconstruction and maintenance, and the choice of species shall not result in longterm soil degradation or adverse impacts on water quality, quantity or substantialdeviation from stream course drainage patterns.10.7 Measures shall be taken to prevent and minimize outbreaks of pests, diseases,fire and invasive plant introductions. Integrated pest management shall form naessential part of the management plan, with primary reliance on prevention andbiological control methods rather than chemical pesticides and fertilizers.Plantation management should make every effort to move away from chemicalpesticides and fertilizers, including their use in nurseries. The use of chemicals isalso covered in Criteria 6.6 and 6.7.10.8 Appropriate to the scale and diversity of the operation, monitoring ofplantations shall include regular assessment of potential on-site and off-siteecological and social impacts, (e.g. natural regeneration, effects on water resourcesand soil fertility, and impacts on local welfare and social well-being), in addition tothose elements addressed in principles 8, 6 and 4. No species should be planted ona large scale until local trials and/or experience have shown that they areecologically well-adapted to the site, are not invasive, and do not have significantnegative ecological impacts on other ecosystems. Special attention will be paid tosocial issues of land acquisition for plantations, especially the protection of localrights of ownership, use or access.ELDORADO selfassessmentStatus (% complete)12/April/2012100 -100 -100 -100 -90Necessary actions to fully accomplish the criteria of eachprincipleTo achieve these criteria, during the audit, the certificationcompany needs to verify if PTEAS is in compliance with FSCprinciples and criteria.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201272

Principles & Criteria - FSC10.9 Plantations established in areas converted from natural forests after November1994 normally shall not qualify for certification. Certification may be allowed incircumstances where sufficient evidence is submitted to the certification body thatthe manager/owner is not responsible directly or indirectly of such conversion.ELDORADO selfassessmentStatus (% complete)12/April/2012100 -Necessary actions to fully accomplish the criteria of eachprincipleNote: Eldorado will be assessed by the valid FSC Standard, available on FSC website. However, Eldorado has chosen to use the General Standard which includes the FSC Principle, criteria and indicators. The new revised FSCstandard excludes indicators because they were incorporated into criteria level. Eldorado chose to use the Standard indicators, knowing that all the necessary requirements to be accomplished would be covered. Removedcriteria in the new version: 1.7, 2.4, 3.5, 3.6, 3.7, 4.6, 4.7, 4.8, 4.9, 4.11, 4.12 and 4.13.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201273

Social programs implemented by ELDORADOAs part of the BNDES – Banco Nacional de Desenvolvimento Econômico e Social(National Bank of Social and Economic Development) financing,ELDORADO shall apply R$ 25,000,000.00 (twenty five million) in socialprojects and programs in the area of influence of the project.Based on the social studies undertaken (EIA, socio economic diagnosis,public hearing, ELDORADO’s experience), ELDORADO proposed toinvest such amount in programs/projects related to the improvement ofthe public infrastructure, and focusing in health and education, social andenvironmental, at Tres Lagoas, Selvira, Inocência and Água Claramunicipalities, all located at Mato Grosso do Sul State.As a result of the social studies, health service is the main vulnerability ofthe region that lacks of physical infrastructure, hospitals, equipment andmedical experts. Although there are educational services available, theregion lacks of technical courses and a better distribution of the servicesthat are concentrated in the urban area.At Social aspect, the treatment of children requires special attentionbecause of the increase demand for educational and refuge services. Theurban infrastructure also lacks of areas of environmental preservation andleisure.ELDORADO identified the followings projects to be supported between2012 and 2014:Três Lagoas Health Programs: Medical equipment to the Emergency Unit (UPA); Construction of 2 Health Basic Units (UBS); Construction of housing to receive elders; and Improvement of the infrastructure of the Hospital Nossa SenhoraAparecida. Educational: Construction of the basic school.ENVIRONMENTAL RESOURCES MANAGEMENT74ELDORADO - APRIL, 2012

Social: Construction of the kindergarten; and Acquisition of 1 vehicle (minibus) to transport children. Environmental: Management Plan and drainage plan to the area of lagoons;Selvíria Health: Medical equipment to the Hospital Selvíria and the Unity of FamilyHealth at Véstia District). Education: Construction of rural school at São Joaquim Rural Settlement; Construction of house to abandoned children and teenager; Construction of kindergarten; and Implantation of the sport square.Água Clara Medical and dental equipment to health system.Inocência Medical equipment to Inocência Hospital.4 PROJECT CATEGORIZATION AND APPLICABLE IFC PERFORMANCESTANDARDS4.1 BACKGROUND TO CATEGORIZATIONAs the Project is not located in a high-income OECD country, in order for theProject to be aligned with the Equator Principles it must meet therequirements of the relevant IFC Performance Standards (PSs). The recentlyrevised IFC PSs are applicable from 1st January 2012 and these have beenapplied to this assignment. The Equator Principles require Project FinancingENVIRONMENTAL RESOURCES MANAGEMENT75ELDORADO - APRIL, 2012

Due Diligence to categorize Projects on the basis of the potential magnitudeand impacts associated with the environmental and social aspects of theProject. The categorization is not influenced by the robustness of mitigationmeasures which may be implemented to reduce the environmental and socialrisks of the Project.As described above the Project is defined as the existing assets which areowned, operated and/or managed by ELDORADO and located within TrêsLagoas, State of Mato Grosso do Sul (and associated Area of Influence) i.e.forestry operations and logistics system.The 2012 IFC PSs and associated IFC guidance and correspondence require theinherent risks related to the project sector and the sensitivity of the localcontext to be specifically considered in the categorization decision, in additionto specific project impacts 1 .4.2 BASIS FOR CATEGORIZATIONAs part of this assessment ERM has assigned the Project a categorization ofCategory A (‘business activities with potential significant adverseenvironmental or social risks and/or impacts that are diverse, irreversible, orunprecedented’ 2 ).Project specific impacts are additionally described within Annex C, D and E ofthis report.4.3 APPLICABLE IFC PERFORMANCE STANDARDSThis report reflects ERM’s assessment of the overall alignment of the currentProject status with the Equator Principles and associated applicable ReferenceStandards. The due diligence process has additionally providedrecommendations which should be implemented in order to mitigate, reduceor manage the environmental and social gaps and risks to a level where theyare more acceptable to potential lenders.Based upon the assessment conducted to date ERM understands that thefollowing PSs are applicable in terms of managing the current and anticipatedimpacts of the Project: PS1. Assessment and Management of Environmental and Social Risks andImpacts;1 Update of IFC’s Policy and Performance Standards on Environmental and Social Sustainability, and Access to Information Policy,International Finance Corporation, April 14, 2011, Paragraph 11, Page v and Pages 9-10. Also available athttp://www1.ifc.org/wps/wcm/connect/fca42a0049800aaaaba2fb336b93d75f/Board-Paper-IFC_SustainabilityFramework-2012.pdf?MOD=AJPERES2 International Finance Corporation’s Policy on Environmental and Social Sustainability, January 1, 2012, Page 8. Also available athttp://www1.ifc.org/wps/wcm/connect/7540778049a792dcb87efaa8c6a8312a/SP_English_2012.pdf?MOD=AJPERESENVIRONMENTAL RESOURCES MANAGEMENT76ELDORADO - APRIL, 2012

PS2. Labor and Working Conditions; PS3. Resource Efficiency and Pollution Prevention; PS4. Community Health, Safety and Security; PS5. Land Acquisition and Involuntary Resettlement; PS6. Biodiversity Conservation and Sustainable Management of LivingNatural Resources; PS7. Indigenous Peoples; and PS8. Cultural Heritage.The following EHS Guidelines were considered applicable: Environmental, Health, and Safety General Guidelines; Environmental, Health, and Safety Guidelines Pulp and Paper Mills; Environmental, Health, and Safety Guidelines for Forest HarvestingOperations; and Environmental, Health, and Safety Guidelines Ports, Harbors andTerminals.All reporting is by exception; where topics are not referred to, no gaps havebeen identified with reference to the IFC PSs or other relevant requirementsidentified above. Please see Annex C, D and E for a detailed conformanceassessment for the requirements of each Performance Standard.4.4 ALIGNMENT WITH EQUATOR PRINCIPLESThe Equator Principles (EPs) represent a financial industry benchmark fordetermining, assessing and managing social and environmental risks inproject financing. They are a set of ten principles which have been adopted byover seventy financial institutions (Equator Principles Financial Institutions -EPFIs) in order to ensure the projects they finance are developed in a mannerthat is socially responsible and reflect sound environmental managementpractices.In overall terms ERM understands that the Project exhibits a status of PartialAlignment with the Equator Principles. It is clear that ELDORADO hasawareness of the standards required and, providing sufficient time andresources are planned, supplied and successfully implemented, may reducemany of these risks and/or close the majority of these gaps.ENVIRONMENTAL RESOURCES MANAGEMENT77ELDORADO - APRIL, 2012

For the purposes of the Equator Principles assessment the followingdefinitions are proposed in Table 4.1 below:Table 4.1EP Compliance DefinitionsRatingDefinitionAligned Information available indicates the Project fulfills therequirement and/or is aligned with intended outcomeof the requirement.Partially Aligned Information available indicates the Project partiallyfulfills the requirement and/or is partially aligned withintended outcome of the requirement.Not Aligned Information available indicates the Project does notfulfil the requirement.Insufficient Information There is insufficient information to make anassessment of the level of alignment.Not Applicable The requirements do not apply to the Project at thecurrent time.Details of alignment with each Equator Principle are provided inTable 4.2 below:Table 4.2Overview of Equator Principles Alignment AssessmentEquator Principle (2006) Comment Project Alignmentwith EP1 Review and CategorizationThe project has beencategorized under Category A,B or C.2 Social and EnvironmentalAssessmentIf Category A or B, anassessment has been preparedby borrower, consultant orexternal expert, and includesmitigation and managementmeasures.The Project is Categorized asCategory A.Justification for thisCategorization is included withinSection 6.1 of this report.The Project includes theconstruction of an industrial site,plantations areas and a logisticsproject (which includes ports,terminal, road, rail and hydroways). Logistics project is ininitial phase of development.Environmental ImpactAssessments (EIAs) have beenconducted for the industrial site.No Project wide, cumulative orProject specific Social andEnvironmental Assessment forforest operations and logistics hasbeen produced.Aligned: No furtheraction required.Partially Aligned:See Annex C, D and Efor details of theProject alignment withSpecific PS’s.ENVIRONMENTAL RESOURCES MANAGEMENT78ELDORADO - APRIL, 2012

Equator Principle (2006) Comment Project Alignmentwith EP3 Applicable Social andEnvironmental StandardsNon-OECD countries andOECD not High-Income: Theproject complies with, orestablishes a justified deviationfrom, applicable PerformanceStandards and EHS Guidelines.High-Income OECD:Compliance of local or nationallaw in High-Income OECDcountries.4 Action Plan and ManagementSystemThe borrower has prepared anAction Plan (AP) to addressfindings, prioritize mitigationmeasures, and take correctiveactions and monitoringmeasures.The borrower has established aSocial and EnvironmentalManagement System.5 Consultation and DisclosureThe borrower, government orthird party expert hasconsulted with project-affectedcommunities in a culturallyappropriate way.The consultation process hasensured free, prior andinformed consultation andparticipation to includecommunity concerns.6 Grievance MechanismTo ensure that consultation,disclosure and communityengagement occurs throughoutconstruction and operation ofthe project, the borrower hasestablished a grievancemechanism, scaled to the risksand adverse impacts of theproject, as part of themanagement system.The grievance mechanismaddresses concerns promptlyand transparently, in aculturally appropriate mannerand is accessible to thecommunity.IFC Performance Standards havebeen used to assessenvironmental and socialcompliance of the Project. Inaddition related IFC EHS and IFCSector Guidance have beenreferred to. No other assessmentsundertaken for the Project (suchas EIAs undertaken forpermitting purposes) haveincluded reference to thePerformance Standards or EHSGuidelines.As part of the due diligenceexercise PS’s 1, 2, 3, 4, 5, 6, 7 and 8have been determined to beapplicable to the Project.No Project specific Action Plan(AP) or integrated social andenvironmental managementsystem has been developed.Preparation of a comprehensiveintegrated Environmental, Socialand Health and SafetyManagement System (ESHMS)and an action plan is arecommendation this report.A Project specific StakeholderEngagement Plan is arecommendation of this report.A Grievance Mechanism existsfor the industrial and forestProjects. No grievancemechanism for logistic operationshas been implemented yet.A pro-active and appropriatelydocumented GrievanceMechanism is a recommendationof this report.Partially Aligned:See Annex C, D and Efor details of theProject alignment withSpecific PS’s.Not Aligned:A Project specificintegratedEnvironmental andSocial ManagementSystem (ESMS) andEnvironmental andSocial Action Plan(ESAP) isrecommended to beimplemented.Partially Aligned:A Project specificStakeholderEngagement Plan(SEP) is recommended.Partially Aligned:The expansion of theexisted GrievanceMechanism to otherstakeholders groups isa recommendation ofthis report.ENVIRONMENTAL RESOURCES MANAGEMENT79ELDORADO - APRIL, 2012

Equator Principle (2006) Comment Project Alignmentwith EP7 Independent ReviewThe Assessment, AP andconsultation processdocumentation have beenreviewed by an independentexpert to assist the EPFI’s duediligence and to assesscompliance with EquatorPrinciples.8 CovenantsThe borrower has covenant(s)linked to the following:a) Comply with social andenvironmental host countrylaws, regulations and permits;b) Comply with the AP duringconstruction and operation;c) Provide periodic reports (atleast annually);d) Decommission facilitiesaccording to plan.9 Independent Monitoring andReportingThe project has appointed anindependent or externalenvironmental and/or socialexpert to ensure ongoingmonitoring and reporting.10 EPFI ReportingThe EPFI reports publicly atleast annually the EP processesand experience, consideringconfidentiality.This report has been prepared tosatisfy this requirement. Thereare still assessments to beperformed and the action planneeds to be detailed.Required covenants will bedeveloped by Lenders as part ofthe Loan Agreement.Independent monitors may beappointed in accordance withcovenants and the LoanAgreement. Annual reportingwill be required.Reporting will be undertaken byLenders in accordance with EPrequirements.Partially Aligned:Further assessmentsand a detailed actionplan arerecommendations ofthis reportNot applicable at thistime:Lenders to developProject specificcovenants.Not applicable at thistime:The Client may engagean appropriateindependent expert(s)to carry out periodicmonitoring of theperformance of theProject andimplementation of theAction Planrecommended by thisESDD.Not applicable at thistime:Lenders to report inaccordance with EPrequirements.5 BENCHMARK OF THE PROJECT - ALIGNMENT WITH BRAZILIANLEGAL REQUIREMENTS AND IFC PERFORMANCE STANDARDSThe IFC standards refer to the concept of Good International Industry Practice(GIIP), and it is on this basis that the gap analysis has been evaluated. Tofacilitate a focused summary of the gaps and proposed mitigation measuresrelating to the Project ERM has adopted the qualitative ranking schemeprovided below. Where one or more aspects at risk correspond to thedefinitions below a Risk Level of H (High), M (Moderate), or L (Low) isprovided.ENVIRONMENTAL RESOURCES MANAGEMENT80ELDORADO - APRIL, 2012

Table 5.1Project Risk Level DefinitionsRiskLevelHighModerateLowRisk Group(s)Immediate actionShort term actionLonger termrecommendationsfor improvementDefinitionImmediate action required to address the keyenvironmental and social risks, which can include legalcompliance findings.Actions related to IFC Standards or legal compliancefindings/ gaps, which represent moderate risk to theproject.Actions that need to be addressed as part of themanagement system.Table 5.2 provides a summary of the results of the Gap Analysis of the Project(including industrial, forest and logistics) against Brazilian legal requirementsand the IFC Performance Standards, including the assessment of risks posedby gaps identified and recommended actions to take steps to mitigate and/oraddress these gaps where possible. Further details of the IFC PS’s and ERM’sassessment of the Project alignment are provided in Annexes C, D and E for thepulp and paper industrial project, forest operations, and logistics project,respectively. All reporting is by exception; where topics are not referred to nogaps have been identified with reference to the IFC PSs or other relevantrequirements.ENVIRONMENTAL RESOURCES MANAGEMENT81ELDORADO - APRIL, 2012

Table 5.2Summary Gap Analysis and Risk AssessmentGapRefNo.PSParaRef.No’s.Risk Group Description Recommended ActionsPS 1 - Assessment and Management of Environmental and Social Risks and ImpactsEnvironmental and Social Assessment and Management System1.1 5 Moderate Industrial OperationAccording to EIA, the project did evaluate environmentaland social impacts of the project, and mitigation measureswere defined for all impacts identified. The EnvironmentalBasic Plan -PBA and PBA reports presented detailed theseprograms and demonstrate the implementation of theconstruction programs until the end of 2011. Programsassociated with the operation will start, reportedly, onNovember 2012. According to information given on sitevisit the management of the programs is held by two thirdpartycompanies currently in charge of the site operation,Meta and DuPont. Reportedly, ELDORADO will take overthe management of the PBA’s implementation and the sitemanagement when the operational license is issued.Guidance for third party companies is provided by adocument called Health and Safety and Environment ofcontracted and subcontracted companies Book.ELDORADO does not conduct due diligence to monitorthird party companies in charge of the site management.LogisticsFor the logistics project, at this phase of the project, noenvironmental or social management system has beendeveloped.For the industrial operations:ELDORADO should implement a system to monitor thirdparty companies in charge of the site management.ELDORADO should integrate the existing practices in amanagement system, that shall include: Training programfor employees and contractors with direct responsibilityfor activities relevant to social and environmentalperformance of the projectFor the Logistics:ELDORADO shall develop an Environmental and SocialManagement System (ESMS), that includes:(i) Training program for employees andcontractors with direct responsibility foractivities relevant to social andenvironmental performance of the project;(ii) Actions to monitor the social andenvironmental performance of thecontractors;(iii) Engagement and community participation(as described in the item below StakeholderEngagement;(iv) Dissemination of information on the ActionPlan through internal reports formanagement of the organization andexternal stakeholders, including affectedcommunities.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201282

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions1.2 7 to 10 Moderate Identification of Risks and Impacts:For the industrial operations, as part of the permittingprocess, ELDORADO developed an Environmental ImpactAssessment (EIA) study, which considers the impactsrelated to the planning, implementation and operation ofthe project. However, the EIA did not identify thecumulative impacts from other existing, planned orreasonably defined developments and also did not identifypotential vulnerable groups that may be differentially ordisproportionately affected by the project because of theirdisadvantaged or vulnerable status nor impacts onbiodiversity and ecosystems services.The Forest Management Plan defined the area affected bythe project. It does not include the lands at São Paulo andMinas Gerais state (that will supply wood for the first yearsof operation) and Dois Irmãos dos Buruti and Anastaciomunicipalities, where ELDORADO owns 4 lands and lease2 lands.Integrate and complete, if necessary, the existing studies(EIA, RAS, social diagnosis, Inventory of HighConservation Areas, and others), in order to: Asses cumulative impacts of the project; and Identify specific vulnerable groups; Identify direct and indirect project-relatedimpacts on biodiversity and ecosystem services; Identify risks and impacts in all parts of thelogistics project (railroad, waterwaytransportations, warehouses modifications, etc.)Complement management programs with the mitigatingaction proposed by risks and impacts assessmentrecommended above.Identify areas likely to be affected by the operation at SãoPaulo and Minas Gerais state and Dois Irmãos dos Burutiand Anastacio municipalities.For the logistics project, as part of the permitting process,ELDORADO has developed a Simplified EnvironmentalReport – RAS for the multimodal terminal at Aparecida doTaboado/MS. No environmental and social assessmentwas performed for the other parts of the logistics project,such as, railroad, waterway transportation, warehousemodifications, among others.1.3 17 Moderate Organizational capacity and competency:For industrial, forest and logistics projects, ELDORADOhas already assigned specific personnel for managingEnvironmental and Social (E&S) programs, however, notraining program to support the designated personnel tocarry out their part of the ESMS.Develop training program to support the designatedpersonnel to carry out their part of the ESMS. The trainingprogram shall ensure consistence with ELDORADOpolicies and procedures. The training can be formal,informal (on-the-job), one-time, periodic, etc. The programmust include third parties with direct responsibility withactivities relevant to the environmental and socialperformance of the project, for example, wood suppliers,rural workers supplier, etc.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201283

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions1.4 20 to 21 Moderate Emergency preparedness and response:During the assessment, ERM verified that the constructionphase of the industrial plant has an emergencypreparedness and response (EPR) plan in place. This planwill be completed and adapted for the operation stage.It was also verified that forest operations have an EPR.No EPR has been developed for the logistics project.Emergency Plan should be communicated to affectedcommunity and relevant governmental authorities withresponsibility on emergency situations, e.g, local police,hospitals, fire department, etc.An emergency plan should be prepared for the logisticsprojects and communicated to affected community andrelevant governmental authorities with responsibility onemergency situations, e.g, local police, hospitals, firedepartment, etc. in all multimodal terminal ports(Aparecida do Taboado, Pederneiras and Santos).1.5 25 to 31 Moderate Industrial, Forest and Logistics Project:Stakeholder engagement:For stakeholder identification, ELDORADO mapped andidentified local stakeholders. Neighbors of the lands whereELDORADO operates (owned lands, leased lands andpartnerships agreements) are identified through PTEAS.ELDORADO has the following consultation initiatives: For the purpose of social economic diagnosis, a sampleof citizens and local governmental authorities wereinterviewed to identify vulnerability of the region; For the Inventory of Areas of High Biodiversity,stakeholders were consulted to identify the areas ofhigh biodiversity important to the community and theuse of it; As a result of the local vulnerabilities identified at thesocial economic diagnosis, local governmentalrepresentatives were consulted by ELDORADO toidentify projects that could be supported byELDORADO; During PTEAS process, neighbors of the lands wereELDORADO’s operate receive information aboutELDORADO and orientation on how to contact thecompany; Forums and public hearings were held for the purposeFor fully comply with the performance standard,ELDORADO should systematize the stakeholdersidentification and contact information, to enableevaluation of stakeholder and classification according thefollowing: Stakeholders affected by ELDORADO, positively andnegatively, directly and indirectly, particularly thosedirectly and adversely affected by project activities,including those that are disadvantaged or vulnerable; Stakeholders who may be able to influence theoutcome of the project because of their knowledgeabout the affected communities or political influenceover them; Legitimate stakeholders representatives, includingelected officials, non-elected community leaders,leader of informal or traditional communityinstitutions, and elders within the affected community; Stakeholders not directly affected by the project butmay have the ability to influence or alter therelationship of the client with the affected community.Develop a Stakeholder Engagement Plan, including: engagement principles, objective and criteria,ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201284

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsof the industry license process and disclosureinformation about the EIA and PBA and identifiedcommunity concerns about the project; A public hearing for the forestry project will be hold forcertification purpose and the Forest Management Planwill be disclosured.A community relationship plan is being developed.ELDORADO does not have a systematic approach toconsult and/or to engage stakeholders.Besides, none of the above mentioned initiatives wereundertaken to Dois Irmãos do Buruti and Anastaciomunicipalities, where ELDORADO owns 6 lands andleases 2 other lands. According to a social diagnosisundertaken at these areas, there are around 7 indigenouslands in the region. According to ELDORADO, none ofthem located inside the lands operated by ELDORADO.Thus, indigenous people, is not currently being engaged orconsulted. These municipalities are located at 350 km awayfrom Tres Lagoas municipality, where ELDORADO’s pulpplant is located. risks and impacts, identification, characterization and priority ofstakeholders, focusing on those directly affected by theproject and vulnerable groups, how interaction should be formalized, consultation frequency, grievance mechanism, list of time-bound activities, resources andresponsibilities, communication channels, including those to disclosureinformation about risk and impact. the engagement process shall also support the updateof risks and impacts of the operation to affectedcommunity.Information about risks and impacts identified, mitigationmeasures shall be periodically disclosure to affectedcommunity, at least annually, as long the specific items inthe management programs. ELDORADO may considerusing sustainability report on the financial, environmentaland social aspects to report so.1.6 22 to 24 Low Industrial, Forest and Logistics Project:Monitoring and review:Documents provided do not contain the procedures tomonitor and measure on a regular basis the keycharacteristics and performance of the social managementprogram, including the use of external experts if required.Develop a systematic to evaluate efficiency of themitigation measures.External Communication and Grievance Mechanism1.7 34 and35LowIndustrial, Forest and Logistics Project:ELDORADO has the followings communication channel: Internal newspaper to workers Disclosure of information at local radios and journal.There are four mechanisms in place for grievance and toregister communication received from stakeholders: There is an ombudsman for industrial workersThe grievance mechanism must be part of the StakeholderEngagement Plan.It is recommended to expand the disclosure on howcommunity and external stakeholders can complain toELDORADO.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201285

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsgrievance (employees and contractor’s worker).Information about the ombudsman is disclosure disclosedin at the Manual for Induction and banners at the site.”Human Resources in the Field”. A representative fromHuman Resources visits workers in the field twice a monthto register their demands. ERM reviewed a spreadsheetcontaining the name of the worker, complaint, feedbackprovided, and time of response. Complains fromcontractor’s workers are registered and directed to theContract company. None of the complaints registered onthe spreadsheet were related to contractor’s workers. There is a form to register external communicationfrom the public. Community and neighbor mightcontact ELDORADO’s office in each municipality,a telephone number, the supervisor of the farm orthose responsible to perform rounds on the farms.The form registers the name of the person,stakeholders category, reason for contact, name ofthe person who receive the contact and actiontaken. Once complete, the form is delivered to oneperson in charge to receive it. The complaint isregistered in a spreadsheet that contains the nameof the person, data, who received the complaint, adescription of the complaint, action taken,feedback and data. ERM reviewed the spreadsheetand it contained 13 complains. The ELDORADO site’s has a channel to receivecommunication through e-mail or telephone number.Forums and public hearings were held for the purposeof the industry license process and disclosureinformation about the EIA and PBA and identifiedcommunity concerns about the project.A public hearingfor the forestry project will be hold for certificationpurpose and the Forest Management Plan will bedisclosure.No grievance mechanism for logistic operations has beendeveloped yet.For more information on Grievance Mechanism refer to Section 2.0of this report.Conduct the public hearing for the forest operations andto disclosure information about the Forest managementPlan.It is recommended to expand the grievance mechanismcurrently in place for industrial and forest operations tothe logistics project. The company may also develop aspecific mechanism instead, guaranteeing that it containsthe following: the grievance mechanism must be available to allstakeholders: workers (employee, contractors),suppliers, affected community, and other significantcategories identified by ELDORADO; it shall be culturally appropriate, readily accessible toall workers; it must be defined roles and responsibilities forreceiving the grievance and communication flow; it must also define the channel for provision offeedback and time to do so;The mechanism should be able to receive and treat allgrievances, including those related to security personnelabuses and others.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201286

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended ActionsOngoing Reporting to Affected Communities1.8 36 Moderate Industrial, Forest and Logistics Project:For the ELDORADO industrial project a public hearingwas held for license purpose. The hearing disclosureinformation about the project, impacts identified throughEIA and mitigation plans.The EIA and PBAs are available for general public. PBA’sare disclosure twice a year with ongoing information aboutthe management programs.It is not clear if stakeholders are communicated about howto access this information.Reportedly a public hearing for the forest operations willbe held for certification purpose and the ForestManagement Plan will be public disclosure.Include on communication channels information abouthow to access PBA of the industrial site and other relevantpublic available information.Conduct the public hearing for the forest operations andto disclosure information about the Forest managementPlan.Include on the stakeholder engagement plan thedisclosure of information related to the logistic project.For the logistics project, no ongoing reporting tostakeholders is planned.PS 2 - Labor and Working ConditionsWorking Conditions and Management of Worker Relationship2.1 7 Moderate Industrial, Forest and Logistics Operation:There is no human resource police that set out its approachto managing workers as required by this PerformanceStandard.There is current a Policy for Remuneration that states thesalaries and benefits by professional category. This Policy isnot available to the employees and general public.There is also Policy for Training developed to be appliedfor industrial and rural workers, however, the policy hasnot being validated by the managers in charge of the forestactivity.ELDORADO reported to be developing an ethical code.2.2 8 Low Forest Operations:During the Induction process, staffs are reportedlyprovided with information associated with legal rights andother information about working conditions, but it lacks ofDevelop a Human Resource Policy, procedures or ethicalcode, to be applied for workers, contracted workers andsupply chain workers, that cover all issues treated by thisperformance standard, as exemplified bellow: workingconditions, terms of employment; collective bargain andfreedom of association; nondiscrimination and equalopportunity; grievance mechanism; child and forcedLabor; right to privacy about surveillance methods.Communicate the policy, procedure or ethical code to allthe workers. It is recommended to public disclosure it.Include on rural workers induction information aboutfreedom of association and the union representation.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201287

GapRefNo.PSParaRef.No’s.2.3 10 High(legal noncompliance)Risk Group Description Recommended Actionsinformation about freedom of association and unionrepresentation. Some workers reported not being informedabout union representation and how to join it.Forest Operations:ELDORADO has currently 1556 workers, 88% of them arerural workers, around 1370. 37% of those are migrantworkers.ELDORADO reported that workers are recruited by a thirdpart contracted by ELDORADO named Multipla.ELDORADO’s contract with Multipla was revised and itcontains a clause (page 4) that states that ELDORADO willpay 30% of the worker salary to Multipla, which will not becharged from the worker. The contract does not detail theprocedure to contract migrant workers. ELDORADO’sprocedure to Employees Selection and Contraction(Procedure PCH RH 001 (00) states companies hired torecruit workers are forbidden to subcontract others to therecruitment process.ERM interviewed 9 migrant workers. One of them reportedthat he was not recruited by Multipla but by a local man,who charged him a fee of R$150.00 for the recruitmentprocess. The charge of a fee from migrant workers doesnot complying with the ILO Convention 110, and theFederal Decree 58.826/66, that promulgates it, and Law9777/98 and the Union Convention issued by theFederation of Rural Workers of Mato Grosso do Sul State,clause 15.Develop a procedure to the recruitment of migrantworkers, including: Criteria for third part recruitment; Travel conditions to workers and to return to theirhome; Information that must be provided to workers beforetraveling.Monitor recruitment to guarantee compliance with theBrazilian legislation.Guarantee that the Declaration of the transport of Workers(CDTT) is issued to all migrant workers travelling to TresLagoas or back to their origin.ELDORADO informed that it did not issue the Declarationof the transport of Workers (CDTT), which does notcomply with the Federal Standard SIT 76/09. This lawstates that the transport of workers recruited to work in anarea other than their origin shall be communicated toLabour regional authority (Superintendências Regionais doTrabalho- SRTE), SRTE through the Declaration of thetransport of Workers (CDTT)..ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201288

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions2.4 11 High Industrial operations:ELDORADO is directly in charge of 3 accommodations formigrant workers hired by contractors.Develop a mechanism to disqualify contractors that arenot monitoring their accommodations or timely solvingthe findings identified by Meta.Contractors are in charge of 135 houses and hotel wereworkers are accommodated. Those houses are monitoredby a third part company hired by ELDORADO. Althoughthe management and monitoring of the contractor’saccommodation is well structured, no compliance withBrazilian Legislation are currently identified and not timelysolved by contractors.2.5 13 Moderate There have been 3 work stoppages of activities in the siteby workers hired by contractors: On January (1 day ofstop), April (2 days of stop) and August 2011 (8 days ofstop). The work stoppages are considered unofficialbecause it lacked the organization aspects defined byBrazilian regulation (it’s is different of strike, which isorganized and follows the legal terms).On August, the demand was associated with salaries andcommuting to work. Companies have increased salaries2,5% and 8% and provided feed benefits. The negotiationwas between the union and contractors, monitored by theLabour Regional Tribunal and supported by ELDORADO.ELDORADO reported that, 300 workers were dismissedafter the work stoppage in August 2011.Monitor dismissal of contractor’s workers who wereengaged on work stoppages /strikes to avoiddiscrimination and guarantee freedom of discriminationand collective bargain.2.6 14 Low Industrial and Forest Operations:Currently, ELDORADO has not taken measures to preventand address discrimination in employment relationship,including harassment, intimidation and/or exploitation.However, ERM did not identify that any nondiscriminationpractices are in place to govern employmentrelationships.Define measures and orient contractors on prevention ofdiscrimination in employment relationship.Take measures to prevent any harassment, includingsexual harassment or psychological mistreatment withinthe workplace, including a module about harassment forleaders, managers, for example.Monitor and treat cases of harassment identified throughombudsman.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201289

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions2.7 15 Moderate Industrial and Forest Operations:ELDORADO has recently hired a doctor to identify amongworkers those that have disability and if the company is incompliance with the Law 7.853 that states a quota of 5% ofworkers with disability for companies with more than1,0000 workers.Identify total number of employees with disability and, ifnot sufficient to comply with law 3298/99, definemeasures to do so at operation phase.Define a measure to comply with Apprentice Law.ELDORADO has not developed a plan or measure toachieve the quota defined by law at operation phase.ELDORADO informed that there is no apprentice at thesite, which is a not compliance with the Apprentice Law5.598/05 apprentices, state a quota for apprentices.However, the company sponsors the Program “My FirstJob” that aims to provide technical training to almost 200students of the local high schools. Fifty percent (50%) ofthose participants shall be contracted by ELDORADO,which should be enough to meet the Law 5598 quota.Although NON COMPLIANT with Federal Decree5.598/05, the measure undertaken seems to be sufficient toguarantee compliance with this requirement.Brazilian companies face difficulty in complying with bothlaws.Occupational Health and Safety2.8 23 Moderate Industry OperationA deficiency was observed regarding the Regulatory NormNR-6, associated with PPE delivery records. The deliveryrecords do not fully match the list of PPEs that must beprovided to each employee, according to theirOccupational Risk Prevention Plan (PPRA).Additionally, some PPE deliveries were not properlyregistered.Workers Engaged by Third Parties2.9 24, 25 LowForest Operations:and 26There are 534 contractors workers hired by Plantar, J&Sand Ruah to perform rural activities. ELDORADOdeveloped a procedure (Contracts Verification Items - IVC)ELDORADO must guarantee the delivery of all PPEs tothe employees. The deliveries must be properly registeredand all PPEs must be adequate to the risks identified andlisted in the PPRA.Guarantee that contractor’s workers are provided withinduction, including information about freedom ofassociation and collective bargain.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201290

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsto verify contractors in relation to labor practice (over time,salary payment, registration of employees, etc.), health andsafety (PPE, water and food supply, safety signs, etc.), andenvironmental (pesticides and environmental standards).The rural workers contractors are verified on a monthlybasis and a report is issues for each verification. In case thecontractor is not complying with the items, a part of thecontractor payment is retained until achieving compliance.Reportedly, ELDORADO’s practice is to verify contractor’sworkers documentation and health and safety conditions inplace and to revise documentation quarterly. The person incharge of the contractor monitors contractor’s operationalperformance and legal fiscal requirements. Clearancecertificate for fiscal workers payment are providedmonthly.There is no policy or procedure to monitor the contractorperformance associated with the other aspects of thisperformance standard, e.g no discrimination, equal ofopportunity, treatment of workers, etc.ELDORADO does not monitor or orient contractors (J&S,Plantar and Ruah) on implementing a grievancemechanism.Define measures and orient contractors on prevention ofdiscrimination in employment relationship, andharassment.Guarantee that contractor’s workers are provided with agrievance mechanism. Take measures to guarantee thatterminal expansion and railway branch are complyingwith labor rights and other issues addressed by theseperformance standards (freedom of association andcollective bargain, non-discrimination in employmentrelationship, harassment, child and forced labor). Thiscould be done through regular visits to the site, auditprocess, etc.Take measures to orient logistics contractors oncompliance with labor rightsLogistics ProjectMost of the logistics operations shall be conducted by thirdparty contractors. Reportedly, all contracts signed betweenELDORADO and contractors have a clause stating that nopart shall employ slavery like and/or child labor.Supply Chain2.10 27 Moderate Forest Operations and Logistics Project:Wood Supply: For contract purpose, ELDORADO requeststhe suppliers several documents and clearance certificationto identify legal risks associated with the farm and thewood transaction. Those documents and certificates could,in thesis, demonstrate any judicial action against the farmdue to child labor or forced labor.ERM reviewed one contract, which has a clause stating thatEstablish a systematic to monitor child and forced labourin primary supply chain. This systematic may include:Identify categories of significant suppliers in theprimary supply chain in high risk of child laborand forced labor.Define measures to monitor significant supplierson employment of child labor and forced labor.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201291

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsboth parts are responsible to avoid employment of child orforced labor.The contract is signed 2 to 4 years before the harvestingoperations begin and ELDORADO does not monitorsuppliers during this period. Not monitoring woodsuppliers not FSC certified poses a risk to the company.Land Supply: ELDORADO’s contract with land supply hasa clause that states that both parts are responsible to avoidthe employment of child or forced labor. The farms VôFiorindo and Buba were leased by the company MMX andthen transferred to ELDORADO. The contract signed byMMX and the farmers does not contain specific clauseabout child and forced labor. No other measure has beentaken to identify and avoid the employment of child andforced labor by these land suppliers.PS 3 - Resource Efficiency and Pollution PreventionGeneral3.1 4 and 5 Moderate Forest OperationThe analysis of environmental impacts related to the forestmanagement was performed at two levels:a) Analysis of the EMS Guidelines and Procedures(preliminary impact assessment (Poyry Silviconsult), EMS,PTEAS, guidelines to prevent use of native forests). Theissues of the EMS guidelines and procedures are related to: The elaboration and application of the PTEAS is stillrestricted to few farms. It was not observed a systematic and comprehensivemonitoring documentation system.b) Efficiency of the EMS procedures: Waste management: ERM observed issues related to theimplementation of the waste management program –see PS 3 Paragraph 12. Hazardous material management: ERM observed issuesrelated to the implementation of the waste managementprogram – see PS 3 Paragraph 13.For wood suppliers, monitoring measure to beconducted in between the contract signature andthe harvesting of the wood, especially for thosethat are not FSC certified.For Vô Fiorino Farm and Buba, include thecontractual clause that both parts will not employchild or forced labour.For the logistic project, inclusion on suppliers’contract a clause stating that both parts areresponsible to avoid the employment of childand forced labor.ELDORADO should apply the PTEAS procedure to alllands prior to the intervention (planting and harvesting).For the lands where intervention (plantation) has alreadyoccurred and no PTEAS undertaken, ELDORADO shouldconduct the PTEAS considering impacts already causedby the activity described by this performance standard(PS3).ELDORADO should also improve the EMS efficiencyregarding the following programs:1 – Waste Management Program2 – Hazardous Material Program3 – Monitoring and Documentation ProgramENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201292

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions Water management: ERM did not observed issuesrelated to the water management program – see PS 3Paragraph 9.3.2 7 and 8 Low Industrial Operations:The ELDORADO Pulp mill of Três Lagoas/MS does nothave an estimate of carbon dioxide emission equivalentsfor the Project. Production has not yet started. Somemeasures adopted in the project are aligned with thereduction of greenhouse gas emissions, such as the use ofrenewable energy sources associated with biomassburning, co-generation of heat and power and chemicalsrecovery, among others.Forestry Operations:The company did not provide documents relating toinventory of Greenhouse Gas (GHG) as an energy balanceof the project. The project considers the use of fossil fuelsources and will result in emission of greenhouse gases.Logistics Project:ELDORADO’s logistics operation is still in the detailingstudy stage. ELDORADO has not yet estimated the carbondioxide emission equivalents for the project. As informed,this estimate is currently being developed, in spite of notbeing required by the Brazilian regulations.3.3 9 Low Logistics Project:The logistics operations are not associated with high waterconsumption. The main water use will be associated withhuman consumption. According to information providedby ELDORADO, no maintenance activities will beperformed in the terminals.In the port of Santos terminals, water is supplied byCODESP, which has two distribution systems: drinkingwater and reuse water. CODESP is supposed to deliverwater to the consumers complying with the drinking waterThe site should develop an estimate of greenhouse gas(GHG) emissions at the project stage, according tointernationally recognized methodology, such as theGuidelines of the Intergovernmental Panel on ClimateChange (IPCC) or equivalent.The GHG emissions estimate should be annuallyreviewed.The company should quantify GHG emissions, not onlycarbon sequestration, but also emissions, as the first stepin managing and ultimately reducing emissions in a costeffectivemanner, as required by Performance Standard 3.Guarantee that no water contamination occurs inside itsinstallations in Santos.Guarantee that third party companies distribute water forhuman consumption in Aparecida do Taboado andPederneiras are in compliance with the drinking waterstandards.Apply for a water abstraction permit for the wellENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201293

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsstandards established by Brazilian regulations. However,ELDORADO is responsible for preventing watercontamination inside its installations.In Aparecida do Taboado a deep well will reportedly beinstalled to supply water for domestic use.No details on the water distribution system were available.Water quality in Pederneiras will be responsibility ofEGTM – Torque and in Aparecida do Taboado of ALL.Pollution Prevention3.4 10 Low Industrial Operations:The air quality monitoring campaigns conducted to datehas not included the monitoring of Particulate MatterPM2.5.3.5 10 and LowIndustrial Operations:11According to the pulp mill project and informationprovided to ERM during the site visit, effluents will betreated in an on-site wastewater treatment system anddischarged into Paraná River via an effluent outfall,installed upstream of the pulp water intake point.comprising primary clarification for solids-containingeffluents, neutralization ofThe effluent treatment system will consist primarytreatment (solids-containing effluent) and a biologicaltreatment for effluents joint treatment (activated sludge).ERM reviewed the process guarantees provided by theeffluent treatment system supplier.Taking into account the process guarantees, ERMcompared the effluent estimated quality with the IFC EHSguidelines and the applicable wastewater dischargestandards.ERM evidenced compliance with the standards.Similarly, the process guarantees result in the followingspecific flow and loads:installation in Aparecida do Taboado.Include Particulate Matter PM 2.5 in the next monitoringcampaigns, to assure compliance with internationalstandards and IFC Guidelines.ELDORADO to confirm whether they can meet the IFCstandard for phosphorous.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201294

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions3.6 10 and11ModerateParameter Specific value IFC GFlow (m³/ADt)28.9 Average36.8 DesignBOD (kg/ADt) 0.59TSS (kg/ADt) 1.11AOX (kg/ADt) 0.14Total Nitrogen (kg/ADt) 0.18Total Phosphorus (kg/Adt) 0.04Although the estimated total phosphorus content isroughly higher than the IFC specific standard, ERMunderstands that ELDORADO can adjust the treatmentprocess to lower the treated effluent phosphorusconcentration.Logistics Project:The São Paulo State Environmental Agency (CETESB)issued a statewide Contaminated Areas Report thatincludes the contaminated Sites in the State of Sao Paulothat are registered with the Agency. CETESB begandeveloping this report in May 2002 and it includes onlythose sites where companies have voluntarily disclosedinformation regarding soil/groundwater contamination. Ingeneral, this report is updated once a year and was lastupdated in November, 2010. The report does not containdetails regarding contaminated areas, such as results ofinvestigation analyses, dates of investigation, remediation,sizes of the areas affected by contamination, etc. It onlygives information on the main contaminants and status ofthe Sites in terms of investigation/remediation efforts.The area located out of the organized port of Santos,operated by Hipercon Terminais, with which ELDORADOwill sign a service provision contract, is not listed inCETESB’s website as a contaminated area. However, it issurrounded by bulk liquid terminals, which are listed ascontaminated areas (Stolthaven Santos, Ultragaz,Request Hipercon Terminais to assess soil and groundwatercontamination in its area to establish the baselineconditions, given that migration of contaminants fromsurrounding areas cannot be totally ruled out.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201295

GapRefNo.PSParaRef.No’s.3.7 12 High(legal noncompliance)Risk Group Description Recommended ActionsTequimar, among others). ERM understands that theoperations with ELDORADO’s finished product (bleachedkraft pulp) at that area will not represent an additionalpotential for soil/groundwater contamination in the area.Additionally, according to information provided byELDORADO, Hipercon Terminais operations at the areaare mostly related to receipt and shipment of sugar.However, regardless of the product handled on behalf ofELDORADO being a non-contaminating material,ELDORADO could be deemed co-responsible if acontamination at the area is detected.Industrial operations:As for the construction stage, ELDORADO hired a thirdparty company (Podium), which is responsible for theconstruction waste management. Podium is responsible tocollect the hazardous and non-hazardous wastes generatedby each contractor working in the construction site,centralize the temporary storage and give properdestination.Each contractor, in its turn, temporarily store generatedhazardous waste in a temporary storage area, until it isremoved by Podium to the central waste managementfacility.During the site visit, ERM sample checked the contractor’sinstallations and some deficiencies were noted. At theinstallations of Serpal (power boiler civil constructioncontractor), the hazardous waste storage area is small(approximately 4.0 m²), apparently insufficient toaccommodate the wastes generated (oily wastes, spentsolvent, etc.) until the transfer to the central waste facilityby Podium. As a result, reportedly because Podium hadnot yet removed the wastes from the generation point, sixdrums were observed outside the storage area, directly onunpaved soil, covered with a plastic sheet (no evidence ofleakage was observed). Additionally, the wastes were notadequately labeled.ERM observed a pile (approximately 50 m²) of fiber-cementInspect the contractors’ installations and make sure thathazardous wastes are being stored in covered, secondarilycontained and paved areas.ELDORADO should require the following actions fromPodium: Expedite the construction of the hazardous wastetemporary storage area; Develop a procedure for handling, storage anddisposal of asbestos-containing wastes that assure notonly environmental compliance with applicableregulations, but also health and safety regulations; Segregate asbestos-containing wastes and give themappropriate final disposal as hazardous waste; Develop a procedure for asbestos-containing wastesmanagement, including handling, storage anddisposal. The procedure should contain the guidancefor asbestos-waste handling, the required PPE to beprovided to employees and employees trainingrequirements; Appropriately train the employees responsible forasbestos-containing wastes handling.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201296

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsroof tiles on an unpaved area and evidenced that part ofthe tiles are asbestos-containing and part asbestos-free(with synthetic fibers). It is not possible to visuallydetermine the percentage of each type. Asbestos-containingconstruction waste is classified under Brazilian regulationsas hazardous waste and must be disposed of as such.Podium has not developed a procedure for handling anddisposal of asbestos-containing wastes, that are beingdisposed of as non-hazardous waste.Forest Operations: Waste handling: during the site visits, it was observedthat some types of waste were not adequately handledin the farms. The major issue is related to the aluminumdisposable dishes provided to the workers as part oftheir daily meal, which sometimes were disposed in animproper manner. Waste collection: it was reported that, in some cases, thegeneral waste of the farms was transported to the finalwaste disposal site by contractor’s stuff, and therefore,not following the Waste Management guidelines.ELDORADO has not provided information on whetherlicensed disposal sites are being operated to acceptablestandards or a possible program to reduce waste sent tosuch sites or alternative disposal options.3.7 13 Moderate Forest Operations:During the site visits at the farms, it was verified thefollowing issues related to the handling, storage and finaldestination of hazardous materials:a) Storage of Chemical and Hazard Materials:The chemical storage facilities (central warehouses) wereimplemented in strategic farms in order to facilitate thedistribution of agricultural inputs (e.g. fertilizers,herbicides, anticides, etc.) to nearby forest plantation sites.The issues related to the operation of these warehouses are: In one warehouse were identified expired products,open and/or violated packages, exposed chemicalImprove the Waste Management Program in order toaccomplish the following goals: Verify if the licensed disposal sites are being operatedto acceptable standards. Develop a program to reduce waste sent to disposalsites or alternative disposal options, including thepossibility of developing their own recovery ordisposal facilities at the project site. Improve the efficiency of the waste managementprocedures in order to avoid the problems identified inthe site visits regarding the waste handling andcollection.Improve the efficiency of the Hazardous MaterialManagement in order to: Provide detailed information on hazardousmaterials to be used throughout the differentproject stages, such as: volumes; characteristics/MSDS; handling and storage; and chemicalsstorage locations. Define the amount of asbestos containingmaterials, PCBs and ozone depleting substancesused by the operation and establish measures toreduce the use. Guarantee that Maintenance area have adequateENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201297

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsmaterials, used products, hazardous and non hazardouswaste. At the same location was observed a wet floor,probably derived from rain water entering through theventilation openings. The chemical inventory control system is not efficient.There are no documents at these places informing theamount or type of stored products. The inventorycontrol is basically done by the contractor’s stuff whenthe product is being used at the forest plantation sites The warehouse has no access restricted to qualifiedpersonnel. Anyone can access and manipulate theproducts. Even though there is a central warehouse, it wasobserved chemical and hazard products stored atinadequate places in other farms. According to evidence on site visit, hazardous products(paint thinner and oil for example) from maintenance oncultivation of eucalyptus fields are stored inadequately.The floor is not paved, there is no secondarycontainment or drainage to avoid leakage directly onsoilb) Transport of Chemical and Hazard Materials fromcentral warehouses to the forest plantation sites The transport of hazardous and chemicals materials isperformed by contractor’s personnel. It was reportedthat the contractor’s personnel does not hold theEmergency Preparedness and Response Plan during thetransportation of these products. ERM did not verify the transport operation of theseproductsc) Temporarily hazard waste disposal facilities The use of adequate storage facilities to storetemporarily used herbicides containers was notobserved. There is no clear definition on how or whereto store these containers. In one farm, misinformationwas provided regarding the location of this facility.d) Final hazard waste destinationhazardous material storage, with secondarycontainment or drainage to avoid leakages onsoil and water bodies.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201298

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions Reportedly all hazardous waste are not stored andimmediately collected by the respective contractedcompany for final disposal. In one farm, it was verifiedthat the hazard waste collection never happened, whereit was possible to count more than 200 used containers atthe same placePS 4 - Community Health, Safety and SecurityCommunity Health and Safety4.1 5 Low Industry ProjectELDORADO has identified the main risks to communityhealth and as defined by law, ELDORADO promotesawareness programs to workers about alcoholism,smoking, besides monitoring workers occupational healththrough medical examinations.Awareness programs should be applied to employees,contractors, their families and affected communities.Forest ProjectThe increase of transport flow on the inhabited areas wasassessed by ELDORADO and as a mitigate measure thecommunity is informed about the transportation schedule.The PTEAS also support the identification of trafficincrease on public roads.Develop the transportation plan considering avoidingimpacts on community health and safety, as identified byPTEAS.The plan to wood transport is not developed and it shall besupported by the PTEAS carried out before harvesting.Logistics Project:Considering the size of the logistics projects , that no inflowof workers is planned and that most of the activities will beperformed by contractors that already operate in the area(waterway, rail way and port), ELDORADO should be incharge to identify risks and impacts to community healthfor the road transportation, the railway branch(construction and operation at Aparecida do Taboado,Pederneiras and Santos) and terminal expansion (atPederneiras and Santos).Perform a health impact assessment to identifyimpact on community and workers health, includingcontractors (e.g identification of existing diseases ornew diseases that can be spread because of the inflowof workers) and, as a result, to define the appropriatemitigation measure to avoid and minimize theimpacts on health. This include: Sanitation (Public Health) measures (e.g. oncediseases are identified, asses if the public healthservice has the capability to prevent and treat it;ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 201299

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended ActionsReportedly, communities impacted by the roadtransportation are included on the EIA and the areaimpacted by industrial operation.Community Health and SafetySecurity Personnel4.2 12 Low ELDORADO reported not to monitor securityarrangements, neither provide training to securitypersonnel, nor there is a systemic procedure to verify ifthose providing security are not involved in past abuses. Prevention of communicable disease; Program to monitor workers health (contractorsand employees) to prevent STIs, water-bornedisease or other identified through the healthimpact assessment.Verify the process to identify health and safety riskand impact undertaken by ALL, MRS and CODESP,checking upon measures that are applicable toELDORADO or that could be undertaken jointly, ifapplicableIdentify risks and impacts to community health andsafety due to the road construction and operation (e.g.risk of coalition and traffic incidents), the railwaybranch and terminals (construction/expansion andoperation) and to define the appropriate measures.Provide workers with transportation serviceseducational programs related to sexual transmittedillness STIs and prevention of fatalities and injuries.Provide workers performing activities at the port ofSantos educational programs related to STIs.Ensure the grievance procedure and StakeholderEngagement Plan (PS1 Paragraph 25) are designed toidentify any concerns from local government,communities and workers regarding security activities.Industry Operations:Company Meta is in charge to manage the site supportfacilities, which include the security personnelarrangements, provided by Security. Reportedly, Meta is incharge to verify the documents of those providing security.Security personnel arrangements is provided at the site andthe 3 accommodations managed by ELDORADO. Thoseproviding security are in charge to supervise the access tothe site and accommodation.Define procedures on the correct code of conduct and useof the force by security personnel. This shall includemeasures to investigate and address any complaintsregarding potential human right abuses committed bythose providing security.Monitor those providing security arrangement to identifycompliance with the above mentioned procedures.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012100

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended ActionsForestry Operations:At most of the farms, there are no security personnel butworkers who perform round to identify fire and plague.Security personnel are provided at the accommodation by athird part company named Apolo Segurança Privada, hiredby Foco. Foco provided evidence of Apolo certificate tooperate, issued by the federal police, and the certificate thatauthorizes one worker to provide security issued by acertificated school. At the farm Correntes there are securitypersonnel hired by the previous owner of the land (thecompany MMX). ERM interviewed the security workingand documentation was according to Brazilian legislation.Logistics Project:Security Personnel shall be provided by those in charge ofeach modal of logistic operation, which include theterminals in Aparecida do Taboado and Pederneiras. AtSantos Port, Hipercom will be in charge of hiring securitypersonnel for their area, ELDORADO will be in charge ofthe area inside the organized Port called Terminal Elmarand CODESP of the general security services of the Port.As reported on the assessment of the industrial operation(PS4, paragraph 12 to 14) ELDORADO does not providetraining to security personnel, neither there is a systemicprocedure to verify if those providing security are notinvolved in past abuses.PS 5 - Land Acquisition and Involuntary ResettlementDisplacementEconomic Displacement5.1 25 to 29 Moderate Forest Operations:The PTEAS – Economic, Environmental and SocialTechnical Project (Projeto Técnico Econômico, Ambiental eSocial) includes the identification of use of roads byneighbors, access to water resources, closeness toneighbors, schools, churches, households, etc., which couldidentify economic displacement. As reported above, thisprocedure is dated December 2011 and it was notCarry out the PTEAS in all farms before intervention ismade. For areas in which intervention was made beforeand PTEAS was not carried on, ELDORADO must definemeasures to identify economic displacement.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012101

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsperformed in farms in which planting was carried outbefore this date.ELDORADO has performed PTEAS for only 2 farms (BarraMansa and Laranjal).Reportedly, no economic displacement has been carried outby ELDORADO.PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural ResourceGeneral6.2 6 and 7 Moderate Industry OperationAccording to the EIA, the studies conducted during theprevious license showed only the initial situation of thearea of influence and allow only a general prediction of theimpacts on biodiversity (related to the change in the landuse, increase in the nuisance to native species andrestrictions to resources usage). The reports of themonitoring programs (PBA) allow comparisons of data, yetstill are not related to ecosystems services.Licensing process does not require and does not includeidentification and analysis of impacts on eco-systemservices. Therefore there is no information regarding thisissue in the documentation presented.Forestry Operations:ELDORADO has performed several studies that addressesimpacts on biodiversity, such as: General environmental aspects and impacts assessment- Environmental Impacts (Impactos Ambientais). Forest Management Plan that includes monitoringactivities in order to check if the impacts are beingmitigated and minimized. Two studies performed by “Casa da Floresta” to identifythe areas with high conservation value inside itsproperties. These studies are: “Selection of areas of highEvaluate potentially impacts on ecosystem servicesthrough the existing studies (Industrial and Forestoperations) and the data obtained in the implementationof the environmental programs.ELDORADO should guarantee that the studies to bedeveloped in High Conservation Value Areas includequantitative and representative sampling of animal andvegetation communities, and make integrated assessmentof all components of the biota (analyzing thecommunities) to then integrate the physical and bioticaspects. This study should also evaluate impacts due tochange of use and isolation of the remaining naturalsinside the cultivation of eucalyptus; and the restriction ofmovement of animals from the Cerrado biome to theforest plantation.The risks and impacts identification studies shouldinclude the scoping for ecosystems services, at least in aqualitative way.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012102

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionsconservation value and planning of environmentalmonitoring”, which identifies and classifies areas ofHigh Conservation Value in order to protect anyexisting riparian areas, wetlands or other significantlyaffected natural or critical habitats; and “Inventory ofareas of high conservation value with critic socioculturalimportance and / or essential social functions inthe regions of work development of the Eldorado Brazil,Mato Grosso do Sul”. A third study is being carried out aiming to perform abiodiversity inventory in the areas identified as highconservation value and perform fauna and floramonitoring. PTEAS – Economic, Environmental and Social TechnicalProject (Projeto Técnico Econômico, Ambiental e Social)is an internal procedure that evaluates the economic,environmental and social aspects of the land beforemajor interferences (cultivation or harvesting).The available environmental studies do not includequantitative and representative sampling of animal andvegetation communities, neither make integratedassessment of all components of the biota (analyzing thecommunities) to then integrate the physical and bioticaspects. Also, it was not reported impacts due to change ofuse and isolation of the remaining naturals inside thecultivation of eucalyptus; and the restriction of movementof animals from the Cerrado biome to the forest plantation.The existing studies do not use concepts of ecosystemsservices.Logistics Project:The Simplified Environmental Report – RAS for themultimodal terminal in Aparecida do Taboado-MScontains an environmental and social impact assessment.However, it did not assessed impacts and risks tobiodiversity and ecosystems.With regards to Aparecida do Taboado, ELDORADOshould: Identify direct and indirect project-related impacts onbiodiversity and ecosystem services and identify anysignificant residual impacts.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012103

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended ActionsProtection and Conservation of Biodiversity6.4 11 and12LowIndustry OperationThe EIA presents quantitative data on fauna and flora.The EIA evaluated the impacts on flora and fauna(vegetation removal), as minor, and did not evaluateimpacts on biodiversity, considering that the project islocated in an area previously modified. It also presentsmitigation and management actions.PBA presents monitoring programs in order to minimizethe impacts and risks identified.Evaluate potentially impacts on biodiversity through theexisting studies (Industrial and Forest operations) and thedata obtained in the implementation of the environmentalprograms.6.5 13, 14and 15LowForest OperationAccording to site visit and information provided byELDORADO, legally protected areas (Permanentpreservation areas and Legal Reserves) as well as endemicor endangered species are maintained and preserved insidethe visited properties.The land use management guidelines (PS6 paragraphs 6and 7) are being also applied to leased lands, partnershipagreements and wood suppliers to guarantee that naturalhabits are not being converted to forest plantation in thirdpartyfarms. This requirement is imposed by contract.ERM observed that some of the legal reserve areas areisolated and surrounded by forest plantation or are notconnected with permanent protected areas (PPA) aroundthe riparian zones. This isolation may interfere with theecological function of these areas. However, this landconfiguration was mostly inherited from previousownership.There are three main actions that ELDORADO could takein order to improve the management of natural resources:1 – Try, when possible, to connect the Legal Reserves withProtected Permanent Areas (PPAs) in order to enhance theecological function of these areas, provide habitatcorridors and promote the conservation of rare,threatened or endangered species.2 – Implement a Native Forest Management System inisolated Legal Reserves in order to enhance theirecological function when other alternatives are notpossible (e.g. connection with PPAs)ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012104

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actions6.6 16 to 19 Moderate Forest OperationELDORADO presented two studies performed by “Casa daFloresta” on January of 2012 to identify the areas with highconservation value inside its properties. These studies are: “Selection of areas of high conservation value andplanning of environmental monitoring”. This studyidentifies and classifies areas of High ConservationValue in order to protect any existing riparian areas,wetlands or other significantly affected natural orcritical habitats. “Inventory of areas of high conservation value withcritic socio-cultural importance and / or essential socialfunctions in the regions of work development of theEldorado Brazil, Mato Grosso do Sul”.A third study is being carried out aiming to perform abiodiversity inventory in the areas identified as highconservation value and perform fauna and floramonitoring.After the conclusion of the third study ELDORADOshould consolidate the improvement actions to beperformed in these areas in a Biodiversity Action Plan, inorder to guarantee net gains of biodiversity values.6.7 20 Low Forest OperationA small fraction (less than 1 hectare) of two ELDORADO’sproperties (Correntes I e II Farms) are located inside anEnvironmental Protected Area (EPA) called PiraputangaPark Road, in the “Dois Irmãos do Buriti” municipality.This EPA was created by the Decreto N° 9.937/2000;however, the required zoning to ordinate the land useinside the Park was never done by the EnvironmentalAgency. It means that there is not yet any instruction orregulation on what type of use is allowed inside the EPA.Therefore, due to the small overlay between these areasand the lack of proper zoning, it does not configure a landuse conflict.ELDORADO is not actively managing the lands to bringthe PPA and the Legal reserve back into their natural state,based on a report that concludes that in Cerrado biome isbetter to leave them for natural reforestation.ELDORADO must follow the development of zoningregulation related to the Piraputanga Park Road, whichmay affect how the land is used in two of their propertiesNatural regeneration of the bioma Cerrado can occur oncethere is a near sources of propagules (other Cerrado areassurrounding) and since the operator favors the naturalregeneration. It should ensure disturbing factors (eg fire,opening trails, movement of domesticated animals likecattle and horses) are minimized or eliminated.ELDORADO should monitor if natural regenerationoccurs, and prepare a recovery plan, if necessary.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012105

GapRefNo.PSParaRef.No’s.PS 7 - Indigenous PeoplesRisk Group Description Recommended Actions7.1 8 Low Industrial and Forest Forest OperationAn archeological survey has been conducted in December2011, and identified that there was no indigenous groups ortraditional people affected by ELDORADO’s industrialoperation. The study was undertaken on 7 municipalitieswere ELDORADO operates: Tres Lagoas, Selvíria,Aparecida do Taboado, Inocencia, Agua Clara, Santa Ritado Pardo, Ribas do Rio Pardo. As a result, no indigenousgroups were identified on ELDORADO land and theclosest one is 96 km from the pulp plant.A social territory study was undertaken for the twomunicipalities, Anastacio and Dois Irmaos do Buruti, wereELDORADO possess lands. The study was undertaken bythe previous land owner and identified 7 indigenouscommunities in the region. .According to ELDORADO, there are no indigenous ortraditional people at ELDORADO’s land and the closestindigenous land is 22 km from Jatiúca Farm.ELDORADO reported that impact on indigenous andtraditional people will be identified through PTEAS thatwill be carried out before harvesting (between June toDecember 2012).ERM visited farms in Anastacio and Dois Irmãos de Buritiand interviewed workers. None were identified asindigenous workers.Identify the influence of the operation at Dois Irmãos doBuruti and Anastacio municipalities over indigenous ortraditional peoples through the PTEAS.In case impact on indigenous or traditional people isidentified, ELDORADO must develop an Action Plan tominimize, restore, and/or compensate for these impacts ina culturally appropriate manner commensurate with thenature and scale of such impacts and the vulnerability ofthe Affected Communities of Indigenous Peoples, incompliance with this performance standard and theBrazilian legislation.Include impacted indigenous people’s representatives, ifapplicable, on the Stakeholder Development Plandescribed in PS1, paragraph 27, 28.PS 8 - Cultural HeritageProtection of Cultural Heritage in Project Design and Execution8.1 6 and 7 Moderate Industry Operations:Archeological survey has been conducted in December2011. The study has revealed a set of 10 archaeological sitesand related chipped lithic remains. This study has beensubmitted to the Institute for National Historical andArtistic Heritage (IPHAN – Instituto do Patrimônio HistóricoRecommendations provided in the archaeological studyshould be implemented by ELDORADO.Guarantee that the Stakeholder Engagement Plan includesconsultation in relation to cultural heritage.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012106

GapRefNo.PSParaRef.No’s.Risk Group Description Recommended Actionse Artístico Nacional) and waits for the issuance of technicalopinion, however it does not involve consultations withaffected communities and therefore does not incorporate inits decision-making process the considerations of theseaffected communities.Forestry Operations:The Inventory of Areas of High Conservation Valueconsulted the community nearby the farms to identifycommon use of the biodiversity areas. This inventoryidentified that there are no areas of common use oressential to the community on ELDORADO’s farms.However, this study did not include the areas at DoisIrmãos do Buruti and Anastácio municipalities.For the disclosure, it was reported that a public hearingwill be carried out for the purpose of forest certification.Logistics Project:No evidence has been provided regarding protection ofcultural heritage.Identify important areas of common use or essential to thecommunity on ELDORADO’s farms located at DoisIrmãos do Buruti and Anastácio municipalities.Conduct the public hearing as planned.If archaeological and cultural remains are found duringconstruction, the works must be stopped and an expert inthe field should be called for inspection. It requirestraining of workers so they can identify these remainsduring construction. This is valid for Aparecida doTaboado and Pederneiras Terminal.ELDORADO should identify and protect cultural heritageby ensuring that internationally recognized practices forthe protection, field-based study, and documentation ofcultural heritage are implemented. The Company shouldconsult with the Affected Communities to identifycultural heritage of importance, and to incorporate intothe client’s decision-making process the views of theAffected Communities on such cultural heritage. This isvalid for Aparecida do Taboado and PederneirasTerminal.As for the Port Terminal in Santos, studies should havealready been performed by IPHAN since the areas isalready occupied for a long period of time. It isrecommended to check this information with the institute.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO - APRIL, 2012107

6 FINAL OBSERVATIONS AND RECOMMENDATIONERM Brazil Ltda. (ERM) was commissioned by ELDORADO BRASIL(ELDORADO) to act as Independent Environmental Consultant and toconduct an independent Social and Environmental Assessment of its pulp andpaper plant project which is currently under construction. The project is beingdeveloped in Três Lagoas State of Mato Grosso do Sul/Brazil and includeslogistics operations for the transportation of pulp produced in the industrialcomplex, to the port of Santos in the State of São Paulo. The objective of theAssessment was to provide technical information for the financing processwith FINNVERA, EKN and OeKB.The Area of Influence of the Project represents the geographical areaconsidered to be affected or potentially affected by the Project’s activities. Thisincludes facilities that are directly owned, operated or managed (including bysub-contractors), and including those areas of unplanned but predictable andindirect impacts on biodiversity or on ecosystem services (the benefits peopleobtain from ecosystems) upon which affected communities’ livelihoods aredependent. In addition facilities associated with or influenced byELDORADO’s existing facilities, which would not have been constructed orexpanded without these facilities, and any third party activities (includingsupply chains) where ELDORADO has significant control and influence overthe third party are also contained within the Area of Influence of the Project.This report presents the findings of the independent analysis which has beencarried out with reference to the Equator Principles; the financial industrybenchmark for identifying, assessing and managing social and environmentalrisk in project financing.Besides the gaps and findings identified and shown in Annex C, D and E forthe industrial plant, forest operations and logistics project, respectively, ERMhas identified some issues as part of the external factor review and during thevisits that also poses risk to ELDORADO and potential lenders. These issuesare described below: According to secondary data review, one of the ELDORADO’S partners,Mário Celso Lopes (from MJ Empreendimentos) has a rubber treeplantation in which the Ministry of Labor identified 23 workers in slavelike conditions in June 2010. This farm (Fazenda Santa Izabel) is located atMato Grosso State, around 2.000 km away from Mato Grosso do Sul State.This resulted in 25 infractions notified by the Ministry and the case wasanalyzed by the Federal Justice. According to a report provided by the lawcompany in charge of his defense, document named Detailed Report ofProcess (Relatório Detalhado de Processo, dated September 22nd 2011 andNovember 30th, 2011), payments to the workers were made according tothe agreement with the Labor Ministry and the case has been consideredconcluded. As a result, Mário Lopes and the farm will not be added to theENVIRONMENTAL RESOURCES MANAGEMENT 108ELDORADO - APRIL, 2012

Labor Ministry’s Black List. Companies listed are not allowed to participateon bidding and to receive public funds; During ERM visit, it was observed a settlement of the Landless Movementhad invaded the right side of way of the federal road, neighboring thefarms Correntes I and II. There are around 10 houses in the area and,according to the farm security personnel, they never invaded the farms. Toavoid conflict with the Landless movement, it is recommended to includethe families in the engagement process and provide adequate training forthe security personnel; and The secondary data review indicated that ALL has been accused by thePublic Ministry for employing 51 migrant workers in slave-like conditionsat São Paulo State, for which is being charged R$100 million. The workerswere recruited by a third party company for the expansion of the railway,but the Public Ministry understands that ALL was responsible for the poorworking conditions because of their deficient contractors managementpractices and because the degrading work was performed on the ALL’ssite, which was directly supervised by the company’s representative.(source: http://www.reporterbrasil.org.br/exibe.php?id=2012). This posesa reputational risk to ELDORADO in case the same practices are repeatedat the construction of the internal railway branch. Reportedly, the contractsigned between ELDORADO and ALL includes a clause that both partsshall not employ slave or child labor.In addition and as explained previously, ERM did not perform site visits to allfarms where ELDORADO has or will have plantations activities, due toschedule and budget reasons. ERM considers that the sampling performedwas adequate for an overall assessment of the Environmental and SocialManagement System, however, recognizes that with this strategy it was notpossible to identify specific conditions in the areas not visited. In order tomitigate this matter, ERM recommends ELDORADO to prioritize anenvironmental and social assessment of the areas not visit and include thespecific gaps in their corrective actions plan.Finally, ERM recommend that ELDORADO must develop a detailed ESMP –Environmental and Social Management Plan based on the evaluation of theE&S impact of the existing and future activities and facilities to ensureongoing compliance with national and IFC requirements during constructionand operation. The ESMP shall provide associated mitigation measures andmonitoring measures for both construction and operation phases.As part of the ESMP the following measures described on Table 5.2 should betaken as priority. A preliminary Environmental and Social (E&S) Action Planwith the priority measures will be prepared by ELDORADO and submitted tothe Financial Institutions.ENVIRONMENTAL RESOURCES MANAGEMENT 109ELDORADO - APRIL, 2012

Moreover, ELDORADO must prepare and provide an annual report on theimplementation progression of the E&S Action Plan and establish a thirdparty review process during remaining construction phase.ENVIRONMENTAL RESOURCES MANAGEMENT 110ELDORADO - APRIL, 2012

Annex AList of Documents Reviewedand Persons Interviewed

TIPO TÍTULO AUTOR DATA VSMapa - PDFTratamento de Efluentes - Estação de Tratamento de Efluentes - Lay Out geral Pöyry Tecnologia Ltda. 19/07/2011ETEnPDF Cais de Atracação - Alteração de localização e metodologia construtiva Pöyry Tecnologia Ltda. 08/11/2011 nWord - PDF Cais de Atracação - LP nº135 - Processo 23/108.071/2009 Eldorado Celulose e Papel S.A. - José Antonio Chiareli Caveanha 22/11/2011 nART - PDF ART - Anotação de Responsabilidade Técnica - Marcos Aparecido Franco Portela Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de08/08/2011São PaulonFormulário - PDF Sistema de Reserva Legal - SISREL MS. Formulário de Requerimento Secretaria de Estado de Meio Ambiente, Cidades, Planejamento, Ciências e26/02/2010TecnologianPDF Caderno de SSMA (Contratadas e Subcontratadas) Diretoria Técnica e Industrial / Gerência Administrativa - Eldorado30/11/2010Celulose e Papel S.A.nWord - PDFAlterações (Comissionamento e descrição das atividades)- Condicionante 07- LI Mayza Carla da Silva Devens - Eldorado Celulose e Papel S.A. 17/10/201117/2011 - Processo 23/101741/2010nWord Acompanhamento de atividades Não possui Não possui nExcel Planilha de monitoramento e medição de fumaça preta e vazamentos Montcalm ago-nov /2011 nPDF Estudo de dispersão atmosférica Storm & Smoke ago/11 nPDF Planilha de controle operacional Sanágua, Meta, Eldorado Brasil out/11 1PDF Planilha de controle operacional Sanágua, Meta, Eldorado Brasil out/11 2Word - PDF Relatório do Monitoramento da Estação de Tratamento de Água Provisória Mayza Carla da Silva Devens - Eldorado Celulose e Papel S.A. 02/01/2012 1Word - PDF Relatório do Monitoramento da Estação de Tratamento de Água Provisória Mayza Carla da Silva Devens - Eldorado Celulose e Papel S.A. 03/01/2012 2Certificado - PDF Certificação de Qualificação de Supervisor de Radioproteção Comissão Nacional de Energia Nuclear - Maria Helena Da Hora Marechal 05/08/2009nWord - PDF Inventário das fontes radioativas Não possui jul/11 nMapa - PDF Fábrica de celulose - área do processo - arranjo geral Pöyry Tecnologia Ltda. Não possui nAutorização ambiental Autorização ambiental para exploração vegetal SEMAC e IMASUL - Carlos Alberto N. Said Menezes 16/06/2011- PDFnLicença de Instalação - Licença de Instalação - Fabricação de celulose branqueada de eucalipto SEMAC e IMASUL - Carlos Alberto N. Said Menezes 26/03/2010PDFnLicença de Instalação - Licença de Instalação - Linha de transmissão de energia elétrica acima de 7,94 KV SEMAC e IMASUL - Carlos Alberto N. Said Menezes 22/07/2010PDFaté 230 KV1Licença de Instalação - Licença de Instalação - Linha de transmissão de energia elétrica acima de 7,94 KV SEMAC e IMASUL - Carlos Alberto N. Said Menezes 27/10/2010PDFaté 230 KV2Licença Prévia - PDF Licença Prévia - Canteiro de Obras SEMAC e IMASUL - Carlos Alberto N. Said Menezes 04/04/2011 1Licença Prévia - PDF Licença Prévia - Canteiro de Obras SEMAC e IMASUL - Carlos Alberto N. Said Menezes 04/04/2011 2Licença Prévia - PDF Licença Prévia - Cais de atração SEMAC e IMASUL - Carlos Alberto N. Said Menezes 04/11/2010 nLicença Prévia - PDF Licença Prévia - Linha de transmissão de energia elétrica acima de 7,94 KV até SEMAC e IMASUL - Carlos Alberto N. Said Menezes 22/07/2010230 KVnLicença Prévia - PDF Licença Prévia - Posto de abastecimento - PA SEMAC e IMASUL - Carlos Alberto N. Said Menezes 04/11/2010 nLicença Prévia - PDF Licença Prévia -Ferrovias SEMAC e IMASUL - Carlos Alberto N. Said Menezes 04/11/2010 nLicença de Operação - Licença Operação -Canteiro de Obras SEMAC e IMASUL - Carlos Alberto N. Said Menezes 13/04/2011PDFnWord - PDFContrato de Cessão onerosa de direito real de uso de imóvel municipal que entresi celebram o município de Três Lagoas e a empresa Eldorado Celulose e PapelLtda.Material Disponibilizado pela Eldorado à ERMMárcia Moura, prefeita de Três Lagoas e José Antonio Chiareli Caveanha,procurador da Eldorado Celulose01/05/2010Word - PDF Requerimento padrão - LO - Canteiro de Obras Eldorado Celulose e Papel S.A. - Edna Martha Martins Pereira 07/10/2011 1Word - PDF Requerimento padrão - LO - Canteiro de Obras Eldorado Celulose e Papel S.A. - Edna Martha Martins Pereira 18/08/2011 2Word - PDF Requerimento de autorização para perfuração de poço tubular profundo Eldorado Celulose e Papel S.A. - Edna Martha Martins Pereira 19/09/2011 nWord - PDF Formulário técnico para registro de poço tubular profundo Eldorado Celulose e Papel S.A. - Edna Martha Martins Pereira 13/07/2011 nAutorização Marinha - Requerimento de obras - Sistema de abastecimento de água Marinha do Brasil - Luis Fernando Baptistella 12/08/2011PDFnAutorização Marinha - Requerimento de obras - Sistema de lançamento de efluente industrial tratado Marinha do Brasil - Luis Fernando Baptistella 12/08/2011PDFnRecibo - GRU Autorização para regularização de um terminal hidroviário na margem direita do Marinha do Brasil - 3º SG MR Edson Cesar 08/12/2011Cobrança - PDF córrego bebedouronPDF Termo de Registro de inspeção Auditor fiscal do trabalho -Péricles Brandão Filho 07/07/2011 nPDF Livro da inspeção do trabalho Paranasa 01/03/2011 nPDF Notificação para apresentação de documentos Ministério do trabalho e emprego. Delegacia Regional do Trabalho -22/03/2011DRT/MS - Vanderci Braga GonçalvesnApresentação em Paralisações -Projeto Eldorado - 2011 Diretoria Técnica / Gerência Administrativa & SSMA 2011Power Point - PDFnWord - PDF Laudo de constatação e Auto de infração IMASUL 01/09/2011 nWord - PDF Auto de infração 2º 02119 Eldorado Brasil - Dr. Ricardo Ferreiro da Silva 19/09/2011 nWord - PDF Licença de operação - Fertibom Industrias Ltda. CETESB 07/07/2010 nWord - PDF Ofício nº 1046/2011 - Outorga de direito de uso dos recursos hídricos. Agência Nacional de Águas - Vicente Andreu. 04/08/2011 nWord - PDF ART - Anotação de Responsabilidade Técnica - Eduardo de Moura Nogueira Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de29/08/2011São PaulonWord - PDF ART - Anotação de Responsabilidade Técnica - Larissa Nantes Pereira Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de29/08/2011São PaulonWord - PDF ART - Anotação de Responsabilidade Técnica - Thiago Ranier Gomes Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de2011São PaulonWord - PDF ART - Anotação de Responsabilidade Técnica - Wagner Alexandre Folli Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de29/08/2011São PaulonDMP -Imagem de Acadstk (Imagem de mapa de Três Lagoas) Não possui Não possuimapa1JPEG - Imagem de Três Lagoas (Imagem de mapa de Três Lagoas) Não possui Não possuimapa2DWG -Imagem de Empreendimento (Imagem de mapa de Três Lagoas) Não possui 2011mapa3BAK -Imagem de Empreendimento (Imagem de mapa de Três Lagoas) Não possui 2011mapa4DWG -Imagem de Área de influência indireta (Imagem de mapa de Três Lagoas) Não possui Não possuimapa1BAK -Imagem de Área de influência indireta (Imagem de mapa de Três Lagoas) Não possui Não possuimapa2JPEG - Imagem de 3L (Imagem de mapa de Três Lagoas) Não possui Não possuimapanJPEG - Imagem de 3 Lagoas Não possui Não possuimapanBAK -Imagens Empreendimento 2011 ventos (Imagem de mapa de Três Lagoas e Predominância Não possui 2011do ventos)nJPEG - Imagem Ventos Não possui Não possui nBAK -Imagem de Empreendimento_2011_Uso_do_Solo_agricola Não possui 2011mapa1DWG -Imagem de Empreendimento_2011_Uso_do_Solo_agricola Não possui 2011mapa2JPEG - Imagem de Mapa solos 2 Não possui Não possuimapanWord EAP - Estudo ambiental preliminar (etapa) e estudo de análise de risco (era) - W F Ambientalago/11ampliação da ilha química com instalação da planta de clorato de sódionWord Programa de Proteção ao Meio Ambiente - Plano de Auto Monitoramento Eldorado Celulose S.A.ago/11nPlanta de Clorato de SódioWord - PDF Requerimento Padrão -LI - Protocolo ampliação p c SEMAC e IMASUL 31/08/2011 nWord - PDFEldorado Brasil Alojamento Am 8943 8944 8945 8946 - Boletim De Análises Sanágua - Fabiano Viana Storti 18/11/20111LaboratoriaisWord - PDF Eldorado Brasil Site 11419 11420 11421 11422 - Boletim De Análises Laboratoriais Sanágua - Fabiano Viana Storti 28/12/20112Word - PDFEldorado Brasil Site De Obras Am 9417 9418 9419 9420 - Boletim De Análises Sanágua - Fabiano Viana Storti 31/10/2011Laboratoriais3Word - PDFEldorado Brasil Site De Obras Am 10199 10200 10201 10202 - Boletim De Análises Sanágua - Fabiano Viana Storti 18/11/2011Laboratoriais4Word - PDFEldorado Brasil Site De Obras Am 10494 10495 10496 10497 - Boletim De Análises Sanágua - Fabiano Viana Storti 29/11/2011Laboratoriais5Word - Imagem Requerimento Padrão - Recuperação de áreas degradadas Edna Martha Martins Pereira - Eldorado Celulose 28/09/2011 nPDF Projeto Técnico para a Recuperação de área Degradada Guará Ambiental - Alessandra Dourado Caliente Quinto 29/09/2011 nMapa - PDF 405_PRADE_-_Projeto_Para_Recuperacao_Area_Degradada -mapa Não possui Não possui nPDF Projeto Eldorado - 1º Relatório PBA Eldorado Celulose e Papel S.A. - José Antonio C. Caveanha jan/11 nPDF Projeto Eldorado - 2º Relatório PBA Eldorado Celulose e Papel S.A. - José Antonio C. Caveanha jul/11 nWord - PDFCondicionante 06- LI 17/2011 - Processo 23/101741/2010- Relatório doMayza Carla da Silva Devens - Eldorado Celulose e Papel S.A. 30/11/2011Monitoramento da Qualidade do arnWord - PDFCondicionante 06- LI 17/2011 - Processo 23/101741/2010- Relatório doMayza Carla da Silva Devens - Eldorado Celulose e Papel S.A. 19/12/2011Monitoramento das águas superficiaisnWord - PDF1º Relatório do PBA - processo IMASUL 23/101741/2010 - Licença de Instalação Eldorado Celulose e Papel S.A. - José Antonio C. Caveanha 18/02/2011nº 54/2010 - fabricação de celulose branqueada de eucalipto - Projeto EldoradonnWord - PDF2º Relatório do PBA - processo IMASUL 23/101741/2010 - Licença de Instalaçãonº 17/2011 - fabricação de celulose branqueada de eucalipto - Projeto EldoradoEldorado Celulose e Papel S.A. -Edna Martha Martins Pereira 18/08/2011n

Material Disponibilizado pela Eldorado à ERMTIPO TÍTULO AUTOR DATA VSPDFRelatório Técnico da 2ª Campanha de Monitoramento Ambiental de Solo e Águas W F Ambientalset/11Subterrâneas Projeto Eldorado - Três Lagoas/MSnPDFMonitoramento da Qualidade das Águas Superficiais. RelatórioAnantecn - Análise Tecnológica Ltda - Edgar Sandim de Macedo Outubro de 2011086000054MAS2011-06nPDFAnálise da Qualidade do Ar na Região de Três Lagoas em Três Pontos Pré Storm & Smoke – Consultoria Ambiental e Prestadora de Serviçosset/11Definidos 21.09.2011 a 24.09.2011nWinZip Processo Executivo do Sistema de Controle Ambiental Pöyry Tecnologia Ltda 18.01.2010 nWord - PDF Projeto Eldorado - Tpe-051 - Transformadores de Potência Imersos em Óleo WEG Transmissão & Distribuição 15/02/2011 nExcel SE138 KV ELDORADO- Transformador de potencia 138 kV (+12x1%-16X1%) -34,5 kV - 90/110 MVA (ONAN/ONAF)SE138 KV ELDORADO- Transformadorde potencia 13,8 - 36,2±2x2,5 kV - 115/140 MVA (ONAN/ONAF)Não possuiNão possuinWord Projeto Eldorado – Três Lagoas Ata De Reunião Eldorado Celulose e Papel S.A. 14/07/21010 nPDF Características do óleo mineral isolante tipo A WEG Transmissão & Distribuição Não possui nInternet - E-mail Proposta Técnica Eldorado Fernando Hebling - WEG Transmissão & Distribuição 09/06/2011 nWord - PDF Licença sanitária 2º 2669/11 Departamento de vigilância sanitária 04/08/2011 nWord - PDF Licença sanitária 2º 2668/11 Departamento de vigilância sanitária 19/09/2011 nWord - PDF Solicitação visita alojamento serviria Meta central de serviços -Mariana Deroide Marcolino 03/01/2012 nExcel - PDF Dados Estatísticos de Acidentes do Trabalho e Meio Ambiente DuPont e Eldorado Celulose e Papel 2011 nApresentação em 1ª Reunião de SSMA 2012 DuPont e Eldorado Celulose e Papel 04/01/2012Power Point - PDFnApresentação em 2ª Reunião de SSMA 2012 DuPont e Eldorado Celulose e Papel 11/01/2012Power Point - PDFnWord - PDF Caderno de SSMA (Contratadas e Subcontratadas) Diretoria Técnica e Industrial / Gerência Administrativa - Eldorado2011Celulose e Papel S.A.nApresentação em COMSECON DuPont e Eldorado Celulose e Papel 19/01/2012Power Point - PDFnExcel - PDF IPA - Índice De Práticas Ambientais Eldorado Celulose e Papel S.A. Não possui nExcel - PDF IPS - Índice De Práticas Seguras Eldorado Celulose e Papel S.A. Não possui nExcel - PDF Quadro informativo Dezembro NOV - (Planilha de incidentes e acidentes) Eldorado Celulose e Papel S.A. Não possui nExcel - PDF Quadro informativo Janeiro NOV - (Planilha de incidentes e acidentes) Eldorado Celulose e Papel S.A. Não possui nVídeo - Windows Teste.Velocidade Prof. Ian Johston - University Accident Researche Centre Não possuiMedianWord - PDF Acordo Coletivo de Trabalho 2011/2013 Antonio Luiz de Oliveira 01/04/2011 nWord - JPEG Tribunal Regional do Trabalho da 24ª Região Desembargador Federal do Trabalho, Francisco das Chagas Lima Filho Não possui1Word - JPEG Tribunal Regional do Trabalho da 24ª Região Desembargador Federal do Trabalho, Francisco das Chagas Lima Filho Não possuiWord - JPEG Tribunal Regional do Trabalho da 24ª Região Desembargador Federal do Trabalho, Francisco das Chagas Lima Filho Não possuiWord - PDF Acordo Coletivo De Trabalho 2011/2012 Sindicato dos Trabalhadores Rurais de Andradina e Florestal Brasil S.A. -Antonio Rodrigues dos Santos, Eduardo Fernando Malta e Marcelo Dantas01/05/201123nWord - PDF Acordo Coletivo De Trabalho 2011/2012 Sindicato dos Trabalhadores nas Indústrias de Papel, Celulose e EldoradoCelulose e Papel S.A. - Almir Morgão e Rogério D’Alcantara Queiroz Peres01/08/2011nAcordo Coletivo De Trabalho 2011/2013Sindicato dos Trabalhadores nas Indústrias Const. Est. Pav. o Ter.Apresentação em Integração de Novos Colaboradores - Florestal Eldorado Celulose e Papel S.A. Não possuiPower Point - PDFnApresentação em Treinamento de Integração Eldorado Celulose e Papel S.A. Não possuiPower Point - PDFnBanner - PDF Ouvidoria - Projeto Eldorado Eldorado Celulose e Papel S.A. Não possui nWord - PDFContrato Particular de compromisso de compra e venda de madeira em pé e Florestal Brasil e Carvoaria Ananmoma 02/12/2010outras avenças, que entre si celebram a Carvoaria Ananmoma e FlorestalnWord - PDF Contrato de Arrendamento Agrícola Florestal Brasil e Tipto e Indústria e Comércio de Calçados Ltda 30/06/2011 nWord - PDF Convenção Coletiva De Trabalho 2010/2012 Federacao dos Trabalhadores na Agricultura do Est MS e Federação da01/07/2010Agricultura e Pecuaria do Estado de Mato Grosso do Sul-FamasulnExcel - PDF Matriz De Treinamentos Legais - Operações Florestais Eldorado Celulose e Papel S.A. Não possui nExcel - PDF Empregados Próprios - Florestal Não possui 19/01/2012 nApresentação em Políticas de Remuneração e Benefícios Eldorado Celulose e Papel S.A. 28/02/2011Power Point - PDFnWord - PDF Lista de presença - Treinamento para os representantes da CIPATR Florestal Brasil e Eldorado Celulose e Papel S.A. out/11 nExcel - PDF Matriz De Treinamentos Legais - Operações Florestais Eldorado Celulose e Papel S.A. Não possui nExcel - PDF Matriz De Treinamentos Legais - D. industrial e Administrativa Eldorado Celulose e Papel S.A. Não possuiWord - PDF Certidão - Registro de imóveis Registradora Substituta - Comarca de Água Clara 27/05/2011 nExcel - PDF Nº de empregados Não possui 19/01/2012 nWord - PDF Procedimento Operacional - Treinamento e Capacitação Eldorado Celulose e Papel S.A. Não possui nApresentação em Políticas de Remuneração e Benefícios Eldorado Celulose e Papel S.A. 28/02/2011Power Point - PDFnWord - PDF Procedimento de Controle de Acessos (Portarias) Diretoria Técnica e Industrial / Gerência Administrativa - EldoradoNão possuiCelulose e Papel S.A.nOutlook - Mensagem Sem título - (transporte dos colaboradores da sua cidade de origem para Três Eldorado Celulose e Papel S.A. 23/01/2012de e-mailLagoas)nExcel - PDF Gestão de Competências Essenciais dez11 Não possui dez/11 nExcel - PDF Gestão de Competências Essenciais_meses_anteriores Não possui nov/11 nVídeo - Windows Floresta Plantada BRACELPA Associação Brasileira de Celulose e Papel Não possuiMedianApresentação em Projeto Eldorado Fábrica de celulose Eldorado Celulose e Papel S.A. 17/01/2012Power Point - PDFnWordP. C. M. S. O. – Programa de Controle Médico de Saúde Ocupacional - Água Médico do Trabalho - Dr. Ronaldo Bacci 21/10/2010ClaranWordP. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Pontal do Médico do Trabalho - Dr. Ronaldo Bacci 21/10/2010AraguaianWordP. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Santa Rita Médico do Trabalho - Dr. Ronaldo Bacci 21/10/2010do PardonWord P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Selviria Médico do Trabalho - Dr. Ronaldo Bacci 21/10/2010nWordP. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Três Médico do Trabalho - Dr. Ronaldo Bacci 21/10/2010LagoasWord P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Água Clara Florestal Brasil 20/10/2010WordP.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Pontal do Florestal Brasil 20/10/2010AraguaianWordP.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Santa Rita do Florestal Brasil 20/10/2010PardonWord P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Selviria Florestal Brasil 20/10/2010 nWord P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Três Lagoas Florestal Brasil 20/10/2010nWord P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional -Florestal Brasil 04/10/2010AndradinanWord P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Andradina Florestal Brasil 01/10/2010 nWord - PDF Licença de funcionamento Secretaria Municipal de Saúde de Andradina - Grupo técnico de vigilância23/03/2011sanitária municipalnExcel Ficha de Registro de Demandas Sociais Florestal Brasil Não possui nDocumento Físico Livro de Inspeção do Ministério do Trabalho Eldorado Celulose e Papel S.A. Não possui nDocumento Físico Livro de Inspeção do Ministério do Trabalho. Fazenda Boa Água Florestal - Fornecedor de Madeira Não possui nDocumento Físico Livro de Inspeção do Ministério do Trabalho. Fazenda Mutum Florestal - Fornecedor de Madeira Não possui nDocumento Físico Procedimento para Utilização do Alojamento Eldorado Não possui nDocumento Físico PC-MAC-003(00) - Projeto Técnico Ambiental e Social (PTEAS) Florestal Brasil Não possui nWord Lista de partes interessadas: Mailing Três Lagoas Eldorado Celulose e Papel S.A. Não possui nWord Lista de partes interessadas: Lista de Contato Três Lagoas Eldorado Celulose e Papel S.A. Não possui nWord Lista de partes interessadas: Fazendas Vizinhas Eldorado Celulose e Papel S.A. Não possui nWord Lista de partes interessadas: Indústrias locais Eldorado Celulose e Papel S.A. Não possui nWord Lista de partes interessadas: Lista de autoridades Eldorado Celulose e Papel S.A. Não possui nWord Lista de partes interessadas: Lista de autoridades do MS Eldorado Celulose e Papel S.A. Não possui nDocumento Físico Contrato de compra de madeira em pé para entrega futura nº 000004 Eldorado Celulose e Papel S.A. Não possui nDocumento Físico Contrato de Arrendamento Agrícola (modelo) Eldorado Celulose e Papel S.A. Não possui nDocumento Físico Contrato de Fornecimento de Madeira para entrega futura (modelo) Eldorado Celulose e Papel S.A. Não possui nDocumento Físico Cópia dos documento de 2 trabalhadores da empresa Plantar Florestal Brasil Não possui nDocumento Físico Cópia dos documento de 2 trabalhadores da empresa JS Florestal, certificados desaúde e segurança ocupacional, registro de entrega de EPIs e treinamentos.Florestal BrasilNão possuinnn

Material Disponibilizado pela Eldorado à ERMTIPO TÍTULO AUTOR DATA VSDocumentos Físicos Documentação de 2 trabalhadores rurais da Eldorado: Ficha de registro do Florestal BrasilNão possuiempregado; Contrato de Trabalho; recibo de entrega e devolução de Carteira deTrabalho e Previdência Social para anotações; Autorização de 20% de descontopara alimentação; Autorização para desconto em holerite da contribuição sindicalnassistencial; Acordo para compensação de horas de trabalho; Acordo paraprorrogação de horas trabalho; Acordo de prorrogação de horas extras; ASO.Documento Físico Jornal da Obra Eldorado Celulose e Papel S.A. jul/11 nMapa - documento Mapa ilustrando terras operadas pela Eldorado e terras indígenas Florestal Brasil Não possuifísiconDocumento Físico Bem-Vindo ao Treinamento de Integração Eldorado Celulose e Papel S.A. Não possui nWord-PDF Estudo de Análise de Riscos Junho 2011 Eldorado Celulose e Papel S.A. jun/11 nPDFAlvará nº 1.438, de 26 de março 2008. Emitido pela Polícia Federal para a Apolo Apolo Segurança privada LTDA 26/03/2008Segurança privada LTDAnPDFAlvará provisório emitido pela Prefeitura Municipal de Água Clara, MS para Foco Hotelaria e Assessoria 20/01/2012Foco Hotelaria e AssessorianApresentação em Relatório Mensal- Repúblicas Novembro 2011. Meta nov/11Power Point - PDFnApresentação em Relatório Mensal- Repúblicas Dezembro 2011. Meta dez/11Power Point - PDFnApresentação em Relatório de Vistoria de Retorno nº 1. Empresa Imetame Meta 10/01/2012Power Point - PDFnApresentação em Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua Silveira Silva. Meta 15/12/2011Power Point - PDFnApresentação em Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua 13 de Junho. Meta 26/10/2011Power Point - PDFnApresentação em Relatório de Vistoria de retorno nº 1. Empresa Paranasa. Rua Silveira Silva. Meta 18/11/2011Power Point - PDFnApresentação em Relatório de Vistoria de retorno nº 2. Empresa Paranasa. Rua Silveira Silva. Meta 12/12/2011Power Point - PDFnApresentação em Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua Rayldo de Meta 15/12/2011Power Point - PDF Oliveira Gomes.nApresentação em Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Rayldo de Oliveira Meta 04/01/2012Power Point - PDF Gomes.nApresentação em Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua MariaMeta 26/01/2011Power Point - PDF Guilhermina Esteves.nApresentação em Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Maria Guilhermina Meta 04/01/2012Power Point - PDF Esteves.nApresentação em Relatório de Vistoria em Alojamento nº 1. Empresa Paranasa. Rua Filinto Muller Meta 08/08/2011Power Point - PDFnApresentação em Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Filinto Muller Meta 25/08/2011Power Point - PDFnApresentação em Relatório de Vistoria de República nº 2. Empresa Paranasa. Rua Filinto Muller Meta 12/12/2011Power Point - PDFnApresentação em Relatório de Vistoria de Retorno nº 2. Empresa Paranasa. Rua Filinto Muller Meta 20/01/2012Power Point - PDFnApresentação em Relatório de Vistoria em Alojamento nº 1. Empresa Paranasa. Rua Viela Senai Meta 21/09/2011Power Point - PDFnApresentação em Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Viela Senai Meta 12/01/2011Power Point - PDFnApresentação em Relatório de Vistoria de Retorno nº 2. Empresa Paranasa. Rua Viela Senai Meta 20/01/2012Power Point - PDFnApresentação em Relatório de Vistoria de Retorno nº 1. Empresa Mutual Construções LTDA, Rua Meta 20/01/2011Power Point - PDF Alfredo Justino, 75nApresentação em Relatório de ocorrência nº 06. Empresa Paranasa Engenharia e Comércio S.A. Rua Meta 02/01/2012Power Point - PDF Silveira Silva, 30 (Amarelinha)nWord - PDF Análise Laboratorial - Sedimentos Analítica - Análises químicas e controle de qualidade 20/12/2010 nImagem - PDF Mapa_ComunidadeAquatica_A3 Anantecn - Análise Tecnológica Ltda set/10 nImagem - PDF Mapa A3 Fauna, Flora Terrestre Anantecn - Análise Tecnológica Ltda set/10 nWord - PDF Monitoramento da Qualidade das Águas Superficiais - Relatório Técnico 02 Anantecn - Análise Tecnológica Ltda dez/10 nWord - PDFMonitoramento da Fauna Silvestre, Flora e Comunidades Aquáticas - Relatório Anantecn - Análise Tecnológica Ltda set e dez /2010Técnico Semestral 01nWord - PDF Relatório Técnico de Amostragem Águas Superficiais Anantecn - Análise Tecnológica Ltda dez/10 nWord - JPEG ART - Anotação de Responsabilidade Técnica Conselho Regional de Engenharia, Arquitetura e Agronomia de Mato18/01/2011Grosso do SulnExcel - PDF Planilha de Calibração/Amostragem – PTS Storm and Smoke - Eng. Amb. Alfrink Haruo Kikuchi Porfirio 29/09/2010 nCertificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 1Certificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 2Certificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 3Certificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 4Word - JPEG Certificado de Calibração Instrutemp - Instrumentos de Medição Ltda. 30/10/2009 1Word - PDFAnálise da Qualidade do Ar na Região de Três Lagoas em Três Pontos Pré Storm and Smoke -Consultoria Ambiental e Prestadora de Serviçosout/10DefinidosnExcel - PDF Planilha de Calibração/Amostragem – PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 22/12/2010 nCertificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 5Certificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 6Certificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 7Certificado - JPEG Certificado de Controle de Qualidade Environnement S.A. - M. Paulze 17/09/2010 8Word - JPEG Certificado de Calibração Instrutemp - Instrumentos de Medição Ltda. 30/10/2009 2Word - JPEG ART - Anotação de Responsabilidade Técnica Conselho Regional de Engenharia, Arquitetura e Agronomia de Mato18/01/2011Grosso do Sul2Word - PDFAnalise da Qualidade do Ar Na Região de Três Lagoas em Três Pontos Pré- Storm and Smoke -Consultoria Ambiental e Prestadora de Serviçosjan/11DefinidosnWord - PDF 1º Relatório PBA – Projeto Eldorado Eldorado Celulose e Papel S.A. jun-dez/2010 nFoto - WinZip Anexo 7 - Projeto primeira profissão Não Possui Não Possui nWord - PDF Ofício - Lançamento de Cartilha de Conscientização Ambiental Secretário Municipal de Meio Ambiente - Cristovam Lages Canela 16/12/2010 nApresentação em Programa: Minha Primeira Profissão - Projeto Eldorado Brasil Eldorado Celulose e Papel S.A. 29/09/2010Power PointnWord - PDFCaderno de SMS (Contratadas e Subcontratadas) - Segurança do Trabalho, Meio Eldorado Celulose e Papel S.A. 20/09/2010Ambiente e Saúde Contratadas e SubcontratadasnWord - PDFProjeto de Levantamento do Patrimônio Arqueológico e Cultural da Área Griphus Consultoria em Recursos Culturais Ltda - Márcio Antônio Telles,nov/10Diretamente Afetada Pela Implantação Projeto Eldorado da Eldorado Celulose E MS Jonas Israel de Sousa MelonPapel Ltda. - Município de Três Lagoas – Mato Grosso Do Sul.Word - PDF Anexo 2a -Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 29/03/2011 nWord - PDF Anexo 2b- Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 30/03/2011 nWord - PDF Anexo 2c -Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 01/04/2011 nWord - PDF Anexo 2d -Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 11/07/2011 nWord - PDF Anexo 2e - Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 12/07/2011 nWord - PDF Anexo 2f - Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 13/07/2011 nWord - PDF Anexo 2g- Planilha de Amostragem - PTS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 14/07/2011 nWord - PDF ADR - 1200s Certificado de Calibração Thermo Fisher Scientific 15/10/2007 nWord - PDF Média Horária do MP10 Eldorado Celulose e Papel S.A. mar-abr/? nWord - PDF Material particulado PM10 Eldorado Celulose e Papel S.A. 11-12/7/2011 nWord - JPEG ART - Anotação de Responsabilidade Técnica Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de07/04/2011São PaulonWord - PDF ART - Anotação de Responsabilidade Técnica - Alfrink Haruo Kikushi Porfirio Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de19/07/2011São PaulonWord - PDF Relatório da Qualidade do Ar na Região de Três Lagoas-MS Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços 15.07.2011 nPDF - WinZip Monitoramento da Fauna Silvestre, Flora e Comunidades Aquáticas - Relatório Anantecn - Análise Tecnológica Ltda.jun/11Consolidado 056000054RMA2011-05nPDF - WinZip Relatório de Visita Técnica Anantecn - Análise Tecnológica Ltda. 30/04/2011 nPDF - WinZip 2º Relatório PBA – Projeto Eldorado Eldorado Celulose e Papel S.A. jun/11 nPDF - WinZip 2º Relatório do Programa Básico Ambiental PBA – Processo IMASUL23/101.741/2010 - Licença de Instalação - Fabricação de celulose branqueada deEldorado Celulose e Papel S.A. - Edna Martha Martins Pereira 18/08/2011neucalipto - Projeto EldoradoApresentação em Atendimento de Licença Ambiental Eldorado Celulose e Papel S.A. - Jose Antonio Caveanha 28 de setembro de 2011Power PointnWord - PDF Plano de Trabalho - Descrição do Projeto - Anexo I Eldorado Celulose e Papel S.A. - Jose Antonio Caveanha 26/07/2010 nWord - PDFTermo de compromisso de compensação ambiental nº 002/2010 que celebra aEldorado Celulose e Papel Ltda. com o Instituto de Meio Ambiente de MatoIMASUL -Carlos Alberto Negreiros Said Menezes. Eldorado Celulose ePapel S.A. - Jose Antonio Caveanha26/07/2010nGrosso do SulPDF - WinZip Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto DMB Engenharia e Florestal Investimentos Florestais S⁄ANão PossuiAmbiental (RIMA) e Análise de Risco (AR) - Capítulo 1 - IntroduçãonPDF - WinZip Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto DMB Engenharia e Florestal Investimentos Florestais S⁄ANão PossuiAmbiental (RIMA) e Análise de Risco (AR) - CAPÍTULO 2 – INFORMAÇÕESnGERAIS

Material Disponibilizado pela Eldorado à ERMTIPO TÍTULO AUTOR DATA VSPDF - WinZip Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto Florestal Investimentos Florestais S⁄ANão PossuiAmbiental (RIMA) e Análise de Risco (AR) -CAPÍTULO 3 – CARACTERIZAÇÃOnDO EMPREENDIMENTOPDF - WinZip Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto Florestal Investimentos Florestais S⁄ANão PossuiAmbiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -nGERENCIAMENTO DE PRODUTOS PERIGOSOSPDF - WinZip Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto DMB Engenharia e Florestal Investimentos Florestais S⁄ANão PossuiAmbiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 - PROGRAMA DEnGERENCIAMENTO AMBIENTAL FABRILBAK e DWG - Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto DMB Engenharia e Florestal Investimentos Florestais S⁄ANão PossuiWinZipAmbiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -CAD_PROCESSOS_PRODUTIVOSImagens - JPEG, BAK Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto DMB Engenharia e Florestal Investimentos Florestais S⁄ANão Possuie DWG - WinZip Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -LayotnImagens de mapas -JPEG - WinZipImagens- JPEG -WinZipPDF - WinZipPDF - WinZipPDF - WinZipImagem de Mapa-PDF - WinZipPDF - WinZipPDF - WinZipPDF - WinZipPDF - WinZipPDF - WinZipPDF - WinZipProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -CARTOGRAFIA_ELDORADO1011Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -LocalizaçãoProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR) -CAPÍTULO 4 – ÀREAS DEINFLUÊNCIAProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR) -5.1 – MEIO FÍSICOProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR) -5.2 – MEIO BIÓTICOProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR) -5.2 – MEIO BIÓTICO - ANEXO:Mapa de cobertura do solo A3Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR-) 5.3 – MEIO ANTRÓPICOProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR-) CAPÍTULO 6 – ANÁLISE DISIMPACTOS AMBIENTAIS E MEDIDASMITIGADORASProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR-) - CAPÍTULO 7 – PROGRAMASAMBIENTAISProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR-) -CAPÍTULO 8 – ESTUDO DEDISPERSÃO ATMOSFÉRICAProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR-) CAPÍTULO 9 – ESTUDO DEANÁLISE DE RISCOProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de ImpactoAmbiental (RIMA) e Análise de Risco (AR-) CAPÍTULO 10 − CONSIDERAÇÕESFINAISDMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ADMB Engenharia e Florestal Investimentos Florestais S⁄ANão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiNão PossuiExcel - PDF Cronograma Projeto Básico Ambiental - PBA - Projeto Eldorado Não Possui Não Possui nWord - PDF Licença de Instalação - Fabricação de Celulose Branqueada de Eucalipto IMASUL -Carlos Alberto Negreiros Said Menezes 26/03/2010 nWord - PDF Projeto Eldorado: Programa Básico Ambiental - PBA DMB Engenharia e Eldorado Celulose e Papel S.A. Não Possui nApresentação em Atendimento de Licença Ambiental Eldorado Celulose e Papel S.A. 28/09/2011Power PointnWord - PDFNotas de reuniões - Fóruns para apresentação do PBA à comunidade de Três Eldorado Celulose e Papel S.A. - Jose Antonio Caveanha 18/03/2010Lagoas e regiãonWord - PDF Monitoramento da Estação de Tratamento de Efluentes Provisória Eldorado Celulose e Papel S.A. - Mayza Carla da Silva Devens 05/01/2012 nWord - PDF Relatório do Monitoramento da Estação de Tratamento de Água Provisória Eldorado Celulose e Papel S.A. - Mayza Carla da Silva Devens 01/09/2011 nWord - PDF Licença Prévia - Eldorado Celuloses e Papel -Canteiro de Obras de Três Lagoas IMASUL -Carlos Alberto Negreiros Said Menezes 04/04/2011nWord - PDF Licença Prévia - Eldorado Celuloses e Papel -Canteiro de Obras de Selviria IMASUL -Carlos Alberto Negreiros Said Menezes 04/04/2011 nWord - PDF Licença Prévia - Eldorado Celuloses e Papel - Cais de atracação de Três Lagoas IMASUL -Carlos Alberto Negreiros Said Menezes 04/04/2011nWord - PDFLicença Prévia - Florestal Investimentos Florestais - Fabricação de celulose IMASUL -Carlos Alberto Negreiros Said Menezes 16/12/2009branqueada de eucaliptonWord - JPEG Licença de Operação - Tratamento e disposição final de resíduos sólidos IMASUL -Carlos Alberto Negreiros Said Menezes 24/09/2009 nWord - PDFLicença de Operação - Eldorado Celulose e Papel - Linha de transmissão de IMASUL -Carlos Alberto Negreiros Said Menezes 24/02/2011energia elétrica acima de 7,94 KV até 230 KVnWord - JPEG Autorização ambiental para exploração vegetal IMASUL -Carlos Alberto Negreiros Said Menezes 16/06/2010 nWord - PDF Outorga de direito de uso dos recursos hídricos Agência Nacional de Águas - Vicente Andreu 04/08/2011 nWord - PDFAutorização para regularização de um terminal hidroviário na margem direita do Marinha do Brasil - 3º Sargento Mr Edson Cesar 08/12/2011córrego bebedouronWord - PDF Autorização para captação de água e emissário Marinha do Brasil - 3º Sargento Mr Edson Cesar 12/08/2011 nWord - PDFRelatório de Conclusão de Obra - Manutenção do Viveiro de Três Lagoas;Certificado de Entrega e Garantia; Atestado de conclusão de obra.Eldorado Celulose e Papel S.A. - Mayza Carla da Silva Devens ; Van DerHoeven-Antonio Carlos Luz; Secretaria Municipal de Meio Ambiente-07/11/2011nMateus Arantes.Word - PDFProjeto Técnico Ambiental para a Atividade de Supressão de Vegetação Nativano imóvel ruraldenominado Fazenda Eldorado conforme Resolução SEMAC n° 08.Janaína Monti Silveira 25/10/2011nWord - PDF Requerimento Padrão - Supressão Vegetal Eldorado Celulose e Papel S.A. -Edna Martha Martins Pereira 26/10/2011 nApresentação em Visão Geral da Companhia Eldorado Celulose e Papel S.A. 01/01/2012Power PointnFolder - PDF Audiência Pública - Projeto Eldorado. Convite. (capa) IMASUL -Carlos Alberto Negreiros Said Menezes; Florestal Invesimentos03/12/2009Florestais S/A- Projeto EldoradonFolder - PDF Audiência Pública. Folder parte 1 (interno) IMASUL -Carlos Alberto Negreiros Said Menezes; Florestal Invesimentos03/12/2009Florestais S/A- Projeto EldoradonFolder - PDF Audiência Pública. Folder parte 2 (final) IMASUL -Carlos Alberto Negreiros Said Menezes; Florestal Invesimentos40150Florestais S/A- Projeto EldoradonDocumento Físico Plano de Manejo submetido à IMASUL em 28 de Abril de 2010. Florestal Brasil 28/04/2010. nDocumento Físico Plano de Manejo submetido à IMASUL em 20 de Dezembro de 2011 para Florestal Brasil 40897reflorestamento de 3.885,7641 ha no município de InocêncianDocumento Físico Controle online da legislação ambiental, fornecida pela Âmbito. Florestal Brasil Não Possui nDocumento Físico Relatório de Aprovação Ambiental de Arrendamento de Terra (Modelo) Florestal Brasil nDocumento Físico Relatório Legal para contrato de arrendamento/parceria agrícola Fazenda Florestal BrasilNevadanDocumento Físico Relatório de Avaliação da Fazenda Barra Mansa, 02/09/2010 Florestal Brasil 40788 nDocumento Físico PTEAS – (Projeto Técnico Econômico, Ambiental e Social) da Fazenda LaranjaQuinhão I e II- UGO 01. Município de Três Lagoas. Visitada em 27 de OutubroFlorestal Brasil 40925n2011. Revisado em 17 de Jan 2012.Documento Físico PTEAS – (Projeto Técnico Econômico, Ambiental e Social) da Fazenda BarraMansa- UGO 01. Município de Três Lagoas. Visitada em 27 de dezembro de 2011.Florestal Brasil 40926nRevisado em 18 Jan 2012.Documento Físico Levantamento arqueológico na área de plantio de eucalipto da Florestal Brasil,municípios de Três Lagoas, Selvíria, Aparecida do Taboado, Inocência, ÁguaClara, Ribas do Rio Pardo e Santa Rita do Rio Pardo/MS. Dez/2011 (ProtocoloFlorestal Brasil Dez. 2011nIPHAN/MS nº 0141.000544/2011-82Documento Físico Planilha de controle de permissão de resíduos Florestal Brasil Não Possui nDocumento Físico Procedimento de gestão de resíduos Florestal Brasil Não Possui nDocumento Físico Alsco Toalheiro Brasil Ltda. - Licença de Operação válida até 05 de Novembro de Alsco Toalheiro Brasil Ltda 415832013.nDocumento Físico Lwart Lubrificantes Ltda. – Licença de Operação nº 453/2009 valida por 4 anos Lwart Lubrificantes Ltda 2009nDocumento Físico Lwart Lubrificantes Ltda. - Licença de Operação válida até 1º de Maio de 2013 Lwart Lubrificantes LtdaDocumento Físico Podium Serviços Ambientais Ltda. - Licença de Operação nº 367/2010 validos por Lwart Lubrificantes Ltda 20104 anosDocumento Físico Estre Emp. de Saneamento e Tratamento de Resíduos S.A. – C.G.R. Guatapará – Estre Emp. de Saneamento e Tratamento de Resíduos S.ALicença Parcial de Operação válida até 21 de Dezembro de 2012.nnnnnnnnnnnnnnDocumento FísicoDocumento FísicoDocumento FísicoDocumento FísicoDocumento FísicoMaxima Ambiental – Serviços Gerais e Participações Ltda. Licença de Operaçãonº 301156/2010 valida até 28 de Novembro de 2013.Essencis Soluções Ambientais S/A – Licença Operacional Parcial válida até 6 deJulho de 2012.Essencis Soluções Ambientais S/A – Licença Operacional Parcial válida até 6 deJunho de 2013.Essencis Soluções Ambientais S/A – Licença Operacional nº 041 válida até 29 deMarço de 2014.PPRA (Programa de Prevenção de Riscos Ambientais) 2012, PSSTSEF (Programade Saúde no Trabalho na Silvicultura e Exploração Florestal) 2011-2012, Registrode Treinamento - Integração, Primeiros Socorros, Manuseio de Pesticida - daempresa JS FlorestalMaxima AmbientalEssencis Soluções AmbientaisEssencis Soluções AmbientaisEssencis Soluções AmbientaisJS Florestal 2011-2012nnnnn

Material Disponibilizado pela Eldorado à ERMTIPO TÍTULO AUTOR DATA VSDocumento Físico Procedimento para Comunicação e Investigação para Acidentes e incidentes de Florestal BrasilnTrabalho – PC- SSO- 002Documento Físico Registro de Diálogo de Saúde e Segurança Florestal Brasil nDocumento Físico Registro de Treinamento para Aplicação e Manuseio de Pesticida em 30 a 31 de Florestal Brasil 40786Agosto de 2011. Duração 20horas para Unidade de Operação 1 - Três Lagoas-MS.nDocumento FísicoDocumento FísicoRegistro de Treinamento para Combate de Fogo em Floresta. 31 de Agosto de2011. Duração: 8 horas para Unidade de Operação 1- Três Lagoas-MS.Florestal Brasil 40786CIPATRs (Comissão Interna de Prevenção de Acidentes do Trabalho Rural) para Florestal Brasilas Unidades Operacionais de Três Lagoas, Selvíria, Andradina, Santa Rita doPardo e Água Clara. Informe da eleição e protocolada no Ministério do Trabalho.nnDocumento FísicoDocumento FísicoRegistro de encontros da CIPATR de 11 de Novembro, 2011 e Treinamento daCIPATR de 20 horas em 28 a 30 de Setembro,2011.PPRA (Programa de Prevenção de Riscos Ambientais) e LTCAT (Laudo Técnicodas Condições do Ambiente de Trabalho) da empresa Plantar 2011/2012Florestal Brasil 11/11/2011 e 30/11/2011Plantar 2011/2012nnDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilTrês Lagoas-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilSelvíria-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilPontal do Araguaia-MT;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilSanta Rita do Pardo-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilÁgua Clara-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilAndradina-SP;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilTrês Lagoas-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilSelvíria-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilPontal do Araguaia-MT;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilSanta Rita do Pardo-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para Florestal BrasilÁgua Clara-MS;nDocumento Físico Programa de Prevenção de Riscos Ocupacionais para Andradina - SP, como Florestal Brasilrequerido pela NR-09;nExcelPROCESSOS - Atividade - Operação (PlanilhaNão PossuiNão PossuiPoyry_Aspecto_Impacto_Avaliação_Final)nExcel PROJETO FSC (Cronog_FSC_CoC) Não Possui fev/12 nPDF - Word Diagnóstico Socioterritorial MMX; Integração Serviços e Assessoria Empresarial Ltda. jun/08 nExcel CERTIFICAÇÃO FLORESTAL - FSC Florestal Brasil Não Possui nPDF - Word Plano de Manejo Florestal Eldorado Brasil jan/12 nPDF - Word Portfólio Serviços Múltipla Múltipla Gestão de Pessoas Não Possui 2PDF - WordRelatório de Autuação (Relatório Autos de Infração - Super. Reg. Trabalho e Departamento jurídico - Thales Alessi de Oliveira Silva e Ana Malvina27/04/2011Emprego Mato Grosso)Ribeiro dos Santos2Word Comunicação e Social (Relatório Grupo Comunicação e Social) Não Possui 15/02/2012 nPDF - WordInventário de Áreas de Alto Valor de Conservação com importãncia sociocultural Casa da Floresta Assessoria Ambiental (Klaus Duarte Barretto, Mônicajan/12crítica e/ou funções sociais essenciais na região de atuação daCabello de Brito) e Eldorado BrasilEldorado Brasil, Mato Grosso do Sul2WordRelatório Detalhado de Processo -Ação Civil Pública -Ministério Público do Advocacia Gustavo Barbaroto Paro 19/06/2009Trabalho ( tr-rela-acp-mptXmcl-barra)nWord Relatório Detalhado de Processo -Ação Inibitória Advocacia Gustavo Barbaroto Paro 25/05/2011 nPDF - Word Boletim de Análises Laboratoriais (Eldorado Brasil Site AM 4069) Sanágua 17/05/2011 nPDF - Word Boletim de Análises Laboratoriais (Eldorado Brasil Site 7642 7643 7644 7645) SanáguanPDF - Word Boletim de Análises Laboratoriais (Eldorado AM 5458) Sanágua 27/06/2011 nPDF - Word Boletim de Análises Laboratoriais (Eldorado AM 5457) Sanágua 27/06/2011 nPDF - Word Relatório de Ensaio Nº11454/11 (Eldorado Brasil Site de Obras AM 11453 Sanágua 14/12/2011_retroativo_ _1_)2PDF Planilha de Controle Operacional - ETE - Site de Obras (RDOs) Sanágua, Eldorado Brasil e Meta 01/07/2011 nPDF Planilha de Controle Operacional - ETA - Site de Obras (RDOs) Sanágua, Eldorado Brasil e Meta 01/07/2011 nPDF Boletim de Análises Laboratoriais (Água site jul 11) Sanágua 01/07/2011 nPDFBoletim de Análises Laboratoriais (ELDORADO BRASIL ALOJAMENTO AM Sanágua 18/11/20118943 8944 8945 8946)nPDFBoletim de Análises Laboratoriais (ELDORADO BRASIL SITE DE OBRAS AM Sanágua 29/11/201110494 10495 10496 10497)nPDFBoletim de Análises Laboratoriais (ELDORADO BRASIL SITE DE OBRAS AM Sanágua 31/10/20119417 9418 9419 9420)nPDF Boletim de Análises Laboratoriais (ELDORADO BRASIL SITE 11419 11420 11421 Sanágua 28/12/201111422)nPDFBoletim de Análises Laboratoriais (ELDORADO BRASIL SITE DE OBRAS AM Sanágua 18/11/201110199 10200 10201 10202)nWinZip - PDF Relatório Analítico MI Dengue Ecovec S.A. , MI Dengue (Maria Rita Antunes Col) 03/07/1905 4Word Notificados e Positivos de Dengue Secretaria Municipal de Saúde de Três Lagoas; Departamento de30/01/2012Vigilância e Saneamento; Vigilância Epidemiológica / SINANNET2PDF Manual de Armazenamento de Produtos Fitossanitários ANDEF - Associação Nacional de Defesa Vegetal; COGAP - Comitê de02/07/1905Boas Práticas AgrícolasnPDF Monitoramento da Qualidade da Água Eldorado Celulose e Papel 01/07/2011 nPDF Solicitação visita sitio de obras Eldorado Celulose e Papel 20/07/2011 nWord Sistema de Documentação - Aquisição e Liberação de Terras Eldorado Celulose e Papel 02/01/2012 nWord Sistema de Documentação - Atendimento à Emergência Florestal Brasil 12/08/2011 nDocumento Físico Sistema de Documentação - Vigilância Patrimonial Eldorado Celulose e Papel 22/12/2011 nPDFPGRS – Plano de Gerenciamento de Resíduos Sólidos da ELDORADO BRASIL- Eldorado Brasil 01/02/2012Base Florestal0PDFConsiderações técnicas e legais do Projeto de Regularização da Reserva Legal do Consultoria Ambiental GuaráNão Possuiimóvel rural Faz. Eldorado.nPDF Proposta Multipla para Recrutamento, Seleção e Gestão de Pessoas Multipla Gestão de Pessoas 14/09/2011 nPDF Procedimento Corporativo para Seleção e Contratação de Pessoal Eldorado Brasil 24/02/2012 PC-RH-001(00)PDF Instrução de Trabalho para Índice de Fumaça Preta Florestal Brasil 13/06/2011 IT-MEF-001(00)PDF Manutenção Preventiva e Corretiva de Equipamentos, Veículos e Máquinas Florestal Brasil 14/06/2011 PO-MEF-001(00)PDF Instrução de Trabalho para Abastecimento de Equipamentos Florestais Florestal Brasil 18/01/2011 IT-MEF-002(00)PDF Procedimento Corporativo para Gerenciamento de Resíduos Eldorado Brasil 12/12/2011 PC-MAC-007(00)Word Projetos Socioambientais PBA - BNDES Eldorado Brasil 30/01/2012 n

Name Function SiteDaniel Mathias Financial Manager CorporateRicardo Ferreira da Silva Legal Affairs Manager CorporateJosé Antonio Caveanha Sustainability Manager IndustrialMaysa Carla da Silva Devens Sustainability Analyst IndustrialGermano Vieira Forest Director ForestJosé Sobrinho Vieira Silviculture Manager ForestSimone Filipo Social Responsibility ForestPriscila Quevedo Monteiro Garcez Forest Licensing ForestNátia Santos Environmental Management ForestOsvaldo Costa Health and Safety ForestAlessandra Schreiner Facilities Forest3 rural workers Worker Forest1 supervisor of rural workers Worker ForestPaulo Leme HR Industry and ForestAna Terra HR Industry and ForestFátima Garcia HR IndustryGislaine Maino Administrative Analyst IndustryMarcone Santos Araújo Environment Certification ForestAntônio José SodréIndustryEmployment RelatioshipCoordinatorSales Bueno Administration Manager IndustrialVinicius Garcia Administration Analyst IndustrialCarlos Borromeu Brunetto Process Consultant IndustryJosé Carlos Kling Process and Technology Manager IndustryDaniel Rubega Project Manager Industry2 contractor’s workers Worker IndustryWaldyr Bisco Manager CBC (power boiler supplierLeonardo Maia RochaManagerSerpal (power boilerconstruction worksGleison Laranjeira Rodrigues Safety Technician SerpalLarissa Rafaela de Oliveira Environmental Analyst SerpalCassio Keller Safety Technician CBCVinicius Borges S.L. Garcia Administration analyst IndustryZampierry IsslerOperational supervisorPodium (waste managementcontractorArtur Monteiro Environmental engineer PodiumFloriswaldo Ferreira da SilvaSupervisorMeta (employee relationshipcontractor)Douglas Henrique QueirozSupervisorMeta (employee relationshipcontractor)Mário Roberto ScossSafety EngineerDuPont (safety managementcontractor)Mário Kajita EHS Coordinator DuPontIssam Fares Jr. Occupational Physician IF Saúde (contractor)Leader of the cultivation team at theGerson de Souzatime of the site visit on Fazenda Barra ForestMansaMateus Reis and Moacir ReisWood Supplier and Land Leaser toELDORADOMutum GroupDaniel Mathias Financial Manager IndustrialAlvaro BunsterLogistics Executive ManagerPort and multimodalterminalsOtávio GrottoneLogistics CoordinatorPort and multimodalterminalsJosé Antonio Caveanha Sustainability Manager IndustrialAgnaldo Silva Souza Jr. Environmental coordinator Santos Port – Terminal ElmarClaudinei Gonçalves Warehouse Foreman Santos Port – Terminal Elmar

Annex BBrazilian EnvironmentalLicensing Process Description

1 ENVIRONMENTAL LICENSING PROCESSAs part of the scope, ERM assessed if the environmental licensing process,which includes the Environmental Impact Assessment (EIA) study, publichearings and the environmental basic programs, was performed incompliance with Brazilian regulations.Environmental Licensing RegulationsFederal Law 6.938/81 (amended by Laws 7.804/1989, 8.028/1990, 9.960/2000,9.966/2000, 10.165/2000, 11.105/2005 and 11.284/2006) defines theenvironmental permitting obligation for construction, installation,enlargement and operation of establishments and activities that useenvironmental resources, considered effective or potential polluters or thatcan cause environmental degradation.Article 10 of Federal Law 6.938/81, amended by Law 7.804/1989, establishesthat States are responsible for environmental licensing in their territories,except for projects with regional or national influence concerningenvironmental impacts, where IBAMA (Instituto Brasileiro de Meio Ambientee Recursos Naturais Renováveis), is currently assigned as the environmentalauthority.The environmental licensing of activities that are considered potential sourcesof pollution or present potential environmental impacts is regulated at theFederal level by Federal Law 6938/81; Federal Decrees 99274/90 and 3942/01;CONAMA Resolution 001/86 and CONAMA Resolution 237/97. Theseregulations establish three general levels of licensing for new projects. Theyalso indicate that the environmental authorities shall make licensingprocedures compatible with the planning and implementation steps of newprojects, having the following as minimum requirements: Preliminary License (Licença Prévia - LP): issued after the project anddesign of each facility has been approved; Installation License (Licença de Instalação - LI): issued before theconstruction of each development; and Operating License (Licença de Operação - LO): issued after the phase ofconstruction and before operations commence.Existing plants/facilities/developments must obtain new environmentalpermits whenever any processes are changed, any facilities are expanded ornew facilities are constructed which include any new equipment or building.

With regards to State licensing regulations for forest activities, according toSEMAC Resolution n.008 of 31 May 2011 of the State of Mato Grosso do Sul,and Resolution SEMAC / MS No. 17 September 20, 2007, the plantingactivities and conduct of forest species mentioned within are exempt fromlicensing.1.1 INDUSTRIAL SITE ENVIRONMENTAL LICENSING PROCEDURES1.1.1 Federal LevelFederal CONAMA Resolution 01/86 requires that Environmental and SocialImpact Assessment (EIA) must be prepared by developers for new projects orexpansions of projects listed in its Article 2, which includes pulp and paperproduction facilities, railways, ports, pipelines, high-voltage transmissionlines above 230 kV and energy power plants above 10 MW, among others.However, this list is only indicative, allowing State or Municipal agencies torequire an EIA for other planned industries or enlargement of existing ones.An EIA and its report RIMA - Environmental Impact Statement (Relatório deImpacto Ambiental) must be developed, submitted to the environmentalprotection agency and to a public hearing, reviewed and approved before theissuance of a Preliminary Permit.The authorities responsible for the EIA review at Federal Level are IBAMA(Brazilian Environmental Institute) and CONAMA (National EnvironmentalCouncil), and at State Level is the Environment Office/Environmental Councilof the respective State.CONAMA Resolution 01/86 also indicates that the EIA must be conducted bya qualified multidisciplinary team, independent of the project entrepreneur.All the 3 stages of permit previously described, besides having an expirationterm, are also subject of alterations, suspensions and annulments. Theseactions can happen in the following cases: Violation or unsatisfactory fulfillment of any legal rule or circumstance; Omission or misdirection of relevant information during the permittingprocess; and Occurrence of severe environmental and/or health risks.According to the Federal Regulations, the permits must be publiclyannounced. This measure was created in order to allow the society to take parton the licensing procedure. As stated by the CONAMA Resolution 006/86,“all the permit requests, renewing and issuing must be published at theofficial press, as well as in large-circulation regional or local periodicals”.

Failure in doing so causes the cancellation of the permit by the government orthe judicial power, by means of a class action.1.1.2 Licensing under Mato Grosso do Sul State ScopeThe Mato Grosso do Sul State Environmental Licensing process follows theFederal regulations and establishes complementation to the State and localresponsibilities.The laws and resolutions bellow summarize the legislation on the subject.Mato Grosso do Sul State Law nº 2257/01 establishes the guidelines for stateenvironmental licensing and the timeframe for the issuance of Permits andEnvironmental authorizations.According to its article 4 the procedure, for environmental licensing mustobey the following steps:I. Environmental Permit application by the entrepreneur, accompanied bythe documents appropriately filled out and following the legal and materialrequirements, projects and environmental studies requested and itspublicity;II. Documents, projects and environmental studies analysis presented andtechnical inspections, when necessary;III. Public Hearings, when necessary, according to the regulations;IV. Explanations and clarifications may be requested due to the analysis of thepublic hearings; andV. Issuance of the permit and publication of the permit concession.In its article 6 the specific procedures for environmental permit authorizationare defined, as well as the unique characteristics of a project or activity, forinstance, simplified procedures for low potential environmental impact whichwill be approved by State Environmental Control Council.Article 8 defines the limit date for notifications or expiration dates for permits.According to article 14, municipalities are responsible for environmentallicensing of enterprises and activities considered to have local impact, as wellas those delegated by IMASUL – Environmental Institute of Mato Grosso doSul State (Instituto de Meio Ambiente do Mato Grosso do Sul) by legalinstrument or agreement.SEMA (State Environmental Secretariat) Resolution nº 1 from January 26, 1989establishes the State Environmental Licensing service for pollutant activities,

defining the process which consists in obtaining three permit levels:Preliminary, Installation and Operating permits and the activities subjected toit.State Decree nº 10.600 from December 19, 2001 establishes the technical andadministrative cooperation between state and municipal environmentalagencies aiming at the licensing and inspection of activities with localenvironmental impacts.State Decree nº 11.204 from May 7, 2003 establishes the State jurisdiction forenvironmental licensing in Mato Grosso do Sul State.SEMA/IMAP Resolution nº 01, from April 30th, 2003 establishes theprocedures for environmental licensing process analysis.According to the Organic Law of Três Lagoas/MS city nº 1.795 from July 16,2002 the municipality is responsible to legislate about local public interests,complementing Federal and State regulations; promote spatial order throughuse and soil occupation control among others.1.1.3 ELDORADO Licensing StatusAs previously explained, the entrepreneurship of ELDORADO in the city ofTrês Lagoas, State of Mato Grosso do Sul -MS consists in the installation of ableached kraft eucalyptus pulp mill, eucalyptus homogeneous reforestationand related infrastructure such as pier, railway and power transmission lines.The Pulp mill is located on the road BR 158, km 231, Fazenda Santa Vera in themunicipality of Três Lagoas in the center western region of Brazil.The pulp mill has been granted, until the present moment, with Preliminaryand Installation Permits by the State Environment Agency IMASUL – MatoGrosso do Sul Environmental Institute (Instituto de Meio Ambiente do MatoGrosso do Sul). The Installation Permit – LI refers to the second step of theenvironmental licensing process, which includes the approval of theenvironmental and social impact assessment (EIA) and also the proposedenvironmental monitoring plans outlined in the Impact assessment study andthen detailed within an Environmental Basic Plan - PBA (Plano BásicoAmbiental).). The requirements of both licenses are being implemented.Therefore, the company is in compliance regarding the environmentallicensing process.The process began in 2009 with the elaboration of the EIA for a pulp milldeveloped by the former owner of the entrepreneurship FlorestalInvestimentos Florestais S⁄A (Florestal). Florestal has developed a strategiceucalyptus cultivation and also partnership and leasing contracts of wood inTrês Lagoas, Selvíria, Água Clara, Inocência, Aparecida do Taboado in MatoGrosso do Sul state and also other cities in the state of São Paulo.

During the EIA analysis process the Environmental Agency IMASULconducted a Public Hearing held on December 3rd, 2009, at 7pm in TrêsLagoas city, in Centro de Eventos Leiloado at Road BR 262, km 11.ELDORADO Brasil received the Preliminary License LP nº 314/2009. Afterthis, a complementary study called Basic Environmental Project (ProjetoBásico Ambiental - PBA) was held in order to detail the environmentalprograms proposed in the EIA and to comply with the technical requirementsimposed on the LP by the Environmental Agency.In this phase of the project it was decided that the power transmission lines,railway, pier and fuel station would have distinct licensing process andtherefore would require their own preliminary, installation and operatinglicenses. The forest is not subject to environmental licensing process.The environmental programs - PBA (Plano Básico Ambiental) are currentlybeing implemented.The table 1.1 lists the environmental programs (PBA).Table 1.1Environmental Programs of the Pulp and Paper MillEnvironmental Programs1. Project for Social Communication and Relationship with Communities close to theEnterprise – PCS2. Environmental Quality Control Project – PCQA2.a Monitoring of Surface Water Quality2.b Monitoring of groundwater quality.2.c Monitoring and Conservation of Flora.2.d Monitoring and Conservation of Terrestrial Fauna.i. Monitoring and Conservation of Avifauna.ii. Monitoring and Follow-up of Herpetofauna.iii. Monitoring and Supervision of the mammals.2.e Monitoring of Aquatic Communities.i. Monitoring and Conservation of Fish fauna.ii. Fauna Monitoring of benthic macroinvertebrates.2.f Air Quality Monitoring2.g Monitoring of the Wastewater Treatment System during installation phase.2.h Monitoring of wastewater Treatment System during operation.3. Social Development Projects – PDS3.a Project for Development Entrepreneurial3.b Adequacy of Project Infrastructure3.c Public Health Project3.d Security Project – Proseg3.e Project for education, leisure and culture to the employees4. Environmental Education and Training Project– PTEA5. Environmental Projects for Construction – PACAfter the elaboration of the PBA, public meetings were held with stakeholdersrepresenting all the society sectors in order to create a transparent process andtake in account different opinions.

Therefore, after analysis of documents from the environmental agency,ELDORADO has been issued the Installation License nº 17/2011 on February24th, 2011. The Installation License is valid until March 26th, 2013.ELDORADO has recently decided to include a sodium chloratemanufacturing plant on site, instead of transporting the sodium chlorate bytank trucks from market suppliers. As a result, it applied for an InstallationPermit for the plant expansion on August 31, 2011. Additionally, it developedan simplified environmental study (EAP – Estudo Ambiental Preliminar) anda risk analysis, considering the presence of the Chlorate plant to subsidize thelicensing process. The Installation Permit for the Chlorate Plant has not beenissued to date.The company foresees the completion of installation in November, 2012.Afterwards it will apply for the Operating Permit. In the meantime,ELDORADO applied for a permit for the commissioning stage on November18th, 2011 in order to include in the Installation Permit the commissioning of:pulp production, chemical recovery, utilities and manufacturing systems forsodium chlorate, chlorine dioxide and oxygen manufacture.The company has other licensing processes as follows below: Operation License nº 83/2011 from November 27th, 2010 for electricalsubstation – currently supplying energy to the construction works; Installation License nº 148/2011 from July 7th, 2010 for electrical substation– currently installing on site; Preliminary License nº 135/2010 from November 4th, 2010 for the pier –Reportedly ELDORADO has submitted to IMASUL a study called EAP –Preliminary Environmental Study, to change in 300m the coordinates of thepier which were informed in the EIA; Preliminary License nº 137/2010 from November 4th, 2010 for the fuelstation – The concessionaire of the fuel station is Petrobras and, reportedly,this company is responsible to issue the documentation for Installation andOperation License, since they will be operating the station and Preliminary License nº 136/2010 from November 4th, 2010 for railextension inside the enterprise.All the licenses listed above are currently valid.2 FORESTRY OPERATIONS LICENSINGFor the forestry activities no Environmental Impact Assessment (EIA) and

Environmental Basic Plan (PBA) were developed, according to the exemptiongranted by State regulations.The previously mentioned legislation requires Florestal to issues to IMASUL -state environmental agency - "Planting Informative" of the concerning areasfor such activity as well as the appropriate "environmental clearance forcutting of planted forests."These documents demand proof of preservation of legally protected areas.The legally protected areas, such as legal reserve and permanent preservationareas are defined by Brazilian legislation. Reportedly, it is expected an averageuse of 65% of the properties. According to information provided on site visitfrom the total of 32.295 m² of legally protected areas, 24.044 m² are legalreserves and 8,251m² are permanent preservation areas. Relating to the legalreserves, reportedly 13% of all legal reserves are submitted and recognized bythe environmental agency, 53% has been submitted to the environmentalagency for approval and 34% has signed term of commitment for proof oflegal reserve within two years.According to documents samples of eucalyptus cultivating areas, providedduring site visit, ELDORADO complies with licensing requirements andprocedures with the state environmental agency.3 LOGISTICS PROJECT ENVIRONMENTAL LICENSING PROCESSAs part of the scope, ERM assessed if the environmental licensing process wasperformed in compliance with Brazilian regulations for the following areas:Fazenda Boa Esperança in Aparecida do Taboado –MS, Terminal inPederneiras – SP, Temporary and future warehouses in Santos Port Terminal-SP.3.1 LICENSING UNDER FEDERAL SCOPEFederal Law 6.938/81 (amended by Laws 7.804/1989, 8.028/1990, 9.960/2000,9.966/2000, 10.165/2000, 11.105/2005 and 11.284/2006) defines theenvironmental permitting obligation for construction, installation,enlargement and operation of establishments and activities that useenvironmental resources, considered effective or potential polluters or thatcan cause environmental degradation.Article 10 of Federal Law 6.938/81, amended by Law 7.804/1989, establishesthat States are responsible for environmental licensing in their territories,except for projects with regional or national influence concerningenvironmental impacts, where the Federal Environmental Agency, IBAMA(Instituto Brasileiro de Meio Ambiente e Recursos Naturais Renováveis), is

currently assigned as the environmental authority.The environmental licensing of activities that are considered potential sourcesof pollution or present potential environmental impacts is regulated at theFederal level by Federal Law 6938/81; Federal Decrees 99274/90 and 3942/01;CONAMA Resolution 001/86 and CONAMA Resolution 237/97. Theseregulations establish three general levels of licensing for new projects. Theyalso indicate that the environmental authorities shall make licensingprocedures compatible with the planning and implementation steps of newprojects, having the following as minimum requirements: Preliminary License (Licença Prévia - LP): issued after the project anddesign of each facility has been approved; Installation License (Licença de Instalação - LI): issued before theconstruction of each development; and Operating License (Licença de Operação - LO): issued after the phase ofconstruction and before operations commence.Existing plants/facilities/developments must obtain new environmentalpermits whenever any processes are changed, any facilities are expanded ornew facilities are constructed which include any new equipment or building.The Federal Law 8630/93 deals with the legal operation of organized portsand port facilities and other measures.ANTAQ Resolution 830/07 approves the leasing program of areas and portfacilities in port of Santos.MMA Ordinance 424/11, provides for specific procedures to be applied byIBAMA in environmental regulation of ports and port terminals, as well asthose granted to Companhia Docas.The area of the Organized Port of Santos is composed in accordance withOrdinance No. 1021 of 12/20/93, of the Ministry of Transport by:a) the existing land port facilities on the right bank of the estuary formed bythe islands of Sao Vicente and Santo Amaro, from Ponta da Praia toAlemoa and on the left bank, from the island of Barnabé to the confluenceof the Rio Santo Amaro, including all piers, docks, bridges, piers andmooring berths, warehouses, yards, buildings in general, internalcirculation roads and rail roads, and also the land along these marginalbands and their surroundings, belonging to the Union, incorporated or notthe property of the Port of Santos, or under its custody and responsibility,including also the Itatinga Hydroelectric Power Plant and the range ofdomain of its transmission lines, and

) for infrastructure protection and waterway access, such as anchorage areas,evolution basin , the access channel until the parallel 23 º 52 '15 "south andadjacent to the banks of the ground facilities of the organized Port asdefined in letter "a" above, which is or will be constructed and maintainedby the Port or other agency of government.3.2 LICENSING UNDER MATO GROSSO DO SUL STATE SCOPEThe Mato Grosso do Sul State Environmental Licensing process follows theFederal regulations and establishes complementation to the State and localresponsibilities.The laws and resolutions bellow summarize the legislation on the subject.Mato Grosso do Sul State Law 2257/01 establishes the guidelines for stateenvironmental licensing and the timeframe for the issuance of Permits andEnvironmental authorizations.According to its article 4 the procedure, for environmental licensing mustobey the following steps:I. Environmental Permit application by the entrepreneur, accompanied bythe documents appropriately filled out and following the legal and materialrequirements, projects and environmental studies requested and itspublicity;II. Documents, projects and environmental studies analysis presented andtechnical inspections, when necessary;III. Public Hearings, when necessary, according to the regulations;IV. Explanations and clarifications may be requested due to the analysis ofthe public hearings; andV. Issuance of the permit and publication of the permit concession.In its article 6 the specific procedures for environmental permit authorizationare defined, as well as the unique characteristics of a project or activity, forinstance, simplified procedures for low potential environmental impact whichwill be approved by State Environmental Control Council.Article 8 defines the limit date for notifications or expiration dates for permits.According to article 14, municipalities are responsible for environmentallicensing of enterprises and activities considered to have local impact, as wellas those delegated by IMASUL – Environmental Institute of Mato Grosso doSul State (Instituto de Meio Ambiente do Mato Grosso do Sul) by legal

instrument or agreement.SEMA (State Environmental Secretariat) Resolution 01/89 establishes the StateEnvironmental Licensing service for pollutant activities, defining the processwhich consists in obtaining three permit levels: Preliminary, Installation andOperating permits and the activities subjected to it.State Decree 10.600/01 establishes the technical and administrativecooperation between state and municipal environmental agencies aiming atthe licensing and inspection of activities with local environmental impacts.State Decree 11.204/03 establishes the State jurisdiction for environmentallicensing in Mato Grosso do Sul State.SEMA/IMAP Resolution 01/03 establishes the procedures for environmentallicensing process analysis.According to SEMAC Resolution 008/2011, it was established thedocumentation required for environmental licensing of an infrastructureproject, such as the multimodal terminal with an area of up to 10,000 m²,which is ELDORADO’s case. To obtain the preliminary license it is required tosubmit the following studies to the state environmental agency (IMASUL):RAS - Simplified Environmental Report, PBA - Basic Environmental Plan andForm of linear works. In addition, to obtain the operating permit it is requiredthe RTC-Technical Report of Completion. In this case, the installation license isnot required.3.3 LICENSING UNDER SÃO PAULO STATE SCOPEThe São Paulo State Environmental Licensing process follows the Federalregulations and establishes complementation to the State and localresponsibilities.In the State of São Paulo, CETESB is the agency assigned with the authority toissue permits for potential pollution sources, including industrial activities.SMA (State Secretary of Environment) reviews licensing procedures for otherpotential pollution sources in the event a Environmental Impact Assessmentexists, in accordance with Federal regulations.According with the State Law 997, issued on May 31st, 1976, modified by Law9477/96, every installation, construction or enlargement and operation ofpollutant sources listed in this law are subject to prior authorization by theEnvironmental Authority via permits.Permits issued by the Environmental State Authority include:

Preliminary Environmental Permit – LP (Licença Prévia): issued duringthe planning of a pollution source. LP contains the basic requirementsthat must be complied with during the location, installation and operationof the project;Installation Environmental Permit – LI (Licença de Instalação): this permitauthorizes the installation / construction of the project; andOperating Environmental Permit - LO (Licença de Operação): authorizesthe operation of the site and any environmental control equipment, inaccordance with LP and LI requirements.The expiration date of the permits will be defined by the EnvironmentalAgency, depending on the projects potential for polluting. An OperatingEnvironmental Permit has a validity of approximately 5 years.State Decree 8468 issued on September 08, 1976 regulates State Law 997/76.Title V of the State Decree, modified by State Decree 47397/02, establishes thepermitting requirements for São Paulo State. Pollution sources subject to anEnvironmental Permit are listed in Article 57 of State Decree 8468/76. Annex10 of State Decree 8468/76 defines the projects subjected to LP. Article 58-A ofState Decree 8468/76, presents the activities subjected to an Installation Permitand Article 62 establishes the activities subjected to an Operating Permit.According to Article 58-A of State Decree 8468/76, the Installation Permitshould be obtained for:The construction, reconstruction, enlargement or renovation of anybuilding where a potential pollution source is installed;The installation of a new potential pollution source in an existingbuilding; andThe installation, enlargement or alteration of a pollution source.According to Article 62 of State Decree 8468/76, the LO should be obtainedfor:Use of a new building or modification to an existing building where anew pollution source will be installed;The operation of a pollution source within an existing building;The operation pollution source already installed, enlarged or modified;andLand subdivision, detachment condominium and housing development,prior to occupation, and cemeteries.

Article 59 of State Decree 8468/76 states that a Municipal Certificate isrequired when a facility applies for the installation permit, in order to verify ifthe location and type of the installation are in accordance with municipallegislation.Article 71 of the State Decree 8468/76 states that the pollution sources alreadycovered by an Operating Permit obtained prior to December 04, 2002 will becontacted by CETESB during the next five years, in order to update thepermit.State Decree 47397, issued on December 04, 2002 modify State Decree 8468/76and establishes deadlines for installation and operating permits applications,expiration dates of operating permits and the fees charged for issuing apermit.State Decree 47400/02 issued on December 04, 2002 regulates State Law9505/97 and establishes expiration dates for each type of environmentalpermit and the conditions for the permit renewal. The Operating Permit willbe valid for a period ranging from 2 to a maximum of 10 years.Article 5 of State Decree 47400/02 establishes that facilities subjected toenvironmental permits must communicate with the environmental agency thesuspension and closure of their activities, through a Deactivation Plan. TheDeactivation Plan must contain the environmental situation of the site and themeasures implemented to recover or remediate the site. A final report must besubmitted to the environmental agency after the completion of theremediation activities. The decree also establishes the schedule and prices forreview of the deactivation process.SMA Resolution 22/07 establishes the unification and integration ofenvironmental permitting in the State of São Paulo, and also modifiespermitting procedures for those activities listed in its attachments. Theintermodal Terminal in Pederneiras will be managed and operated by a thirdparty company which will be responsible for all environmental licensingprocedures as detailed below.3.4 PORT LICENSINGThere are different agencies with responsibilities related to environmentalcontrols in the area affected by the operations of the port of Santos: CODESP,which coordinates and monitors the progress of environmental management;the Navy, who must control the ships and pollution episodes caused by them,as well as channels and tide lands; the State Environmental Agency (CETESB),tasked with overseeing potentially polluting activities, monitor theenvironment and perform the licensing of activities that modify theenvironment; and the Federal Environmental Agency, IBAMA which is alsoresponsible for environmental licensing.

The Board of IBAMA Environmental Licensing, along with some stateenvironmental agencies (OEMA), are adopting the criteria of location in theterritorial sea or internal waters for the definition of competence of jurisdictionof environmental agencies to conduct the environmental permits for ports. Todo so, they are using the demarcation of straight baselines established byFederal Decree 4.983/2004.It is clear that, in accordance with Article 1 of Federal Law nº 8.617/1993, theBrazilian territorial sea is a belt of twelve nautical miles wide, measured fromthe low tide line of the coastal mainland and islands, as indicated in largescalecharts officially recognized in Brazil. In locations where the coastline isindented and cut deep or where there is a fringe of islands along the coast inits immediate vicinity, it is adopted the method of straight baselinesconnecting the appropriate points for drawing the baseline, from which tomeasure the extent of territorial sea.According to the Federal Decree 4.983/2004, in all other parts of the mainlandand island coasts of Brazil, where there were delimited straight baselines, areadopted Baseline Standard, as indicated in the large scale charts published bythe Board Hydrography and Navigation of the Navy of Brazil. Also accordingto its Article 4, the Straight and Normal Baselines should be used only as asource for the trace of the outer limits of the territorial sea, the contiguouszone, exclusive economic zone and continental shelf, whose concepts arespecified in the Act No 8.617/1993.Regarding the definition of internal waters, it can be found in the Federal Law9.966/2000 and at least two CONAMA Resolution (No. 344/2004 and No.392/2005). According to these legal instruments, would be those waters:between the coast and the line-of-base line, from which the territorial seais measured;waters of the ports;of the bays;the rivers and their estuaries;of lakes, ponds and canals;of the islands; andthe waters from the shallows and the discovery coast.Thus, in the case of the Port of Santos, both the port itself and the disposalarea where oceanic sediments are disposed of dredging are located under thelegal point of view, in internal waters. Therefore, it is possible to conclude thatthe licensing outside the organized port (which will be the temporary

warehouse managed and owned by a third party company and alsowarehouses III, VIII, XIII and XVIII purchased by ELDORADO) is the stateenvironmental agency (Cetesb) responsibility under the management ofManagement Port Authority (Codesp).In accordance with the provisions of federal and state environmentallegislation (mainly the CONAMA Resolution 237/1997 and the State Decree47.400/2002) Cetesb sets out the developments and port activities to belicensed.The permanent areas of the organized port, warehouses IX to XII, are licensedunder Federal Environmental Agency (IBAMA).3.5 ENVIRONMENTAL LICENSING STATUSAparecida do Taboado - MSAs previously explained, ELDORADO acquired a parcel of land, with 61.7hectares, which was part of a farm (Fazenda Boa Esperança) to build themultimodal terminal in Aparecida do Taboado, in Mato Grosso do Sul state.Reportedly, the area in which the warehouses will be built is approximatelyfrom 7,000 to 8,000m². Therefore, ELDORADO has hired Poyry Silviconsult inorder to develop the Simplified Environmental Report-RAS required forissuance of Preliminary License. The study was developed and reportedlysubmitted to the state environmental agency IMASUL. The study is beinganalyzed by IMASUL, in order to provide the preliminary license or requestfurther clarifications/complements before issuing such license.Reportedly, the adjustments of the railway extension access and all licensingprocedures in Aparecida do Taboado, will be performed by ELDORADO. Thisincludes eventual vegetation suppression with its compensations. ALL(América Latina Logística) will be responsible to transport the pulp and paperfrom Aparecida do Taboado to the Port of Santos according contractagreement already signed with ELDORADO.Pederneiras - SPReportedly, a warehouse will be constructed by ELDORADO, withapproximately 6,000-m² covered area, in Pederneiras. ELDORADO has hiredEGTM Navegação (Torque) which already owns a multimodal terminal andwill expand its boundaries in other to meet the demand.Regarding this company hired to work in logistics waterways of cellulose, itwas reported that the Service Agreement signed by the parties on December22, 2011 has an item referring that EGTM Navegação (Torque) agrees toobserve and comply with environmental legislation, being responsible forfines and notices of violation of activities directly related to the transportation

of cellulose, and is responsible for obtaining and maintaining any permits orlicenses required by public agencies, due to the object of the contract.Therefore, ELDORADO declares that has no responsibility regarding permitsor licensing of the area.Reportedly, the adjustments of the railway extension access in Pederneiras,will be performed MRS LOGÍSTICA S.A. As reported, the licensingprocedures and eventual vegetation suppression with its compensations willbe managed by this company.Santos-SPThe port of Santos is a logistic complex, with countless facilities, with a shareof common use, under the management of the Port Administration - CODESP,and partly directed to cargo handling, directly operated by private entities,under leasing agreements. There are few private use terminals in theorganized area of the port. These private companies have the useful domain ofthe area where they are.The port is equipped with rail to rail transit and railroads that serve it, and hasplaces for storage of general cargo, including containers, dry and liquid bulk,and the entire complex is managed by CODESP and policed by port guard.According to information available on IBAMA’s website, CODESP is currentlygoing through a regularization process and has been granted with theInstallation License nº 852/2011 on December 23, 2011.Reportedly, the railway to be used by the leased land is property of MRSLOGÍSTICA S.A. According information provided during interview withELDORADO staff, in order to build the rail extension needed for wagonsmaneuver, approximately 1.5km, the state agency would require an expansionplan from MRS. The area is close to mangrove vegetation considered aspreservation area by the Brazilian Environmental Legislation (Forest Code).Therefore, it is possible that MRS be subjected to compensation plans for thesuppression areas.The temporary warehouse, in which was established a service provisioncontract out of the organized port of Santos, is owned by Hipercon Terminaisde Cargas Ltda which currently has installation license according informationprovided on Cetesb’s website. ELDORADO has informed that the area will beoperated by this company which will be responsible for obtaining andmaintaining environmental permits and licenses, as well as for complyingwith the environmental legislation. Reportedly, the area of warehouses III,VIII, XIII and XVIII, inside the previously mentioned Elmar Terminal, hasbeen purchased by ELDORADO from Rodrimar S/A TransportesEquipamentos Industriais e Armazéns Gerais. Evidence has not beenprovided. Operating permits for warehouses III and VIII are currently under

Rodrimar’s name, according information on Cetesb’s website. Operatingpermit for warehouse III nº18001394 has been issued on 28/12/2009 and isvalid until 28/12/2013; operating permit for warehouse VIII nº 18001731 hasbeen issued on 03/10/2011 and is valid until 13/07/2014. No information hasbeen provided regarding changes in the corporate name of these permits.Regarding the permanent warehouses IX to XII, ELDORADO has providedthe Letter of introduction of the project of Port Terminal Eldorado Brazil /Santos-SP Portway submitted to IBAMA on 22/03/2011 showing that thefollowing items were issued:Illustrative picture of terminal project (former sugar terminal);Plan of leased areas and planned to lease in the port of Santos;Plant- conceptual design - Terminal Eldorado; andPlant of the future passenger terminal in Santos/ SP.According to IBAMA’s website, Terminal Eldorado Brasil (regardingwarehouses IX to XII) is in the initial phase of licensing and has requestedterm of reference; however the area is still waiting for bidding from CODESP.

Annex CGap Analysis Table – Pulpand Paper Industrial Project

Review against IFC Performance Standard 1 (Environmental and Social Management and Evaluation Systems)No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsEnvironmental and Social Assessment and Management System5. The client, in coordination with other responsible government agenciesand third parties as appropriate, will conduct a process ofenvironmental and social assessment, and establish and maintain anESMS (Environmental and Social Management System) appropriate tothe nature and scale of the project and commensurate with the level ofits environmental and social risks and impacts. The ESMS willincorporate the following elements: (i) policy; (ii) identification of risksand impacts; (iii) management programs; (iv) organizational capacityand competency; (v) emergency preparedness and response; (vi)stakeholder engagement; and (vii) monitoring and review.Policy6. The client will establish an overarching policy defining theenvironmental and social objectives and principles that guide theproject to achieve sound environmental and social performance. Thepolicy provides a framework for the environmental and socialassessment and management process, and specifies that the project (orbusiness activities, as appropriate) will comply with the applicablelaws and regulations of the jurisdictions in which it is beingundertaken, including those laws implementing host countryobligations under international law. The policy should be consistentwith the principles of the Performance Standards. Under somecircumstances, clients may also subscribe to other internationallyrecognized standards, certification schemes, or codes of practice andthese too should be included in the policy. The policy will indicatewho, within the client’s organization, will ensure conformance with thepolicy and be responsible for its execution (with reference to anappropriate responsible government agency or third party, asnecessary). The client will communicate the policy to all levels of itsorganization.PS 1, paragraph 6Compliance Status/ FindingsPARTIALLY COMPLIANTAccording to EIA, the project did evaluate environmental and socialimpacts of the project, and mitigation measures were defined for all impactsidentified. The Environmental Basic Plan -PBA and PBA reports presenteddetailed these programs and demonstrate the implementation of theconstruction programs until the end of 2011. Programs associated with theoperation will start, reportedly, on November 2012. According toinformation given on site visit the management of the programs is held bytwo third-party companies currently in charge of the site operation, Metaand DuPont. Reportedly, ELDORADO will take over the management ofthe PBA’s implementation and the site management when the operationallicense is issued. Guidance for third party companies is provided by adocument called Health and Safety and Environment of contracted andsubcontracted companies Book.ELDORADO does not conduct due diligence to monitor third partycompanies in charge of the site management.For third companies in charge of the site infrastructure project, a report isdeveloped in monthly basis by DuPont and Meta and presented toELDORADO and the companies. Report includes indicators associated withpeople management, health and safety, environmental, quality andschedule.ELDORADO has not implemented formal environmental managementsystem, but there are some aspects of management developed anddeveloping, as eg mission, vision, values (implemented and available oncompany’s website); A sustainability policy has been developed.Prevention and control measures adopted in the project implementation,that are further detailed in the assessment of EHS guidelines, are consideredin line with good international practice for pulp and paper mills.COMPLIANTAccording to information available on the company’s website and on theForest Management Plan, a sustainability policy, mission, vision and valueshave been developed and disclosed publicly.Recommended further actionsELDORADO should implement a system to monitor third party companies incharge of the site management.ELDORADO should integrate the existing practices in a management system,that shall include:(i) Training program for employees and contractors with direct responsibilityfor activities relevant to social and environmental performance of the project;None.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsIdentification of Risks and Impacts7. The client will establish and maintain a process for identifying theenvironmental and social risks and impacts of the project (seeparagraph 18 for competency requirements). The type, scale, andlocation of the project guide the scope and level of effort devoted to therisks and impacts identification process. The scope of the risks andimpacts identification process will be consistent with goodinternational industry practice, and will determine the appropriate andrelevant methods and assessment tools. The process may comprise afull-scale environmental and social impact assessment, a limited orfocused environmental and social assessment, or straightforwardapplication of environmental siting, pollution standards, designcriteria, or construction standards. When the project involves existingassets, environmental and/or social audits or risk/hazard assessmentscan be appropriate and sufficient to identify risks and impacts. If assetsto be developed, acquired or financed have yet to be defined, theestablishment of an environmental and social due diligence processwill identify risks and impacts at a point in the future when thephysical elements, assets, and facilities are reasonably understood. Therisks and impacts identification process will be based on recentenvironmental and social baseline data at an appropriate level of detail.The process will consider all relevant environmental and social risksand impacts of the project, including the issues identified inPerformance Standards 2 through 8, and those who are likely to beaffected by such risks and impacts. The risks and impacts identificationprocess will consider the emissions of greenhouse gases, the relevantrisks associated with a changing climate and the adaptationopportunities, and potential transboundary effects, such as pollution ofair, or use or pollution of international waterways.8. Where the project involves specifically identified physical elements,aspects, and facilities that are likely to generate impacts, environmentaland social risks and impacts will be identified in the context of theproject’s area of influence. This area of influence encompasses, asappropriate: The area likely to be affected by: (i) the project and the client’sactivities and facilities that are directly owned, operated ormanaged (including by contractors) and that are a component of theproject; (ii) impacts from unplanned but predictable developmentscaused by the project that may occur later or at a different location;or (iii) indirect project impacts on biodiversity or on ecosystemservices upon which Affected Communities’ livelihoods aredependent. Associated facilities, which are facilities that are not funded as partof the project and that would not have been constructed orexpanded if the project did not exist and without which the projectwould not be viable.Cumulative impacts that result from the incremental impact, on areasor resources used or directly impacted by the project, from otherexisting, planned or reasonably defined developments at the time therisks and impacts identification process is conducted.9. In the event of risks and impacts in the project’s area of influenceresulting from a third party’s actions, the client will address those risksand impacts in a manner commensurate with the client’s control andinfluence over the third parties, and with due regard to conflict ofinterest.PS 1, paragraph 7PS 1, paragraphs 8, 9Compliance Status/ FindingsCOMPLIANTThe Environmental Impact Assessment (EIA) Study for the project wasdeveloped on 2009 by DMB Construtora e Assessoria Técnica Ltda. andconsiders the impacts related to the planning, implementation andoperation of the project.The EIA did not evaluate the impacts for the decommissioning phase of theplant, nor has presented a justification for not performing this assessment.However, ERM understands that this is not a non compliance situation, asthe project has a long lifecycle.The study has been approved by the environmental agency and thepreliminary license LP has been issued.PARTIALLY COMPLIANTThe EIA has defined the projects areas: direct influence area, indirectinfluence area and directly affected area. However, these areas do notencompass impacts from unplanned but predictable developments causedby the project that may occur later or at a different location; or indirectproject impacts on biodiversity or on ecosystem services upon whichAffected Communities’ livelihoods are dependent.The EIA does not include the study of associated facilities neither assesscumulative impacts from other existing, planned or reasonably defineddevelopments.The risks and impacts identification process did not consider the emissionsof greenhouse gases.Please see paragraph PS1, paragraph 5.Recommended further actionsNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsIdentification of Risks and Impacts10. Where the client can reasonably exercise control, the risks andimpacts identification process will also consider those risks andimpacts associated with primary supply chains, as defined inPerformance Standard 2 (paragraphs 27–29) and PerformanceStandard 6 (paragraph 30).PS 1, paragraph 10Compliance Status/ FindingsCOMPLIANTThere are several contractors in charge of the industrial infrastructureproject. ELDORADO has developed a management structure to supervisethese third part companies and their workers.A company hired by ELDORADO, named Meta, is in charge to manage allaspects associated with contractor’s workers. DuPont is in charge tomanage all health and safety aspects associated with the project.Meta verifies the documentation of all workers that have access to the siteto identify compliance with Brazilian legislation.An Align Meeting is held every 60 days with all the companies involved inthe project installation. Demands are raised and a work plan is developed.ELDORADO does not conduct due diligence to monitor third partycompanies in charge of the site management.The feedstock for the pulp production will be obtained by eucalyptusplanted at ELDORADO´s farms (owned lands, leased and partnershipagreements). Wood will be supplied by third parties until 2016.Refer to PS2 and PS6 for further information about supply chainmanagement.Recommended further actionsNone.11. Where the project involves specifically identified physical elements,aspects and facilities that are likely to generate environmental andsocial impacts, the identification of risks and impacts will take intoaccount the findings and conclusions of related and applicableplans, studies, or assessments prepared by relevant governmentauthorities or other parties that are directly related to the project andits area of influence. These include master economic developmentplans, country or regional plans, feasibility studies, alternativesanalyses, and cumulative, regional, sectoral, or strategicenvironmental assessments where relevant. The risks and impactsidentification will take account of the outcome of the engagementprocess with Affected Communities as appropriate.12. Where the project involves specifically identified physical elements,aspects and facilities that are likely to generate impacts, and as partof the process of identifying risks and impacts, the client willidentify individuals and groups that may be directly anddifferentially or disproportionately affected by the project because oftheir disadvantaged or vulnerable status. Where individuals orgroups are identified as disadvantaged or vulnerable, the client willpropose and implement differentiated measures so that adverseimpacts do not fall disproportionately on them and they are notdisadvantaged in sharing development benefits and opportunities.PS 1, paragraph 11 Refer to PS1, paragraph 8 and 9. NonePS 1, paragraph 12PARTIALLY COMPLIANTThere is a detailed socio economic evaluation and community profile, butit does not identify potential vulnerable groups that may be differentiallyor disproportionately affected by the project because of theirdisadvantaged or vulnerable status.According to IFC disadvantage or vulnerable status may stem from anindividual’s or group’s race, color, sex, language, religion, political orother opinion, national or social origin, property, birth, or other status. Itshall also consider factors such as gender, age, ethnicity, culture, literacy,sickness, physical or mental disability, poverty or economic disadvantage,and dependence on unique natural resources.Identify any potential group that may be differentially or disproportionatelyaffected by the expansion project and implement differentiated measures sothat adverse impacts do not fall disproportionately on them and they are notdisadvantaged in sharing development benefits and opportunities. If no groupis identified as vulnerable or differentially affected, this should bedocumented (a brief statement to this fact is sufficient with supporting data).There may be individuals or groups within the project’s area of influencewho are particularly vulnerable or disadvantaged and who couldexperience adverse impacts from the proposed project more severely thanothers. Large-scale projects with a large area of influence and multipleAffected Communities are more likely to expose these individuals andgroups to adverse impacts than smaller-scale projects with site-specificissues.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsManagement Programs13. Consistent with the client’s policy and the objectives and principlesdescribed therein, the client will establish management programsthat, in sum, will describe mitigation and performanceimprovement measures and actions that address the identifiedenvironmental and social risks and impacts of the project.Identification of Risks and ImpactsManagement Programs14. Depending on the nature and scale of the project, these programsmay consist of some documented combination of operationalprocedures, practices, plans, and related supporting documents(including legal agreements) that are managed in a systematic way.The programs may apply broadly across the client’s organization,including contractors and primary suppliers over which theorganization has control or influence, or to specific sites, facilities,or activities. The mitigation hierarchy to address identified risksand impacts will favor the avoidance of impacts over minimization,and, where residual impacts remain, compensation/offset,wherever technically and financially feasible15. Where the identified risks and impacts cannot be avoided, the clientwill identify mitigation and performance measures and establishcorresponding actions to ensure the project will operate incompliance with applicable laws and regulations, and meet therequirements of Performance Standards 1 through 8. The level ofdetail and complexity of this collective management program andthe priority of the identified measures and actions will becommensurate with the project’s risks and impacts, and will takeaccount of the outcome of the engagement process with AffectedCommunities as appropriate.16. The management programs will establish environmental and socialAction Plans, which will define desired outcomes and actions toaddress the issues raised in the risks and impacts identificationprocess, as measurable events to the extent possible, with elementssuch as performance indicators, targets, or acceptance criteria thatcan be tracked over defined time periods, and with estimates of theresources and responsibilities for implementation. As appropriate,the management program will recognize and incorporate the role ofrelevant actions and events controlled by third parties to addressidentified risks and impacts. Recognizing the dynamic nature of theproject, the management program will be responsive to changes incircumstances, unforeseen events, and the results of monitoring andreview.PS 1, paragraphs 13 to 16Compliance Status/ FindingsCOMPLIANTEnvironmental and social management and monitoring procedures aswell as mitigation measures have been proposed in the EIA report inresponse to the identified relevant impacts. The PBA and PBA reportspresented detail these programs and demonstrate their implementationuntil the end of 2011.Recommended further actionsAn implementation schedule or timeline showing status of programs andactivities to be done could illustrate the progress.In addition to the PBA, ELDORADO shall define other measures to addressthe recommendations described in this document.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsOrganizational Capacity and Competency17. The client, in collaboration with appropriate and relevant thirdparties, will establish, maintain, and strengthen as necessary anorganizational structure that defines roles, responsibilities, andauthority to implement the ESMS. Specific personnel, includingmanagement representative(s), with clear lines of responsibility andauthority should be designated. Key environmental and socialresponsibilities should be well defined and communicated to therelevant personnel and to the rest of the client’s organization.Sufficient management sponsorship and human and financialresources will be provided on an ongoing basis to achieve effectiveand continuous environmental and social performance.18. Personnel within the client’s organization with direct responsibilityfor the project’s environmental and social performance will have theknowledge, skills, and experience necessary to perform their work,including current knowledge of the host country’s regulatoryrequirements and the applicable requirements of PerformanceStandards 1 through 8. Personnel will also possess the knowledge,skills, and experience to implement the specific measures and actionsrequired under the ESMS and the methods required to perform theactions in a competent and efficient manner.19. The process of identification of risks and impacts will consist of anadequate, accurate, and objective evaluation and presentation,prepared by competent professionals. For projects posing potentiallysignificant adverse impacts or where technically complex issues areinvolved, clients may be required to involve external experts to assistin the risks and impacts identification process.Emergency Preparedness and Response20. Where the project involves specifically identified physical elements,aspects and facilities that are likely to generate impacts, the ESMSwill establish and maintain an emergency preparedness and responsesystem so that the client, in collaboration with appropriate andrelevant third parties, will be prepared to respond to accidental andemergency situations associated with the project in a mannerappropriate to prevent and mitigate any harm to people and/or theenvironment. This preparation will include the identification of areaswhere accidents and emergency situations may occur, communitiesand individuals that may be impacted, response procedures,provision of equipment and resources, designation of responsibilities,communication, including that with potentially AffectedCommunities and periodic training to ensure effective response. Theemergency preparedness and response activities will be periodicallyreviewed and revised, as necessary, to reflect changing conditions.PS 1, paragraphs 17, 18and 19PS 1, paragraph 20, 21PS4, paragraph 11Compliance Status/ FindingsPARTIALLY COMPLIANTReportedly, specific personnel have been assigned for roles andresponsibilities within the environmental and social aspects of the project.Currently, as reported on paragraph 5,the third part companies DuPontand Meta are in charge of the implementation of the PBA. ELDORADOwill take over the management programs once the operation license isissued.Guidance for third party companies is provided by a document calledHealth and Safety and Environment of contracted and subcontractedcompanies Book. Documents on site were provided in order to evidencemanagement control of third party companies in regards to environmentaland social performance. A training matrix was developed to identify legaltraining for each work category. Those legal required training does notcover the aspects treated by this performance standard, specially the socialaspects.Most of the staff interviewed people reported previous experience onsimilar paper, pulp and forest companies.External experts have been hired in order to perform the EnvironmentalImpact Assessment Study. Refer to PS 1, paragraph 7.PARTIALLY COMPLIANTCONSTRUCTION STAGE AND OPERATION STAGEThe contractor DuPont, which was hired to manage health and safety issuesduring the construction stage, developed an Emergency Response Plan forthe construction works. Several accident scenarios have been considered,such as chemicals release, fire and accidents involving employees, amongothers. Emergency procedures were detailed for chemicals releases(hazardous products spills) and fire/explosion related to the leakage ofLiquefied Petroleum Gas.As reported by DuPont, the Emergency Response Plan will be completedand adapted for the operation stage.The risk analysis developed for the pulp mill has not indicated accidentscenarios with the potential to affect external communitiesELDORADO informed to have identified local governmental structure toact in emergency situations. PBA includes plans to support public securityand public health infrastructures.Recommended further actionsTo develop training program to support the designated personnel to carry outtheir part of the ESMS. The training program shall ensure consistence withELDORADO policies and procedures. The training can be formal, informal(on-the-job), one-time, periodic, etc. The program must include third partieswith direct responsibility with activities relevant to the environmental andsocial performance of the project, for example, wood suppliers, rural workerssupplier, etc.Emergency Plan should be communicated to affected community andrelevant governmental authorities with responsibility on emergencysituations, e.g, local police, hospitals, fire department, etc.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsEmergency Preparedness and Response21. Where applicable, the client will also assist and collaborate with thepotentially Affected Communities (see Performance Standard 4) andthe local government agencies in their preparations to respondeffectively to emergency situations, especially when theirparticipation and collaboration are necessary to ensure effectiveresponse. If local government agencies have little or no capacity torespond effectively, the client will play an active role in preparing forand responding to emergencies associated with the project. The clientwill document its emergency preparedness and response activities,resources, and responsibilities, and will provide appropriateinformation to potentially Affected Community and relevantgovernment agencies.Monitoring and Review22. The client will establish procedures to monitor and measure theeffectiveness of the management program, as well as compliance withany related legal and/or contractual obligations and regulatoryrequirements. Where the government or other third party hasresponsibility for managing specific risks and impacts and associatedmitigation measures, the client will collaborate in establishing andmonitoring such mitigation measures. Where appropriate, clients willconsider involving representatives from Affected Communities toparticipate in monitoring activities. The client’s monitoring programshould be overseen by the appropriate level in the organization. Forprojects with significant impacts, the client will retain externalexperts to verify its monitoring information. The extent of monitoringshould be commensurate with the project’s environmental and socialrisks and impacts and with compliance requirements.23. In addition to recording information to track performance andestablishing relevant operational controls, the client should usedynamic mechanisms, such as internal inspections and audits, whererelevant, to verify compliance and progress toward the desiredoutcomes. Monitoring will normally include recording information totrack performance and comparing this against the previouslyestablished benchmarks or requirements in the managementprogram. Monitoring should be adjusted according to performanceexperience and actions requested by relevant regulatory authorities.The client will document monitoring results and identify and reflectthe necessary corrective and preventive actions in the amendedmanagement program and plans. The client, in collaboration withappropriate and relevant third parties, will implement thesecorrective and preventive actions, and follow up on these actions inupcoming monitoring cycles to ensure their effectiveness.24. Senior management in the client organization will receive periodicperformance reviews of the effectiveness of the ESMS, based onsystematic data collection and analysis. The scope and frequency ofsuch reporting will depend upon the nature and scope of theactivities identified and undertaken in accordance with the client’sESMS and other applicable project requirements. Based on resultswithin these performance reviews, senior management will take thenecessary and appropriate steps to ensure the intent of the client’spolicy is met, that procedures, practices, and plans are beingimplemented, and are seen to be effective.PS 1, paragraphs 22 and23PS 1, paragraph 24Compliance Status/ FindingsPARTIALLY COMPLIANTThe PBA describes the activities, monitoring activities and the purpose of it,that the site intends to implement in order to mitigate or manageenvironmental impacts. PBA reports evidence that these monitoringactivities have been initiated. See PS 1, paragraphs 13 to 16.Neither the PBA nor related reports measure the effectiveness of theprograms implemented.COMPLIANTThe Sustainability Manager responds direct to ELDORADO’s CEO and hasdirect and frequent access to him. Information about license process andstakeholder relations is disclosed at the directors meetings.Once a week and once a month there are meetings about the projectinstallation and a report is disclosed to the directors of the company.Every 60 days an Align Meeting is held with all the companies involved inthe project installation. Demands are raised and a work plan is developed.Recommended further actionsDevelop measures to monitor measures to mitigate/control socio-economicimpacts.Develop measures to evaluate effectiveness of the implemented programs.Define measure to identify and monitor impacts on community health andsafety (refer to PS4 for further recommendation).Identify any potential group that may be differentially or disproportionatelyaffected by the project and implement differentiated measures so thatadverse impacts do not fall disproportionately on them and they are notdisadvantaged in sharing development benefits and opportunities. If nogroup is identified as vulnerable or differentially affected document (a briefstatement to this fact is sufficient) and justify so.NoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsStakeholder Engagement25. Stakeholder engagement is the basis for building strong, constructive,and responsive relationships that are essential for the successfulmanagement of a project's environmental and social impacts.Stakeholder engagement is an ongoing process that may involve, invarying degrees, the following elements: stakeholder analysis andplanning, disclosure and dissemination of information, consultationand participation, grievance mechanism, and ongoing reporting toAffected Communities. The nature, frequency, and level of effort ofstakeholder engagement may vary considerably and will becommensurate with the project’s risks and adverse impacts, and theproject’s phase of development.PS 1, paragraph 25Compliance Status/ FindingsPARTIALLY COMPLIANTELDORADO has following practices on stakeholder engagement: Stakeholders mapping and identification, mostly through the socialeconomic diagnosis; Consultation to local governmentalrepresentatives to identify projects that can be supported byELDORADO; Consultation of a sample of citizens to identify vulnerability of theregion as part of the social economic diagnosis; Consultation ofcommunity members to identify areas of high conservation valour andtheir dependence toward it.as part of the inventory of areas of highconservation; Identification of land neighbors as part of the PTEAS; A public hearing will be carried out for the purpose of forestcertification. The Forest Management Plan will be public disclosure;and A community relationship plan is being developed.None of the above mentioned initiatives were undertaken to 2 Irmãos doBuruti and Anastacio municipalities.ELDORADO does not have a systematic approach to consult or to engagestakeholders neither, for which this item is rated partial..Recommended further actionsTo systematize the stakeholders identification and contact information, toenable evaluation of stakeholder and classification according the following: Stakeholders affected by ELDORADO, positively and negatively, directlyand indirectly, particularly those directly and adversely affected by projectactivities, including those that are disadvantaged or vulnerable; Stakeholders who may be able to influence the outcome of the projectbecause of their knowledge about the affected communities or politicalinfluence over them; Legitimate stakeholders representatives, including elected officials, nonelectedcommunity leaders, leader of informal or traditional communityinstitutions, and elders within the affected community; Stakeholders not directly affected by the project but may have the ability toinfluence or alter the relationship of the client with the affectedcommunity.If the impact and risk identification process define that the community will beaffected by ELDORADO, Stakeholder Engagement Plan is required. Thisshould include: engagement principles, objective and criteria, risks and impacts, identification, characterization and priority of stakeholders, focusing onthose directly affected by the project and vulnerable groups, how interaction should be formalized, consultation frequency, grievance mechanism (refer to PS1, paragraph 35) list of time-bound activities, resources and responsibilities, communication channels, including those to disclosure information aboutrisk and impact.The engagement process shall also support the update of risks and impacts ofthe operation to affected community.Information about risks and impacts identified, mitigation measures shall beperiodically disclosure to affected community, at least annually, as long thespecific items in the management programs. ELDORADO may consider usingsustainability report on the financial, environmental and social aspects toreport so.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsStakeholder Analysis and Engagement Planning26. Clients should identify the range of stakeholders that may beinterested in their actions and consider how external communicationsmight facilitate a dialog with all stakeholders (paragraph 34 below).Where projects involve specifically identified physical elements,aspects and/or facilities that are likely to generate adverseenvironmental and social impacts to Affected Communities the clientwill identify the Affected Communities and will meet the relevantrequirements described below.PS 1, paragraph 26 and 27Compliance Status/ FindingsPARTIALLY COMPLIANTRefer to PS1 paragraph 25.Recommended further actionsRefer to PS1 paragraph 25.27. The client will develop and implement a Stakeholder EngagementPlan that is scaled to the project risks and impacts and developmentstage, and be tailored to the characteristics and interests of theAffected Communities. Where applicable, the StakeholderEngagement Plan will include differentiated measures to allow theeffective participation of those identified as disadvantaged orvulnerable. When the stakeholder engagement process dependssubstantially on community representatives, the client will makeevery reasonable effort to verify that such persons do in factrepresent the views of Affected Communities and that they can berelied upon to faithfully communicate the results of consultations totheir constituents.28. In cases where the exact location of the project is not known, but it isreasonably expected to have significant impacts on localcommunities, the client will prepare a Stakeholder EngagementFramework, as part of its management program, outlining generalprinciples and a strategy to identify Affected Communities and otherrelevant stakeholders and plan for an engagement processcompatible with this Performance Standard that will be implementedonce the physical location of the project is known.Disclosure of Information29. Disclosure of relevant project information helps AffectedCommunities and other stakeholders understand the risks, impactsand opportunities of the project. The client will provide AffectedCommunities with access to relevant information on: (i) the purpose,nature, and scale of the project; (ii) the duration of proposed projectactivities; (iii) any risks to and potential impacts on suchcommunities and relevant mitigation measures; (iv) the envisagedstakeholder engagement process; and (v) the grievance mechanism.PS 1, paragraph 28NOT APPLICABLEThe project location is known.NonePS 1, paragraph 29PARTIALLY COMPLIANTPublic hearing was held to disclosure information about the EIA and thePBA as part of the licensing process. Public meetings were held before it toidentify community concerns about the project.ELDORADO has the followings communication channel: Internal newspaper to workers Disclosure of information at local radios and journal.There is no systematic to update the information disclosure to the affectedcommunities.For information about the grievance mechanism, refer to PS1, paragraph35.Refer to PS1 paragraph 25.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsConsultation30. When Affected Communities are subject to identified risks andadverse impacts from a project, the client will undertake a process ofconsultation in a manner that provides the Affected Communitieswith opportunities to express their views on project risks, impactsand mitigation measures, and allows the client to consider andrespond to them. The extent and degree of engagement required bythe consultation process should be commensurate with the project’srisks and adverse impacts and with the concerns raised by theAffected Communities. Effective consultation is a two-way processthat should: (i) begin early in the process of identification ofenvironmental and social risks and impacts and continue on anongoing basis as risks and impacts arise; (ii) be based on the priordisclosure and dissemination of relevant, transparent, objective,meaningful and easily accessible information which is in a culturallyappropriate local language(s) and format and is understandable toAffected Communities; (iii) focus inclusive engagement on thosedirectly affected as opposed to those not directly affected; (iv) be freeof external manipulation, interference, coercion, or intimidation; (v)enable meaningful participation, where applicable; and (vi) bedocumented. The client will tailor its consultation process to thelanguage preferences of the Affected Communities, their decisionmakingprocess, and the needs of disadvantaged or vulnerablegroups. If clients have already engaged in such a process, they willprovide adequate documented evidence of such engagement.Informed Consultation and Participation31. For projects with potentially significant adverse impacts on AffectedCommunities, the client will conduct an Informed Consultation andParticipation (ICP) process that will build upon the steps outlinedabove in Consultation and will result in the Affected Communities’informed participation. ICP involves a more in-depth exchange ofviews and information, and an organized and iterative consultation,leading to the client’s incorporating into their decision-makingprocess the views of the Affected Communities on matters that affectthem directly, such as the proposed mitigation measures, the sharingof development benefits and opportunities, and implementationissues. The consultation process should (i) capture both men’s andwomen’s views, if necessary through separate forums orengagements, and (ii) reflect men’s and women’s different concernsand priorities about impacts, mitigation mechanisms, and benefits,where appropriate. The client will document the process, inparticular the measures taken to avoid or minimize risks to andadverse impacts on the Affected Communities, and will inform thoseaffected about how their concerns have been considered.PS 1, paragraph 30PS 1, paragraph 31Compliance Status/ FindingsPARTIALLY COMPLIANTELDORADO has the following initiatives to consultation: For the purpose of social economic diagnosis, a sample of citizenswere interviewed to identify vulnerability of the region; For the Inventory of Areas of High Biodiversity, stakeholderswere consulted to identify the areas of high biodiversityimportant to the community and the use of it; As a result of the local vulnerabilities identified at the socialeconomic diagnosis, local governmental representatives wereconsulted by ELDORADO to identify projects that could besupported by ELDORADO; Public hearings and meetings with stakeholders were held forlicense purpose.The consultation process is not systemized and it was not definedfrequency of consultationPARTIALLY COMPLIANTFor the ELDORADO industrial project a public hearing was held forlicense purpose and, previously to the public hearing, public meetingsidentified stakeholders concerns. The public hearing disclosureinformation about the project, impacts identified through EIA andmitigation plans.ELDORADO communication procedure does not include systematicconsultation to stakeholders.For the purpose of this IFC assessment, one neighbor of theAccommodation I, located at Tres Lagoas, was interviewed. Theaccommodation has capacity to accommodate 1920 workers.The neighbor informed that he was not disturbed by the closeness to theaccommodation. He reported to know that ELDORADO is a paper andpulp project and to have good expectation about the project because of itseconomic impacts. He also reported that he had never been contacted,informed or consulted by ELDORADOThis consultation process is not systematically defined, as such this item israted partial.Recommended further actionsSystemize the stakeholder identification, consultation and engagementprocess, as described on Refer to PS1, paragraph 25.Refer to PS1, paragraph 26, 27.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsIndigenous Peoples32. For projects with adverse impacts to Indigenous Peoples, the client isrequired to engage them in a process of ICP and in certaincircumstances the client is required to obtain their Free, Prior, andInformed Consent (FPIC). The requirements related to IndigenousPeoples and the definition of the special circumstances requiringFPIC are described in Performance Standard 7.PS 1, paragraph 32Private Sector Responsibilities Under Government-Led Stakeholder Engagement33. Where stakeholder engagement is the responsibility of the hostgovernment, the client will collaborate with the responsiblegovernment agency, to the extent permitted by the agency, to achieveoutcomes that are consistent with the objectives of this PerformanceStandard. In addition, where government capacity is limited, theclient will play an active role during the stakeholder engagementplanning, implementation, and monitoring. If the process conductedby the government does not meet the relevant requirements of thisPerformance Standard, the client will conduct a complementaryprocess and, where appropriate, identify supplemental actions.External Communications and Grievance MechanismsExternal Communications34. Clients will implement and maintain a procedure for external PS 1, paragraph 34communications that includes methods to (i) receive and registerexternal communications from the public; (ii) screen and assess theissues raised and determine how to address them; (iii) provide, track,and document responses, if any; and (iv) adjust the managementprogram, as appropriate. In addition, clients are encouraged to makepublicly available periodic reports on their environmental and socialsustainability.Grievance Mechanism for Affected Communities35. Where there are Affected Communities, the client will establish a PS 1, paragraph 35grievance mechanism to receive and facilitate resolution of AffectedCommunities’ concerns and grievances about the client’senvironmental and social performance. The grievance mechanismshould be scaled to the risks and adverse impacts of the project andhave Affected Communities as its primary user. It should seek toresolve concerns promptly, using an understandable and transparentconsultative process that is culturally appropriate and readilyaccessible, and at no cost and without retribution to the party thatoriginated the issue or concern. The mechanism should not impedeaccess to judicial or administrative remedies. The client will informthe Affected Communities about the mechanism in the course of thestakeholder engagement process.Compliance Status/ FindingsCOMPLIANTArcheological survey has been conducted in December 2011, andidentified that there was no indigenous groups or traditional peopleaffected by ELDORADO’s operation at Três Lagoas.PS 1, paragraph 33 NOT APPLICABLE NonePARTIALLY COMPLIANTThe ELDORADO site’s has a channel to receive communication through e-mail or telephone number. ELDORADO did not inform the procedure totreat grievance received through this channel, neither how community isinformed about this mechanism.Refer to paragraph 35 for grievance mechanism.PARTIALLY COMPLIANTELDORADO has the followings communication channel: Internal newspaper to workers Disclosure of information at local radios and journal.Besides, forums and public hearings were held for the purpose of theindustry license process and disclosure information about the EIA andPBA and identified community concerns about the project.ELDORADO site’s has a channel to receive communication through e-mailor telephone number.There are mechanisms in place for grievance and to registercommunication received from stakeholders: There is a form to register external communication from thepublic. Community and neighbor might contact ELDORADO’soffice in each municipality, a telephone number, the supervisor ofthe farm or those responsible to perform rounds on the farms.The form registers the name of the person, stakeholders category,reason for contact, name of the person who receive the contactand action taken. Once complete, the form is delivered to oneperson in charge to receive it. The complaint is registered in aspreadsheet that contains the name of the person, data, whoreceived the complaint, a description of the complaint, actiontaken, feedback and data. There is an ombudsman for industrial workers grievance(employees and contractor’s worker).Recommended further actionsNoneRefer to PS1, paragraphs 25 above and 35, below.The grievance mechanism must be part of the Stakeholder Engagement Plan.Refer to PS1, paragraph 25.It is recommended to expand the disclosure on how community andstakeholders can complain to ELDORADO.ELDORADO should guarantee that the grievance mechanism for affectedcommunity contains the following:the grievance mechanism must be available to all stakeholders:workers (employee, contractors, suppliers), suppliers, affectedcommunity, and other significant categories identified byELDORADO;it shall be culturally appropriate, readily accessible to all workers,;it must be defined roles and responsibilities for receiving thegrievance and communication flow;It must also define the channel for provision of feedback and timeto do so;the mechanism should be able to receive and treat all grievances,including those related to security personnel abuses.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsGrievance Mechanism for Affected Communities35.Compliance Status/ Findings Grievances are received through: Directly to the ombudsman representative at the site; Though each company social assistance at the site; Written and posted in a box available at the site and theaccommodation; Telephone number E-mailGrievances are registered and are treated by the Ombudsman, who is theperson in charge of the contractors’ workers management. Grievance isanalyzed, investigated, and feedback is provided to the worker by thesocial assistant. In case of anonymous grievance, the respond is disclosureon a board available close to the cafeteria.Information about the ombudsman is disclosed in the Manual forInduction and banners at the site.Recommended further actionsOngoing Reporting to Affected Communities36. The client will provide periodic reports to the Affected Communitiesthat describe progress with implementation of the project ActionPlans on issues that involve ongoing risk to or impacts on AffectedCommunities and on issues that the consultation process or grievancemechanism have identified as a concern to those Communities. If themanagement program results in material changes in or additions tothe mitigation measures or actions described in the Action Plans onissues of concern to the Affected Communities, the updated relevantmitigation measures or actions will be communicated to them. Thefrequency of these reports will be proportionate to the concerns ofAffected Communities but not less than annually.PS 1, paragraph 36The Eldorado site’s has a channel to receive communication through e-mail or telephone number. ELDORADO did not provided informationabout the structure of the grievance mechanism to stakeholders.PARTIALLY COMPLIANTFor the ELDORADO industrial project a public hearing was held forlicense purpose. The hearing disclosure information about the project,impacts identified through EIA and mitigation plans.The EIA and PBAs are available for general public. PBA’s are disclosuretwice a year with ongoing information about the management programs.It is not clear if stakeholders are communicated about how to access thisinformation.To include on communication channels information about how to accessPBA and other relevant public available information.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 2 (Labor and Working Conditions)No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWorking Conditions and Management of Worker RelationshipHuman Resources Policies and Procedures7. The client will adopt and implement human resources policies andprocedures appropriate to its size and workforce that set out itsapproach to managing workers consistent with the requirements ofthis Performance Standard and national law.8. The client will provide workers with documented information that isclear and understandable, regarding their rights under national laborand employment law and any applicable collective agreements,including their rights related to hours of work, wages, overtime,compensation, and benefits upon beginning the working relationshipand when any material changes occur.Working Conditions and Terms of Employment9. Where the client is a party to a collective bargaining agreement with aworkers’ organization, such agreement will be respected. Where suchagreements do not exist, or do not address working conditions andterms of employment, the client will provide reasonable workingconditions and terms of employment.10. The client will identify migrant workers and ensure that they areengaged on substantially equivalent terms and conditions to nonmigrantworkers carrying out similar work.PS 2, paragraph 7PS 2, paragraph 8PS 2, paragraph 9Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leis doTrabalho" (CLT or LabourLaw Consolidation).Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leis doTrabalho" (CLT or LabourLaw Consolidation).PS 2, paragraph 10Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leis doTrabalho" (CLT or LabourLaw Consolidation).Compliance Status/ FindingsPARTIALLY COMPLIANTThere is no human resource police that set out its approach to managingworkers as required by this Performance Standard.There is current a Policy for Remuneration that states the salaries andbenefits by professional category. This Policy is not available to theemployees and general public.There is also Policy for Training developed to be applied for industrial andrural workers, however, the policy has not being validated by themanagers in charge of the forest activityELDORADO has a grievance mechanism although not defined in a formalprocedure.Contacts with third part has a clause that stats the commitment of notemploying child or forced labour.ELDORADO reported to be developing an ethical code.COMPLIANTWorkers documents were revised and were in compliance with theBrazilian legislation. Workers are provided with a contract and, during theInductions, it is provided information associated with legal rights:experience period; workers permit; working hours and working hoursregister; identification to access the site, legal absences, medical leave,salary and variable remuneration, payment conditions, vacations, unionand union feed and benefits (medical assistance, life insurance,alimentation, workers transportation).Workers receive a manual that includes information about the site, healthand safety, legal rights, buses, working hours, work contract, ombudsman,access to the site, etc.COMPLIANTThere is currently a Union Agreement in place, signed with the Union ofWorkers on Paper and Pulp Industry of Três Lagoas (SINDICELPA).Contractors’ workers are represented by the Union of ConstructionWorkers.COMPLIANTThere are around 5.700 migrant workers hired by contractors to performactivities associated with the ELDORADO project infrastructure.Term of conditions and employment are the same those provided to localworkers. Migrant workers are also represented by the local UnionAgreement.Recommended further actionsTo develop a Human Resource Policy, procedures or ethical codeappropriate to the ELDORADO, to be applied for workers, contractedworkers and supply chain workers. The policy, procedure or ethical codeshall cover all issues treated by this performance standard, as exemplifiedbellow: Working conditions: e.g physical environmental, health and safetyprecautions, treatment of workers, disciplinary practices, respect toworkers’s personal dignity (such as refraining from physicalpunishment or abusive language), terms of employment (wages,benefits, wage deduction, hours of work, breaks, rest days,overtime arrangement, overtime compensation, medical insurance,pension, and leave for illness, vacation, maternity and holiday. Collective bargain and freedom of association; Non discrimination and Equal Opportunity; Grievance mechanism; Child Labour; Forced Labour; Right to privacy about surveillance methods (being filmed andbody and personal belongs search) and personal data that will bekept and how will It be used.Workers must receive information about the policy, procedure or ethicalcode. It is recommended to publicly disclose it.NoneNoneNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWorking Conditions and Terms of Employment11. Where accommodation services are provided to workers covered bythe scope of this Performance Standard, the client will put in placeand implement policies on the quality and management of theaccommodation and provision of basic services. The accommodationservices will be provided in a manner consistent with the principlesof non-discrimination and equal opportunity. Workers’accommodation arrangements should not restrict workers’ freedomof movement or of association.PS 2, paragraph 11NR24: Sanitary andcomfort at the work placeDecree 3.298/99 -Regulates the Law7.853/89 on the NationalPolicy for the Integrationof Disabled PersonIN 90/11Federal Decree 58.826/66 -Promulgates the ILOConvention 110: Worker'srecruitmentLaw 9777/98 - Change onthe Law 2848/40 (CriminalCode) - Labour rights:Slave labourCompliance Status/ FindingsPARTIALLY COMPLIANTELDORADO is directly in charge for 3 accommodations for migrantworkers hired by contractors. A company, named Meta, was hired tomanage the accommodation: (1) Accomodation I, located at Três Lagoas,has capacity for 1920 workers; (2) Accomodation II, located at TrêsLagoa,\s has capacity for 1020 workers; (3) Accomodation Selvíria, locatedat Selviría, has capacity for 720 workers.Contractors are in charge of the recruitment and transport of workers andare recommended to comply with IN 90/11, that states the requirement totransport migrant workers. However, this is not monitored byELDORADO.ERM visited Accommodation and it was in compliance with NR24 andconsistent with the principles of non-discrimination and equalopportunity. Besides, ELDORADO informed that there is no restriction tofreedom of movement and workers can leave or enter the accommodationat any time, this was confirmed by one worker interviewed atAccommodation I.Workers are provided with a badge to access the accommodation. Bagsand suitcases are inspected by Security Personnel to prevent the entranceof alcoholic drinks, gums and drugs.During check in, workers are informed of the Procedure to use theAccommodation and about inspections.. A copy of the Procedure to usethe Accommodation is also available in each of the rooms.ELDORADO informed that Union has access to the accommodation andthat they request to be previous informed of the visit. Secondary datareview indicates that Union representatives had accessed theAccommodation II to register workers grievance associated with theaccommodations conditions.Recommended further actionsTo monitor recruitment and transport of migrant workers, to guaranteecompliance with the Brazilian legislation, described on column “Related PRRequirement, EHS Guidelines and Legal Standards”.To develop a mechanism to disqualify contractors that are not monitoringtheir accommodation or timely solving the findings identified by Meta.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWorking Conditions and Terms of EmploymentCompliance Status/ Findings11. There are other 2.553 contractors’ workers accommodated in 135 houses andhotels rented by the contractors. ELDORADO has also hired Meta to monitorthese accommodations compliance with NR 24. Contractor’saccommodation are visited once a month and a report is developed. In caseof no compliance, contractors has 1 month to solve the issues otherwise theaccommodation can be interdicted and a fine issued by ELDORADO to thecontractorERM did not visit any of contractors’ accommodations butreviewed a sample of the reports developed by Meta for a contractor namedParanasa. ELDORADO provided ERM with 18 reports from 7 Paranasa’saccommodation. 11 reports identified no compliance with NR24, 1recommended the interdiction of the accommodation and 1 report a fire atthe accommodation named Amarelinha, for which workers are beinginvestigated.The management conditions for ELDORADO and contractor’saccommodation is well structure and effective, however, as evidenced by thereports reviewed, findings of no compliance with NR24 are constantlyidentified and not timely solved.This imposes a risk of non compliance with the Ministry of Labour in case ofinspection and risk to workers community safety.Workers’ Organizations12. In countries where national law recognizes workers’ rights to form andto join workers’ organizations of their choosing without interferenceand to bargain collectively, the client will comply with national law.Where national law substantially restricts workers’ organizations, theclient will not restrict workers from developing alternativemechanisms to express their grievances and protect their rightsregarding working conditions and terms of employment. The clientshould not seek to influence or control these mechanisms13. In either case described in paragraph 13 of this Performance Standard,and where national law is silent, the client will not discourage workersfrom electing worker representatives, forming or joining workers’organizations of their choosing, or from bargaining collectively, andwill not discriminate or retaliate against workers who participate, orseek to participate, in such organizations and collective bargaining.The client will engage with such workers’ representatives andworkers’ organizations, and provide them with information needed formeaningful negotiation in a timely manner. Workers’ organizations areexpected to fairly represent the workers in the workforce.PS 2, paragraph 12Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).PS 2, paragraph 13Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).COMPLIANTELDORADO workers are represented by the Union of Workers on Paperand Pulp Industry of Três Lagoas (SINDICELPA). During the Inductionworkers are informed of the Union contacts and Union Agreement.Contractors workers are represented by the Union of Workers onConstruction.ELDORADO reported that union has access to the workers at the site andaccommodation and ELDORADO request to be previously informed of thevisit. Union representative must also be guided (scorted by an ELDORADOrepresentative during the visit.ELDORADO informed that main demand of the workers is associated withthe different salary and benefits paid by contractors.NON COMPLIANTThere have been 3 work stoppages of activities in the site by workers hiredby contractors: On January (1 day of stop), April (2 days of stop) and August2011 (8 days of stop). The work stoppages are considered unofficial becauseit lacked the organization aspects defined by Brazilian regulation (it’s isdifferent of strike, which is organized and follows the legal terms).On August, the demand was associated with salaries and commuting towork. Companies have increased salaries 2,5% and 8% and provided feedbenefits. The negotiation was between the union and contractors, monitoredby the Labour Regional Tribunal and supported by ELDORADO.ELDORADO reported that, 300 workers were dismissed after the workstoppage in August 2011.Recommended further actionsMonitor dismissal of contractor’s workers who were engaged on workstoppages /strikes to avoid discrimination and guarantee freedom ofdiscrimination and collective bargain.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsNon-Discrimination and Equal Opportunity14 The client will not make employment decisions on the basis ofpersonal characteristics unrelated to inherent job requirements. Theclient will base the employment relationship on the principle of equalopportunity and fair treatment, and will not discriminate with respectto any aspects of the employment relationship, such as recruitment andhiring, compensation (including wages and benefits), workingconditions and terms of employment, access to training, jobassignment, promotion, termination of employment or retirement, anddisciplinary practices. The client will take measures to prevent andaddress harassment, intimidation, and/or exploitation, especially inregard to women. The principles of non-discrimination apply tomigrant workers.15. In countries where national law provides for non-discrimination inemployment, the client will comply with national law. When nationallaws are silent on non-discrimination in employment, the client willmeet this Performance Standard. In circumstances where national lawis inconsistent with this Performance Standard, the client isencouraged to carry out its operations consistent with the intent ofparagraph 15 above without contravening applicable laws.16. Special measures of protection or assistance to remedy pastdiscrimination or selection for a particular job based on the inherentrequirements of the job will not be deemed as discrimination, providedthey are consistent with national law.Retrenchment17. Prior to implementing any collective dismissals, the client will carryout an analysis of alternatives to retrenchment. If the analysis does notidentify viable alternatives to retrenchment, a retrenchment plan willbe developed and implemented to reduce the adverse impacts ofretrenchment on workers. The retrenchment plan will be based on theprinciple of non-discrimination and will reflect the client’s consultationwith workers, their organizations, and, where appropriate, thegovernment, and comply with collective bargaining agreements if theyexist. The client will comply with all legal and contractualrequirements related to notification of public authorities, and provisionof information to, and consultation with workers and theirorganizations.PS 2, paragraph 14Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).PS 2, paragraph 15PS 2, paragraph 15Decree 3.298/99 -Regulates the Law7.853/89 on the NationalPolicy for the Integrationof Disabled Person.Law 8069/90 - Establishthe Child and TeenagerStatuteFederal Decree 5.598/05- Regulates theemployment ofapprentices and othermeasures.PS 1, paragraph 17Compliance Status/ FindingsPARTIALLY COMPLIANTContractors are provided with a Health and Safety and Environmental Bookthat contains a list of actions in which workers shall not be involved,including discrimination because of the origin, race, color, age, gender orphysical condition. However it lacks measures to provide guidance tocontractors on how to prevent such behaviors or how to address such cases ifthey occur.Currently, ELDORADO has not taken measures to prevent and addressdiscrimination in employment relationship, including harassment,intimidation and/or exploitation. However, ERM did not identified that anynon-discrimination practices are in place to govern employmentrelationships.NON COMPLIANTELDORADO has recently hired a doctor to identify among workers thosethat have disability and if the company is in compliance with the Law 7.853that states a quota of 5% of workers with disability for companies with morethan 1,0000 workers.ELDORADO has not developed a plan or measure to achieve the quotadefined by law at operation phase.ELDORADO reported that there is no apprentice at the site, which is a notcompliance with the Apprentice Law 5.598/05 apprentices, state a quota forapprentices. However, the company sponsors the Program My First Job, thataims to provide technical training to almost 200 students of the local highschools. 50% of those participants shall be contracted by ELDORADO, whichshould be enough to meet the Law 5598 quota.Although NON COMPLIANT with Federal Decree 5.598/05, the measureundertaken seems to be sufficient to guarantee compliance with thisrequirement in the future.NOT APPLICABLE ELDORADO did not report any cases that required reparation.NOT APPLICABLEELDORADO informed to be in contracting phase and there it is not planningcollective dismissal, therefore no retrenchment was developed.For migrant workers, ELDORADO provides their return to the city of origin.Recommended further actionsRefer to PS2, paragraph 7, that recommends aspects to be covered by theHuman Rights Policy.To take measures to prevent any harassment, including sexual harassmentor psychological mistreatment within the workplace, e.g:include a module about harassment for leaders, managers;monitorand treat cases of harassment identified through ombudsman.To include on all workers induction information about harassment.To define measures and orient contractors on prevention of discriminationin employment relationship.Identify total number of employees with disability and, if not sufficient tocomply with law 3298/99, to define measures to do so at operation phase.Define measures to comply with Apprentice Law.Prior to implementing any collective dismissals, the client will carry out ananalysis of alternatives to retrenchment. Retrenchment means theelimination of a number of work positions or the dismissal or layoff of anumber of worker by an employer, generally by reason of plant closing orfor cost savings.The retrenchment plan shall address costs and alternative solutions toretrenchment, e.g working time reduction programs, employee capacitybuilding programs, and other those proposed by employees and; otherstakeholders.If dismissal is unavoidable, the plan shall consider schedule of the dismissal,retrenchment methods and procedure, selection criteria, severancepayments, offers to alternative employment, job placement, etc.Selection criteria shall be objective, fair, transparent and based on nondiscrimination.Workers, government and relevant stakeholders shall be consulted to theplan development.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal Standards19. The client should ensure that all workers receive notice of dismissaland severance payments mandated by law and collective agreementsin a timely manner. All outstanding back pay and social securitybenefits and pension contributions and benefits will be paid (i) on orbefore termination of the working relationship to the workers, (ii)where appropriate, for the benefit of the workers, or (iii) payment willbe made in accordance with a timeline agreed through a collectiveagreement. Where payments are made for the benefit of workers,workers will be provided with evidence of such payments.Grievance Mechanism20. The client will provide a grievance mechanism for workers (and theirorganizations, where they exist) to raise workplace concerns. The clientwill inform the workers of the grievance mechanism at the time ofrecruitment and make it easily accessible to them. The mechanismshould involve an appropriate level of management and addressconcerns promptly, using an understandable and transparent processthat provides timely feedback to those concerned, without anyretribution. The mechanism should also allow for anonymouscomplaints to be raised and addressed. The mechanism should notimpede access to other judicial or administrative remedies that mightbe available under the law or through existing arbitration procedures,or substitute for grievance mechanisms provided through collectiveagreements.Protecting the Work ForceChild Labor21. The client will not employ children in any manner that is economicallyexploitative, or is likely to be hazardous or to interfere with the child’seducation, or to be harmful to the child’s health or physical, mental,spiritual, moral, or social development. The client will identify thepresence of all persons under the age of 18. Where national laws haveprovisions for the employment of minors, the client will follow thoselaws applicable to the client. Children under the age of 18 will not beemployed in hazardous work. All work of persons under the age of 18will be subject to an appropriate risk assessment and regularmonitoring of health, working conditions, and hours of work.PS 2, paragraph 19PS 2, paragraph 20NR 31: RegulatoryStandard for Securityand Health of workerson agriculture, cattlerising, forest explorationand others ruralactivitiesPS 2, paragraph 21Federal Decree 5.598/05- Regulates theemployment ofapprentices and othermeasures.Federal Decree 3.597/00Promulgate the 182 ILOConvention and 190 ILORecommendationconcerning the worstforms of child labourand immediate action toeliminate them,convened in Geneva,June 17 1999.Federal Decree 4.134/02Promulgate the 138 ILOConvention and 146 ILORecommendation onminimum age foradmission toemployment.Decree 6.481/2008 -Regulates Articles 3 andCompliance Status/ FindingsCOMPLIANTFor dismissal, ELDORADO identifies if the worker has any legal restrictionto be dismissal. Human resource personnel also evaluate with the managerthe reasons for the dismissal of the workers. ELDORADO is developing aPlan to Evaluate Workers Performance.For Workers Contractors, ELDORADO verifies on a monthly basesdocuments that probes that contractors have paid social security benefits andcontributions defined by Brazilian Law.COMPLIANTThere is an ombudsman for workers grievance (employees and those hiredby third part).Grievances are receives through:- Directly to the ombudsman representative at the site;- To the company social assistance at the site;- Written and posted in a box available at the site and theaccommodation;- Telephone number- E-mailGrievances are registered and are treated by the Ombudsman, who is theperson in charge of the contractors’ workers management. . Grievance isanalyzed, investigated, and feedback is provided to the worker by the socialassistant. In case of anonymous grievance, the respond is disclosure on aboard available close to the cafeteria.Information about the ombudsman is disclosure at the Manual for Inductionand banners at the site.COMPLIANTELDORADO informed that there is no worker under 18 years oldperforming any activity at the site. Copies of documents related tocontractor’s worker are verified by ELDORADO, for which they believe theyare not in risk of child labour.ELDORADO sponsors the Regional Program to Combat the SexualExploration of Children, leaded by the Public Ministry for Children and theTrês Lagoas’ Network for the Protection of Children.This program is part of the workers induction providing information aboutchildren’s right.Recommended further actionsNoneNoneNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal Standards4 of the ILO Convention182 concerning the worstforms of child labourand immediate action toeliminate them,convened in Geneva,June 17 1999.Standard (InstruçãoNormativa) SIT n° 66/06- States on workinspection to combatchild labour and protectteenager work.Forced LaborThe client will not employ forced labor, which consists of any work orservice not voluntarily performed that is exacted from an individualunder threat of force or penalty. This covers any kind of involuntary orcompulsory labor, such as indentured labor, bonded labor, or similarlabor-contracting arrangements. The client will not employ traffickedpersons.Occupational Health and Safety23. The client will provide a safe and healthy work environment, takinginto account inherent risks in its particular sector and specific classes ofhazards in the client’s work areas, including physical, chemical,biological, and radiological hazards, and specific threats to women.The client will take steps to prevent accidents, injury, and diseasearising from, associated with, or occurring in the course of work byminimizing, as far as reasonably practicable, the causes of hazards. In amanner consistent with good international industry practice, asreflected in various internationally recognized sources including theWorld Bank Group Environmental, Health and Safety Guidelines, theclient will address areas that include the (i) identification of potentialhazards to workers, particularly those that may be life-threatening; (ii)provision of preventive and protective measures, includingmodification, substitution, or elimination of hazardous conditions orsubstances; (iii) training of workers; (iv) documentation and reportingof occupational accidents, diseases, and incidents; and (v) emergencyprevention, preparedness, and response arrangements. For additionalinformation related to emergency preparedness and response refer toPerformance Standard 1.PS 2, paragraph 22Law 9777/98 - Changeon the Law 2848/40(Criminal Code) -Labour rights: SlavelabourPS2, Paragraph 23Brazilian RegulatoryNorm NR-6, PersonalProtective Equipment –PPE.IFC GeneralEnvironmental, Healthand Safety (EHS)GuidelinesIFC Environmental,Health and SafetyGuidelines – Pulp andPaper MillsCompliance Status/ FindingsCOMPLIANTELDORADO informed that the operation is not in risk of employment ofslave like conditions. ELDORADO hired Meta to verify the documentationof all contractor’s workers. All workers directly hired by ELDORADO areformal registered as long as workers hired by third parts. This wasevidenced by documents verification.ELDORADO informed that overtime is controlled. All workers are providedwith a badge that electronic compute the total hours worked at the site perday. The shift is 8 hours and workers can perform 2 hour of overtime. If theworker stays longer than 10 hours, he must register in the system thejustification and manager is requested to authorize.CONSTRUCTION STAGEPARTIALLY COMPLIANTERM sample checked the occupational health & safety documents andprograms that are legally required by the Brazilian regulations. For one ofthe contractors that is working in the Project construction (Serpal, a civilconstruction company), ERM checked, among others, the following mainprograms/documents. Training records Occupational Risk Prevention Plan (PPRA); Medical Surveillance Program (PCMSO); Workplace Environmental Conditions Program (PCMAT); Safety committee (election, minutes of meeting); Accidents communication and investigation reports; Personal Protective Equipment.ERM observed that the contractor has developed the requireddocuments/programs. However, a deficiency was observed regarding theRegulatory Norm NR-6, associated with PPE delivery records. The deliveryrecords do not fully match the list of PPEs that must be provided to eachemployee as function of the job performed, according to a PPE requirementlist included in their Occupational Risk Prevention Plan. Additionally, somePPE deliveries were not properly registered.Recommended further actionsNoneELDORADO must guarantee that all PPEs be delivered to the employees,the PPE delivery properly registered and that all PPEs be adequate to therisks identified and listed in the PPRA.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsOccupational Health and SafetyCompliance Status/ FindingsOPERATION STAGENOT POSSIBLE TO EVALUATEERM cannot evaluate compliance with the Occupational, Health and Safetyrequirements, given that the pulp mill is not yet operating.Recommended further actionsIn the Operation Stage, ELDORADO should comply with the BrazilianHealth & Safety requirements and IFC General Environmental, Health andSafety (EHS) Guidelines and the IFC Environmental, Health and SafetyGuidelines – Pulp and Paper Mills. This will include , but not limited to,implementing the following main programs: Occupational Risks Prevention Program as required by Brazilianstandard NR-09, for the industrial operations; Medical Surveillance and Occupational Health Program as required byBrazilian standard NR-07; Health and safety training program in accordance with Brazilianlegislation; Emergency response plan for the existing facility; Accident and incident records, investigations and reporting; Occupational diseases records, investigations and reporting;Workers Engaged by Third Parties24. With respect to contracted workers the client will take commerciallyreasonable efforts to ascertain that the third parties who engage theseworkers are reputable and legitimate enterprises and have anappropriate ESMS that will allow them to operate in a mannerconsistent with the requirements of this Performance Standard, exceptfor paragraphs 18–19, and 27–29.25. The client will establish policies and procedures for managing andmonitoring the performance of such third party employers in relationto the requirements of this Performance Standard. In addition, theclient will use commercially reasonable efforts to incorporate theserequirements in contractual agreements with such third partyemployers.26. The client will ensure that contracted workers, covered in paragraphs24–25 of this Performance Standard, have access to a grievancemechanism. In cases where the third party is not able to provide agrievance mechanism the client will extend its own grievancemechanism to serve workers engaged by the third party.Supply Chain27. Where there is a high risk of child labor or forced labor in the primarysupply chain, the client will identify those risks consistent withparagraphs 21 and 22 above. If child labor or forced labor cases areidentified, the client will take appropriate steps to remedy them. Theclient will monitor its primary supply chain on an ongoing basis inorder to identify any significant changes in its supply chain and if newrisks or incidents of child and/or forced labor are identified, the clientwill take appropriate steps to remedy them.28. Additionally, where there is a high risk of significant safety issuesrelated to supply chain workers, the client will introduce proceduresand mitigation measures to ensure that primary suppliers within thesupply chain are taking steps to prevent or to correct life-threateningsituations.PS 2, paragraph 24PS 2, paragraph 25PS 2, paragraph 26PS 2, paragraph 27PARTIALLY COMPLIANTCurrently, ELDORADO has 186 employees and around 6.000 workers hiredby third parts.ELDORADO provides induction to employees and workers hired by thirdpart performing activities at the site.Contractors are provided with Health and Safety and Environmental Book,which contains the legal EHS requirements and describes a code of conductto contractors’ workers.Refer to the whole PS2 paragraphs to detailed information aboutmanagement of subcontractors.In summary, ELDORADO is partially compliant on the following items: PS2, Working conditions and terms of employment, paragraph 11: noncompliances with contractors’ accommodation are constantly identified; PS2, Workers organization, paragraph 13: contractors’ workers weredismissed after a work stoppage; PS2, Non discrimination and freedom of association, paragraph 14: thereare no measures in place to prevent discriminationCOMPLIANTSee grievance Mechanism Paragraph 20.PARTIALLY COMPLIANTSuppliers contracts have a clause that states that both parts are responsible toavoid child employment or forced labour.PS 2, paragraph 28 Refer to PS2, paragraph 27 NoneRefer to PS1 paragraph 11, 13 and 14.NoneTo identify categories of significant suppliers in the primary supply chain inhigh risk of child labour and forced labor.To define measures to monitor significant suppliers on employment of childlabour and forced labour. The measures shall be defined according to thesuppliers risk. High risk suppliers shall be audited.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsSupply Chain29. The ability of the client to fully address these risks will depend uponthe client’s level of management control or influence over its primarysuppliers. Where remedy is not possible, the client will shift theproject’s primary supply chain over time to suppliers that candemonstrate that they are complying with this Performance Standard.Compliance Status/ FindingsPS 2, paragraph 29 Refer to PS2, paragraph 27 NoneRecommended further actionsReview against IFC Performance Standard 3 (Resource Efficiency and Pollution Prevention)Nº: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal Standards4. During the project life-cycle, the client will consider ambientconditions and apply technically and financially feasible resourceefficiency and pollution prevention principles and techniques that arebest suited to avoid, or where avoidance is not possible, minimizeadverse impacts on human health and the environment. The principlesand techniques applied during the project life-cycle will be tailored tothe hazards and risks associated with the nature of the project andconsistent with good international industry practice (GIIP), as reflectedin various internationally recognized sources, including the WorldBank Group Environmental, Health and Safety Guidelines (EHSGuidelines).5. The client will refer to the EHS Guidelines or other internationallyrecognized sources, as appropriate, when evaluating and selectingresource efficiency and pollution prevention and control techniques forthe project. The EHS Guidelines contain the performance levels andmeasures that are normally acceptable and applicable to projects.When host country regulations differ from the levels and measurespresented in the EHS Guidelines, clients will be required to achievewhichever is more stringent. If less stringent levels or measures thanthose provided in the EHS Guidelines are appropriate in view ofspecific project circumstances, the client will provide full and detailedjustification for any proposed alternatives through the environmentaland social risks and impacts identification and assessment process.This justification must demonstrate that the choice for any alternateperformance levels is consistent with the objectives of this PerformanceStandard.PS 3 Paragraph 4Federal CONAMAResolution 01/86State Law 2257/2001PS 3 Paragraph 5Compliance Status/ FindingsPARTIALLY COMPLIANTThe ELDORADO pulp mill is still under implementation. According to None Requiredreviewed documents and information provided to ERM during the site visit,ELDORADO project implementation followed the legally required steps inBrazil for a pulp mill project. This included, among others, the developmentof an Environmental Impact Assessment (EIA) that took into considerationlocal environmental conditions, such as water availability and quality and airbackground air quality.The EIA considered the main impacts associated with a project of suchmagnitude and adequate mitigation measures from the environmentalstandpoint, for the implementation and for the operation stages. AlthoughELDORADO has not anticipated the impacts of the plant decommissioning,ERM understands that pulp mills are not designed to be decommissioned onshort-term basis. As per ERM experience, Pulp mills are constantly inmodernization process, which could extend indefinitely.Prevention and control measures adopted in the project implementation, thatare further detailed in the assessment of EHS guidelines, are considered inline with good international practice for pulp and paper mills.COMPLIANTAs reported by ELDORADO and according to reviewed documents and None required.information provided to ERM during the site visit, the ELDORADO Projectis in line with the best available technologies for pulp and papermanufacturingThrough documents review and information provided by the site contactsduring the visit, ERM could identify examples of pollutants minimization,such as dry debarking systems (effluents), continuous digestion, closedcircuit pulp washing and screening (lower effluent flow and load), use ofoxygen delignification prior to the bleaching stages (lower chemical use andeffluent loads), elimination of elemental chlorine in bleaching (ECF),evaporation system with multiple stages and indirect contact (air emissions),use of high-efficiency electrostatic precipitators for the recovery boiler,power boiler and lime kiln, among others.Although no formal written energy conservation program was identified byERM in documents review, the process technology incorporates the latestdevelopments in pulp and paper industry associated with energy efficiency.The ELDORADO pulp mill will not only be self-sufficient in energy but willalso connect to the National Electricity System to sell the excess energyproduced.Recommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Nº: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsResource Efficiency6. The client will implement technically and financially feasible and costeffective measures for improving efficiency in its consumption ofenergy, water, as well as other resources and material inputs, with afocus on areas that are considered core business activities. Suchmeasures will integrate the principles of cleaner production intoproduct design and production processes with the objective ofconserving raw materials, energy, and water. Where benchmarkingdata are available, the client will make a comparison to establish therelative level of efficiency.Compliance Status/ FindingsCOMPLIANTAs previously mentioned, production activities will incorporate the bestavailable technology for pulp production. Further discussions are presentedin the specific sections of this table.Recommended further actionsNone requiredGreenhouse Gases7. In addition to the resource efficiency measures described above, theclient will consider alternatives and implement technically andfinancially feasible and cost-effective options to reduce project-relatedGHG emissions during the design and operation of the project. Theseoptions may include, but are not limited to, alternative projectlocations, adoption of renewable or low carbon energy sources,sustainable agricultural, forestry and livestock management practices,the reduction of fugitive emissions and the reduction of gas flaring.PS 3, Paragraphs 7 and 8 NON COMPLIANTThe ELDORADO Pulp mill of Três Lagoas/MS does not have anestimate of carbon dioxide emission equivalents for the Project.Production has not yet started.Some measures adopted in the project are aligned with the reduction ofgreenhouse gas emissions, such as the use of renewable energy sourcesassociated with biomass burning, co-generation of heat and power andchemicals recovery, among others.The site should develop an estimate of greenhouse gas (GHG) emissions atthe project stage, according to internationally recognized methodology, suchas the Guidelines of the Intergovernmental Panel on Climate Change (IPCC)or equivalent.The GHG emissions estimate should be annually reviewed.8. For projects that are expected to or currently produce more than 25,000tonnes of CO2-equivalent annually, the client will quantify directemissions from the facilities owned or controlled within the physicalproject boundary, as well as indirect emissions associated with the offsiteproduction of energy used by the project. Quantification of GHGemissions will be conducted by the client annually in accordance withinternationally recognized methodologies and good practice.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Nº: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWater Consumption9. When the project is a potentially significant consumer of water, inaddition to applying the resource efficiency requirements of thisPerformance Standard, the client shall adopt measures that avoid orreduce water usage so that the project’s water consumption does nothave significant adverse impacts on others. These measures include,but are not limited to, the use of additional technically feasible waterconservation measures within the client’s operations, the use ofalternative water supplies, water consumption offsets to reduce totaldemand for water resources to within the available supply, andevaluation of alternative project locations.PS 3, Paragraph 9IFC GeneralEnvironmental, Healthand Safety (EHS)GuidelinesIFC Environmental,Health and SafetyGuidelines – Pulp andPaper MillsFederal MS Ordinance518/2004, altered andrevoked by MSOrdinance 2914/2011(issued on December 12,2011), which establishesdrinking waterstandards in Brazil.Technical requirementof Operating Permit116/2011, issued by theState EnvironmentalAgency Imasul on April12, 2011, valid for fouryears, for the temporarywater and wastewatertreatment systems.Compliance Status/ FindingsCOMPLIANTAs previously stated, the ELDORADO project incorporates the best availabletechnologies for pulp mills.The impact of the pulp mill operations in the neighborhood regarding wateravailability is regarded as low, considering that water will be abstractedfrom Paraná River. The EIA developed for ELDORADO pulp mill took intoaccount water availability as one factor for location alternatives. A flowmeasurement period of 22 years was considered for Paraná River. Withinthis period, the average flow was 7,299 m³/s, with a maximum flow of 28,222³/s and minimum of 1,597 m³/s. The characteristic flow (Q 95 ) was 2,070 m³/s(occurring 95% of the time).The project incorporates strategies to reduce water consumption, such as drywood debarking, closed circuit pulp washing and screening, counter-currentpulp washing in the bleaching lines, among others.The design water intake for industrial purposes, used for the dimensioningof the water treatment plant to be installed in ELDORADO pulp mill is 7,500m³/h (2.08 m³/s, what represents 0.1% of Paraná river Q95 flow.Considering the daily production capacity of 4,240 Adt, the specific waterconsumption for the design flow will result in approximately 42.4 m³/Adt.However, Eldorado expects to work with a water consumption ofapproximately 5,400 m³/h, resulting in a specific consumption of 30.5m³/ADt.For the operation stage, ELDORADO holds the water abstractionauthorization issued by the National Water Agency – ANA (AgênciaNacional de Águas), authorizing a water intake of 7,500 m³/h.For the construction stage, ELDORADO installed a temporary watertreatment system with 120 m³/h capacity. The water treatment plant is aconventional physical-chemical treatment consisting of coagulation,flocculation, clarification (clarifier with lamellae settlers) and filtration.ELDORADO holds the Environmental Operating Permit # 116/2011, issuedby the State Environmental Agency – IMASUL on April 13, 2011, valid forfour years, authorizing the operation of the temporary water treatmentsystem. It also holds the water abstraction permit from ANA, authorizing awater intake of 120 m³/h from Paraná River.According to technical requirement of the Environmental Operating Permit116/2011, the site should prepare and submit to the State EnvironmentalAgency monitoring reports every six months, considering the drinking waterstandards established by MS Ordinance 518/2004. ELDORADO hassubmitted monitoring reports to the Environmental Agency as required,which showed compliance with the applicable drinking water standards forthe analyzed parameters. As per documents review, ELDORADO hasdeveloped a drinking water quality monitoring plan, as required, and hassubmitted monitoring reports to the competent authorities, with analysis ofthe main drinking water standards (microbiological, free residual chlorine,turbidity, pH among others). Additionally, ELDORADO has conducted ananalysis for the complete set of parameters established in Ordinance518/2004, which includes inorganic parameters, organic parameters(including pesticides) and organoleptic parameters. No deviations wereobservedRecommended further actionsNone requiredENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsPollution Prevention10. The client will avoid the release of pollutants or, when avoidance is notfeasible, minimize and/or control the intensity and mass flow of theirrelease. This applies to the release of pollutants to air, water, and landdue to routine, non-routine, and accidental circumstances with thepotential for local, regional, and transboundary impacts. Wherehistorical pollution such as land or ground water contamination exists,the client will seek to determine whether it is responsible formitigation measures. If it is determined that the client is legallyresponsible, then these liabilities will be resolved in accordance withnational law, or where this is silent, with GIIP.PS 3, Paragraphs 10 and11IFC GeneralEnvironmental, Healthand Safety (EHS)GuidelinesIFC Environmental,Health and SafetyGuidelines – Pulp andPaper MillsCONAMA Resolution03/1990, whichestablishes the waterquality standards(primary and secondarystandards)CONAMA resolution382/2006, whichestablishes the airemission standards forthe type of industriesspecified in its annexes,including pulp andpaper mills.Compliance Status/ FindingsAmbient Air QualityPARTIALLY COMPLIANTERM reviewed two air quality monitoring reports developed by the hiredconsulting company Storm & Smoke – Consultoria Ambiental e Prestadorade Serviços. Three monitoring points were determined: 24-hour monitoring at Fazenda Santa Vera (where the mill will belocated); 24-hour monitoring at Assentamento Pontal do Faia (locatedapproximately 6.0 km East from ELDORADO Pulp Mill site) 24-hour monitoring at one point in the city of Três Lagoas (distantapproximately 22 km southeast of ELDORADO site, straight line).One report refers to monitoring campaigns conducted in March and July,2011. Monitored parameters included particulates (inhalable particles andtotal suspended particles), NO2, ozone, carbon monoxide and SO x . The areais considered homogeneous in what refers to air quality.The results indicated that the monitored parameters meet the air qualitystandards established in Brazilian regulations and the WHO Ambient AirQuality Guidelines, except for Particulate Matter PM 10 , in July, 2011, whichexceeded the guideline value of 50 µg/m³ (24-hour average concentration of52.92µg/m³).The second report refers to a monitoring campaign conducted in September2011. The results show that all the parameters comply with the Brazilianregulations and WHO Ambient Air Quality Guidelines, except for PM 10 ,which exceeded the Interim target 3 value of 75µg/m³ (24-hour averageconcentration of 87.95µG/m³).The PM 10 concentrations are apparently related to seasonal variations. Themonitoring campaign conducted in March (rainy season) showed muchlower result (24-hour average of 8.3 µg/m³) than the campaigns conducted inJuly and September (dry season).Brazilian regulations do not establish air quality standards for ParticulateMatter PM 2.5 . As such, this parameter has not been monitored in the airquality monitoring campaigns conducted by ELDORADO. However, thisparameter is addressed in the IFC EHS guidelines.Recommended further actionsThe air quality monitoring campaigns conducted to date have not includedthe monitoring of Particulate Matter PM 2.5 . Regardless of Brazilianregulations not establishing a quality standard for PM 2.5 , ELDORADOshould include this parameter in the next monitoring campaigns, to assurecompliance with international standards and IFC Guidelines.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsPollution PreventionCompliance Status/ Findings10. An air quality monitoring station will be installed in a location to be definedin Três Lagoas, for the monitoring of Particulates, TRS, NOx, SOx and CO.The monitoring station will reportedly be operational by the time of the plantcommissioning.Atmospheric emissions dispersion modeling in the EIA took into account theconstruction of a 120-m high stack. The dispersion model was reviewed inAugust 2011. A new dispersion study has been developed considering theactual stack height of 145 m and the late inclusion of a sodium chlorate plantwithin the industrial complex.The air dispersion model was developed taking into account the installationof a 145-m high structure that will support the exhaust ducts of the recoveryboiler, power boiler and lime kiln and different meteorological conditions,for the average annual concentrations and 24-hour concentrations (primaryand secondary air quality standards), and considering the use of differentfuels.The mathematical modeling analyzed the concentrations of inhalableparticles, NO 2 , SO 2 , CO, TRS and Cl 2 . According to the dispersion model, thehighest additional pollutant concentrations will be, respectively, 0.39 µg/m³,1.73 µg/m³, 0.98 µg/m³, 0.85 µg/m³, 0.01 µg/m³, 0.22 µg/m³. The conclusionis that, based on the modeling for each evaluated pollutant, no additionalimpact on the regional air quality will be caused by the pulp mill operation.ELDORADO will also establish an Odor Perception Network. The OPN willbe formed by volunteers from the neighboring communities trained tocontact the company in case any characteristic odor is perceived. Thevolunteers will be trained (qualified) through workshops, visits to the plantto be able to distinguish any odor that could be attributed to the industrialprocess. The network is to be trained until mid-2012, prior to ELDORADOcommissioning stage.11. To address potential adverse project impacts on existing ambientconditions, the client will consider relevant factors, including, forexample (i) existing ambient conditions; (ii) the finite assimilativecapacity of the environment; (iii) existing and future land use; (iv) theproject’s proximity to areas of importance to biodiversity; and (v) thepotential for cumulative impacts with uncertain and/or irreversibleconsequences. In addition to applying resource efficiency andpollution control measures as required in this Performance Standard,when the project has the potential to constitute a significant source ofemissions in an already degraded area, the client will consideradditional strategies and adopt measures that avoid or reduce negativeeffects. These strategies include, but are not limited to, evaluation ofproject location alternatives and emissions offsets.PS 3, Paragraphs 10 and11.IFC GeneralEnvironmental, Healthand Safety (EHS)GuidelinesIFC Environmental,Health and SafetyGuidelines – Pulp andPaper MillsCONAMA resolution382/2006, whichestablishes the airemission standards forthe type of industriesspecified in its annexes,including pulp andpaper mills.Atmospheric EmissionsCOMPLIANTRegarding the construction stage, ELDORADO has established a program toreduce fugitive emissions related to re-suspension of particulates resultingfrom vehicles traffic and wind action. This program includes wetting ofunpaved using tank trucks. During the site visit, due to the weatherconditions (occurrence of precipitation in the three days of visit), no wettingwas being conducted. However, no fugitive emissions were noted.As informed by the site contacts and according to reviewed documents,ELDORADO will install Continuous monitoring at the recovery boiler, limekiln and power boiler for gas flow, temperature, pressure, moisture, oxygen,total reduced sulfur (TRS), NO x , SO X , Carbon monoxide and particulates.ERM reviewed the process guarantees provided by the suppliers of the mainemission sources, namely the recovery boiler, the power boiler and the limekiln.Taking into account the process guarantees, ERM verified compliance withthe limits established by the Brazilian regulations and the more stringent IFCEnvironmental, Health and Safety Guidelines – Pulp and Paper Mills.The guaranteed air emissions of each source comply with the emissionstandards established by Brazilian regulations for pulp and paper mills.Recommended further actionsNone RequiredENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsPollution PreventionCompliance Status/ Findings11. Similarly, process guarantees result in the following specific emissions:Recommended further actionsPS 3, Paragraphs 10 and11CONAMA Resolution357/2005, whichestablishes the surfacewater quality standardsin Brazil.yePS3 Paragraphs 10 and11CONAMA Resolution430/2011, whichestablishes nationalwastewater dischargestandards. StateDeliberação CECA/MS03/1997, whichestablishes thewastewater dischargestandards in the State ofMato Grosso do Sul.ParameterSpecific emission(kg/ADt)IFC GuidelineStandard (kg/Adt)TRS 0.017 0.5SO 2 0.399 0.5NO 2 1.084 1.5Particulates 0.27 0.5SURFACE WATER QUALITYCOMPLIANTAs a basic Environmental Plan and to meet technical requirement of theEnvironmental Installation Permit, ELDORADO has developed a surfacewater monitoring program. Six monitoring points were defined in the areaof direct influence of the pulp mill:1. Santa Vera Creek (southern property boundary), downstream of thefuture pulp mill;2. Santa Vera Creek, upstream of the future pulp mill3. Bebedouro creek (northern property boundary), upstream of the futurepulp mill;4. Bebedouro creek, downstream of the future pulp mill;5. Paraná river, upstream of the effluent outfall;6. Paraná River, downstream of the effluent outfall.ERM reviewed the report related to the monitoring campaign conducted onSeptember 19 and 20, 2011. Water and sediments samples were collected andthe analytical results compared with the quality standards established byFederal CONAMA Resolution 357/2005. Total phosphorus was detected inall monitoring points (except point 01) above the water quality standard.Benthonic invertebrates were also monitored and one invasive species wasdetected (Melanoides tuberculata).The monitoring report recommends thecontinuation of invertebrates monitoring, because this indicator is influencedby human interferences in the environment.WASTEWATER MANAGEMENTPARTIALLY COMPLIANTAccording to the pulp mill project and information provided to ERM duringthe site visit, effluents will be treated in an on-site wastewater treatmentsystem and discharged into Paraná River via an effluent outfall, installedupstream of the pulp water intake point. comprising primary clarification forsolids-containing effluents, neutralization ofThe effluent treatment system will consist primary treatment (solidscontainingeffluent) and a biological treatment for effluents joint treatment(activated sludge).ERM reviewed the process guarantees provided by the effluent treatmentsystem supplier.Taking into account the process guarantees, ERM compared the effluentestimated quality with the IFC EHS guidelines and the applicablewastewater discharge standards.ERM evidenced compliance with the standards.Similarly, the process guarantees result in the following specific flow andloads:None requiredReportedly the surface water monitoring plan will continue as proposed tothe State Environmental Agency.ELDORADO to confirm whether they can meet the IFC standard forphosphorous.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsPollution PreventionCompliance Status/ Findings11. Parameter Specific value IFC GuidelineFlow (m³/ADt)28.950.0 Average36.8 DesignBOD (kg/ADt) 0.59 1.0TSS (kg/ADt) 1.11 1.5AOX (kg/ADt) 0.14 0.26Total Nitrogen (kg/ADt) 0.18 0.20Total Phosphorus (kg/Adt) 0.04 0.03Although the estimated total phosphorus content is roughly higher than theIFC specific standard, ERM understands that ELDORADO can adjust thetreatment process to lower the treated effluent phosphorus concentration. PS3 Paragraphs 10and 11Federal CONAMAResolution 01/1990,which establishes thatthe emission of noisefrom any industrialactivity should complywith the conditionsestablished in NBR10151/00Brazilian Standard NBR10151/00, whichdescribes procedures foridentifying theacceptability of noise ininhabited areas.ENVIRONMENTAL NOISECOMPLIANTFor the development of the EIA, a noise monitoring campaign wasconducted in November, 2009, so as to establish the background condition ofthe area where the industrial complex is inserted. No activities were beingcarried out at the time of monitoring. Meteorological data during the day ofthe monitoring campaign was obtained from the National MeteorologyInstitute (INMET) and the adopted parameters were from the automaticmeteorological station located in the municipality of Valparaíso, State of SãoPaulo, approximately 100 km distant from Três Lagoas. The noisemonitoring was conducted during the day at four points inside the property,being two next to BR-158 road and two closer to Paraná River, opposite tothe highway.The area where the site is located is a rural area as reference for evaluation,the noise levels were compared with the limits established by FederalCONAMA Resolution 01/1990, which establishes that noise levels foracoustic comfort defined in the Brazilian Standard NBR 10151. The noiselevels measured at monitoring points 1 and 2 (next to the highway) exceededthe limit for rural areas and daily period established in the mentionedstandard. This was attributed to the vehicles traffic at the highway, giventhat at points 3 and 4, the noise levels resulted significantly lower than theestablished limit.The established limit for rural areas during the day (from 7:00 am to 10:00pm) is 40 dB(A). The limit for night period is 35 dB (A).Recommended further actionsELDORADO will have to conduct additional noise monitoring campaignsprior to commissioning and during operations.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWastes12. The client will avoid the generation of hazardous and non-hazardouswaste materials. Where waste generation cannot be avoided, the clientwill reduce the generation of waste, and recover and reuse waste in amanner that is safe for human health and the environment. Wherewaste cannot be recovered or reused, the client will treat, destroy, ordispose of it in an environmentally sound manner that includes theappropriate control of emissions and residues resulting from thehandling and processing of the waste material. If the generated wasteis considered hazardous, the client will adopt GIIP alternatives for itsenvironmentally sound disposal while adhering to the limitationsapplicable to its transboundary movement. When hazardous wastedisposal is conducted by third parties, the client will use contractorsthat are reputable and legitimate enterprises licensed by the relevantgovernment regulatory agencies and obtain chain of custodydocumentation to the final destination. The client should ascertainwhether licensed disposal sites are being operated to acceptablestandards and where they are, the client will use these sites. Where thisis not the case, clients should reduce waste sent to such sites andconsider alternative disposal options, including the possibility ofdeveloping their own recovery or disposal facilities at the project site.PS3, Paragraph 12Brazilian Standard NBR10004, which classifiesthe wastes into threecategories: Class I(hazardous), Class IIA(non-hazardous, noninert)and Class IIB(inerts).CONAMA Resolution313/2002, whichestablishes the NationalWaste Inventory andrequires industrialactivities to develop awaste inventory to besubmitted to the StateEnvironmental Agency;Federal CONAMAResolution 362/2000,which establishesguidelines for collectionand disposal of spentlubricating oilsFederal CONAMAResolution 358/2005,which establishes criteriafor treatment anddisposal of clinicalwastesState Law 2080/2000,which establishesprocedures and criteriaregarding wastegeneration, packing,storage, collection,transport and disposal.Compliance Status/ FindingsOPERATION STAGECOMPLIANTThe consulting company Poyry Tecnologia developed a Solid WasteManagement Plan (PGRS – Plano de Gerenciamento de Resíduos Sólidos) forthe industrial complex, addressing the waste management during theELDORADO operation stage.The PRGS includes procedures and responsibilities related to themanagement of: Clinical wastes (hazardous);Industrial wastes, including dregs and grits from causticizing, sandfrom wood handling, eucalyptus bark (if not burned in the powerboiler), rejects from pulp washing and screening, ash from the powerboiler, screened material form the water and wastewater treatmentsystems and primary and secondary sludge;Non-industrial waste: generated at the process support areas, includehazardous wastes, such as spent lubricating oils, batteries, burntfluorescent tubes, expired chemicals, wastes contaminated with oils,grease and solvents and batteries, among others; non-hazardouswastes, including restaurant wastes, cooking oil and common wastes,among others; recyclable wastes, such as scrap pulp, scrap metal,plastics, empty non-contaminated containers, paper and cardboard,among others.ELDORADO project includes the installation of an industrial landfill toreceive non-hazardous wastes (Class IIA according to applicable Brazilianstandards) and inert wastes (Class II B). According to documents reviewed,the landfill will be constructed following the best practices, including cellslining, leak detection, protection against storm water runoff and leachatecollection and treatment. Additionally, the landfill will be installed for a twoyearoperation, while ELDORADO evaluates composting alternatives tominimize the amount of landfilled wastes.Recommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWastes12. PS3 Paragraph 12CONAMA Resolution307/2002, establishes thestandards to managecivil construction wastesand classifies the wastesaccording to its origin.CONAMA Resolution348/2004, modified theCONAMA Resolution307/2002, and includedasbestos in thehazardous wastescategory.PS 3 Paragraph 12Federal CONAMAResolution 420/2009,which establishes thecriteria and soil qualityoriented values andguidance for themanagement ofcontaminated areas.Compliance Status/ FindingsCONSTRUCTION STAGEPARTIALLY COMPLIANTAs for the construction stage, ELDORADO hired a third party company(Podium), which is responsible for the construction waste management.Podium is responsible to collect the hazardous and non-hazardous wastesgenerated by each contractor working in the construction site, centralize thetemporary storage and give proper destination.Each contractor, in its turn, temporarily store generated hazardous waste in atemporary storage area, until it is removed by Podium to the central wastemanagement facility.During the site visit, ERM sample checked the contractor’s installations andsome deficiencies were noted. At the installations of Serpal (power boilercivil construction contractor), the hazardous waste storage area is small(approximately 4.0 m²), apparently insufficient to accommodate the wastesgenerated (oily wastes, spent solvent, etc.) until the transfer to the centralwaste facility by Podium. As a result, reportedly because Podium had not yetremoved the wastes from the generation point, six drums were observedoutside the storage area, directly on unpaved soil, covered with a plasticsheet (no evidence of leakage was observed). Additionally, the wastes werenot adequately labeled.As for Podium installations, ERM observed that a waste temporary storagearea was under construction, reportedly according to applicable standards(covered and provided with secondary containment, and sealed floor). Ahazardous waste load was waiting for shipment packed within a truckdumpster, properly covered with tarpaulin, but placed on an unpaved area(no evidence of leak was observed).As informed and observed at Podium installations, concrete debris are notbeing disposed of as waste. Instead, they are currently being crushed to belater used in the forest areas to cover access and internal circulation roads..The final disposal given to the construction wastes, according to informationprovided by Podium and documents reviewed, has been adequate, except forasbestos-containing wastes. ERM observed a pile (approximately 50 m²) offiber-cement roof tiles on an unpaved area and evidenced that part of thetiles are asbestos-containing and part asbestos-free (with synthetic fibers). Itis not possible to visually determine the percentage of each type. Asbestoscontainingconstruction waste is classified under Brazilian regulations ashazardous waste and must be disposed of as such. Podium has notdeveloped a procedure for handling and disposal of asbestos-containingwastes, that are being disposed of as non-hazardous waste.As reported during the visit of the construction site and according to None requireddocuments reviewed, the future pulp mill will incorporate technical criteriaand construction features designed to prevent soil/groundwatercontamination. Among others, the following could be mentioned: All the lagoons part of the wastewater and storm water collection andtreatment will be lined with compacted soil and synthetic membranes(HDPE). The wood yard will be paved and contained, being the storm waterrunoff directed to a storm water lagoon (to be further treated ordischarged); All production areas will be concrete paved and diked; All chemicals storage tanks will be installed inside impermeablecontainment basins.Recommended further actionsELDORADO should inspect the contractors’s installations and make surethat hazardous wastes are being stored in covered, secondarily containedand paved areas.ELDORADO should require the following actions from Podium: Expedite the construction of the hazardous waste temporary storagearea; Develop a procedure for handling, storage and disposal of asbestoscontainingwastes that assure not only environmental compliance withapplicable regulations, but also health and safety regulations; Segregate asbestos-containing wastes and give them appropriate finaldisposal as hazardous waste; Develop a procedure for asbestos-containing wastes management,including handling, storage and disposal. The procedure should containthe guidance for asbestos-waste handling, the required PPE to beprovided to employees and employees training requirements; Appropriately train the employees responsible for asbestos-containingwastes handling.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsWastesCompliance Status/ Findings12. The industrial landfill will be lined and equipped with a leak detectionsystemA soil/groundwater monitoring plan was initiated after the earth workscompletion and monitoring wells (piezometers) were installed as part of theBasic Environmental Plan proposed in the Environmental ImpactAssessment and required by the State Environmental Agency - IMASUL. Thecomplete system will comprise the installation of thirty three piezometers(until August 2011, 21 wells had already been installed). Soil andgroundwater samples were collected and analyzed for VOC, SVOC(including pesticides), PAH, TPH, metals, sodium, potassium, calcium,chlorides, sulfates and carbonates.Ten soil samples were collected in August 2011, at 1.0-m depth and at thecapillary fringe zone. No parameters exceeding the established referencevalues (CONAMA Resolution 420/2009) were detected in the soil samplesanalyzed.Twenty one groundwater samples were collected in August 2011.Aluminum, iron and manganese were detected above the reference limits(CONAMA Resolution 420/2009) in samples collected from severalmonitoring wells (aluminum in 16, iron in 13 and manganese in 10 out of 21wells). The occurrence of these metals is attributed to background conditionsand geological characteristics of the soil at the area where the pulp mill willbe installed.Recommended further actionsHazardous Materials Management13. Hazardous materials are sometimes used as raw material or producedas product by the project. The client will avoid or, when avoidance isnot possible, minimize and control the release of hazardous materials.In this context, the production, transportation, handling, storage, anduse of hazardous materials for project activities should be assessed.The client will consider less hazardous substitutes where hazardousmaterials are intended to be used in manufacturing processes or otheroperations. The client will avoid the manufacture, trade, and use ofchemicals and hazardous materials subject to international bans orphase-outs due to their high toxicity to living organisms,environmental persistence, potential for bioaccumulation, or potentialfor depletion of the ozone layer.PS3 Paragraph 13COMPLIANTChapter 9 of the Environmental Impact Assessment (EIA) presents a RiskAssessment study developed for ELDORADO Cellulose Plant. The studyidentified accidental scenarios related to the release of flammable materials(methanol and diesel oil), proposed mitigating measures and establishedemergency response procedures. The study also mentions that a HAZOP(Hazards and Operability) study is being developed and will identifypotential process deviations and risks, and also recommendations tominimize the risks.A Quantitative Risk Assessment study was developed in July 2011 bycompany AGR Engenharia as part of the Preliminary Environmental Study.The study assessed the risks of the Pulp Mill Plant and the sodium chlorateplant (Ilha Química) recently included in the project. This study alsoevaluated the potential accidents that could result in the release of toxic andflammable materials. A HAZID (hazards identification) was developed andidentified 197 risks, of which 68 are related to toxic or flammable materialrelease. Main chemical releases identified are: methanol, hydrogen, chlorinedioxide, hydrochloric acid, diesel oil, hydrogen sulfide, natural gas andliquefied petroleum gas. The study also developed a consequence modelingof each of the 68 scenarios identified and verified that none of them have thepotential to affect communities. In order to prevent the accidental scenariosidentified and mitigate the risks, the study proposed severalrecommendations.The mitigating measures recommended in the Risk Assessment studyrelated to release of flammable materials must be accomplished during theoperating phase of the facility. In addition, after the HAZOP studyconclusion, all recommendations generated must be incorporated into theprocess design in order to minimize the risks.The recommendations proposed in the Quantitative Risk Assessment mustbe accomplished during the operating phase of the facility.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsPesticide Use and Management14. The client will, where appropriate, formulate and implement anintegrated pest management (IPM) and/or integrated vectormanagement (IVM) approach targeting economically significant pestinfestations and disease vectors of public health significance. Theclient’s IPM and IVM program will integrate coordinated use of pestand environmental information along with available pest controlmethods, including cultural practices, biological, genetic, and, as a lastresort, chemical means to prevent economically significant pestdamage and/or disease transmission to humans and animals.15. When pest management activities include the use of chemicalpesticides, the client will select chemical pesticides that are low inhuman toxicity, that are known to be effective against the targetspecies, and that have minimal effects on non-target species and theenvironment. When the client selects chemical pesticides, the selectionwill be based upon requirements that the pesticides be packaged insafe containers, be clearly labelled for safe and proper use, and that thepesticides have been manufactured by an entity currently licensed byrelevant regulatory agencies.16. The client will design its pesticide application regime to (i) avoiddamage to natural enemies of the target pest, and where avoidance isnot possible, minimize, and (ii) avoid the risks associated with thedevelopment of resistance in pests and vectors, and where avoidanceis not possible minimize. In addition, pesticides will be handled,stored, applied, and disposed of in accordance with the Food andAgriculture Organization’s International Code of Conduct on theDistribution and Use of Pesticides or other GIIP.Pesticide Use and Management17. The client will not purchase, store, use, manufacture, or trade inproducts that fall in WHO Recommended Classification of Pesticidesby Hazard Class Ia (extremely hazardous); or Ib (highly hazardous).The client will not purchase, store, use, manufacture or trade in Class II(moderately hazardous) pesticides, unless the project has appropriatecontrols on manufacture, procurement, or distribution and/or use ofthese chemicals. These chemicals should not be accessible to personnelwithout proper training, equipment, and facilities to handle, store,apply, and dispose of these products properly.PS 3 Paragraphs 14, 15,16 and 17Compliance Status/ FindingsNOT APPLICABLEAccording to information provided by the site contacts, no pesticides are orwill be used at industrial complex.During the site visit, ERM has not identified any pesticide storage area.Recommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 4 (Community Health, Safety, and Security)No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsCommunity Health and Safety5. The client will evaluate the risks and impacts to the health and safetyof the Affected Communities during the project life-cycle and willestablish preventive and control measures consistent with goodinternational industry practice (GIIP), such as in the World BankGroup Environmental, Health and Safety Guidelines (EHS Guidelines)or other internationally recognized sources. The client will identifyrisks and impacts and propose mitigation measures that arecommensurate with their nature and magnitude. These measures willfavor the avoidance of risks and impacts over minimization.PS4, paragraph 5EHS Guidelines Paperand Pulp item 1.3Compliance Status/ FindingsPARTIALLY COMPLIANTThe increase of transport flow on the inhabitant areas is assessed andcommunity is informed about it.There is a system to combat fire in place (fire brigade). Neighbors and localgovernment are informed on how to contact the fire brigade in case of fire.There are measures in place to manage waste and to avoid dissemination ofwater-borne diseases and endemic (as leishmaniasis and dengue).Recommended further actionsAwareness programs should be applied to employees, contractors, theirfamilies and affected communities.Include workers providing transportation services on educational programsrelated to STIs and prevention of fatalities and injuries.The assessment of public health as detailed on these performance standardsis not commonly requested on license process.ELDORADO is involving in the following programs/action: participating with the health surveillance system on a program tocombat leishmaniasis; provision of information about sexual transmitted illness (STIs) toworkers as part of the Program for Public Health and Safety; support the Tres Lagoas municipality to monitor Dengue and todefine measures to minimize the transition of the disease; To promote vaccination for influenza to all workers.As defined by law, ELDORADO promotes awareness programs to workersabout alcoholism, smoking, besides, monitoring workers occupational healththrough medical examinations.The social diagnosis assessment undertaken for the 7 municipalities were themain farms are located indicates as the main vulnerability the lack ofappropriate health public facilities. ELDORADO has met with publicauthorities to discuss local facility, areas that must be improved and projectsthat could be supported by ELDORADO. Minutes of these meetings werereviewed by ERM.As reported in the PBA reports, ELDORADO has met with public authoritiesto discuss local infrastructure, areas that must be improved and projects thatcould be supported by ELDORADO.There is a plan for transportation of hazardous material defined in the PBA.Refer to PS3, paragraph 10 and 11 for mitigation management programs.ReferENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsInfrastructure and Equipment Design and Safety6. The client will design, construct, operate, and decommission thestructural elements or components of the project in accordance withGIIP, taking into consideration safety risks to third parties or AffectedCommunities. When new buildings and structures will be accessed bymembers of the public, the client will consider incremental risks of thepublic’s potential exposure to operational accidents and/or naturalhazards and be consistent with the principles of universal access.Structural elements will be designed and constructed by competentprofessionals, and certified or approved by competent authorities orprofessionals. When structural elements or components, such as dams,tailings dams, or ash ponds are situated in high-risk locations, andtheir failure or malfunction may threaten the safety of communities,the client will engage one or more external experts with relevant andrecognized experience in similar projects, separate from thoseresponsible for the design and construction, to conduct a review asearly as possible in project development and throughout the stages ofproject design, construction, operation, and decommissioning. Forprojects that operate moving equipment on public roads and otherforms of infrastructure, the client will seek to avoid the occurrence ofincidents and injuries to members of the public associated with theoperation of such equipment.Hazardous Materials Management and Safety7. The client will avoid or minimize the potential for communityexposure to hazardous materials and substances that may be releasedby the project. Where there is a potential for the public (includingworkers and their families) to be exposed to hazards, particularly thosethat may be life-threatening, the client will exercise special care toavoid or minimize their exposure by modifying, substituting, oreliminating the condition or material causing the potential hazards.Where hazardous materials are part of existing project infrastructure orcomponents, the client will exercise special care when conductingdecommissioning activities in order to avoid exposure to thecommunity. The client will exercise commercially reasonable efforts tocontrol the safety of deliveries of hazardous materials, and oftransportation and disposal of hazardous wastes, and will implementmeasures to avoid or control community exposure to pesticides, inaccordance with the requirements of Performance Standard 3.Compliance Status/ FindingsCOMPLIANTSecurity techniques implemented on construction and predicted toinstallation are appropriate to this kind of projectsThe protection techniques adopted at the project, lining of treatment poundsand landfill, storm water contamination treatment, are designed andconstructed to avoid risk that could impact community health and safety.The site is designed to be accessible to disable people once constructionphase is over.COMPLIANTThe EIA, chapter 9, describe the risk assessment and canaries of communityexposure to risk of hazardous material during transportation (methanol,sulfuric acid, caustic soda). Mitigate measures were recommended.Refer to PS3 Paragraph 13.Recommended further actionsNoneRefer to PS3 Paragraph 13.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsEcosystem Services8. The project’s direct impacts on priority ecosystem services may resultin adverse health and safety risks and impacts to AffectedCommunities. With respect to this Performance Standard, ecosystemservices are limited to provisioning and regulating services as definedin paragraph 2 of Performance Standard 6. For example, land usechanges or the loss of natural buffer areas such as wetlands,mangroves, and upland forests that mitigate the effects of naturalhazards such as flooding, landslides, and fire, may result in increasedvulnerability and community safety-related risks and impacts. Thediminution or degradation of natural resources, such as adverseimpacts on the quality, quantity, and availability of freshwater, mayresult in health-related risks and impacts. Where appropriate andfeasible, the client will identify those risks and potential impacts onpriority ecosystem services that may be exacerbated by climate change.Adverse impacts should be avoided, and if these impacts areunavoidable, the client will implement mitigation measures inaccordance with paragraphs 24 and 25 of Performance Standard 6.With respect to the use of and loss of access to provisioning services,clients will implement mitigation measures in accordance withparagraphs 25–29 of Performance Standard 5.Community Exposure to Disease9. The client will avoid or minimize the potential for communityexposure to water-borne, water-based, water-related, and vector-bornediseases, and communicable diseases that could result from projectactivities, taking into consideration differentiated exposure to andhigher sensitivity of vulnerable groups. Where specific diseases areendemic in communities in the project area of influence, the client isencouraged to explore opportunities during the project life-cycle toimprove environmental conditions that could help minimize theirincidence.10. The client will avoid or minimize transmission of communicablediseases that may be associated with the influx of temporary orpermanent project labor.Emergency Preparedness and Response11. In addition to the emergency preparedness and response requirementsdescribed in Performance Standard 1, the client will also assist andcollaborate with the Affected Communities, local governmentagencies, and other relevant parties, in their preparations to respondeffectively to emergency situations, especially when their participationand collaboration are necessary to respond to such emergencysituations. If local government agencies have little or no capacity torespond effectively, the client will play an active role in preparing forand responding to emergencies associated with the project. The clientwill document its emergency preparedness and response activities,resources, and responsibilities, and will disclose appropriateinformation to Affected Communities, relevant government agencies,or other relevant parties.Compliance Status/ FindingsRefer to PS 6, paragraphs 6 and 7PS4, paragraph 9 Refer to PS4, paragraph 5.PS4, paragraph 10PS4, paragraph 11COMPLIANTCONSTRUCTION STAGE AND OPERATION STAGEThe contractor DuPont, which was hired to manage health and safety issuesduring the construction stage, developed an Emergency Response Plan forthe construction works, identifying hazard conditions, basic procedures foremergency situations, definition of responsibilities, material assetspreservation, training, resources and minimization of emergency impacts.Several accident scenarios have been considered, such as chemicals release,fire and accidents involving employees, among others. Emergencyprocedures were detailed for chemicals releases (hazardous products spills)and fire/explosion related to the leakage of Liquefied Petroleum Gas.As reported by DuPont, the Emergency Response Plan will be completedand adapted for the operation stage.Recommended further actionsNoneAlthough the risk analysis developed for the pulp mill has not identifiedaccident scenarios with the potential to affect external communities, theEmergency plan prepared for the operation stage should cover assistance tonearby communities and cooperation with local authorities, emergencyservices and other potentially affected stakeholders.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsSecurity Personnel12. When the client retains direct or contracted workers to providesecurity to safeguard its personnel and property, it will assess risksposed by its security arrangements to those within and outside theproject site. In making such arrangements, the client will be guided bythe principles of proportionality and good international practice inrelation to hiring, rules of conduct, training, equipping, andmonitoring of such workers, and by applicable law. The client willmake reasonable inquiries to ensure that those providing security arenot implicated in past abuses; will train them adequately in the use offorce (and where applicable, firearms), and appropriate conducttoward workers and Affected Communities; and require them to actwithin the applicable law. The client will not sanction any use of forceexcept when used for preventive and defensive purposes in proportionto the nature and extent of the threat. The client will provide agrievance mechanism for Affected Communities to express concernsabout the security arrangements and acts of security personnel.13. The client will assess and document risks arising from the project’s useof government security personnel deployed to provide securityservices. The client will seek to ensure that security personnel will actin a manner consistent with paragraph 12 above, and encourage therelevant public authorities to disclose the security arrangements for theclient’s facilities to the public, subject to overriding security concerns.14. The client will consider and, where appropriate, investigate allallegations of unlawful or abusive acts of security personnel, takeaction (or urge appropriate parties to take action) to preventrecurrence, and report unlawful and abusive acts to public authorities.PS4, paragraph 12PS4, paragraph 13PS4, paragraph 14Compliance Status/ FindingsPARTIALLY COMPLIANTMeta is in charge to manage the site support facilities, which include thesecurity personnel arrangements, provided by Security. Reportedly, Meta isin charge to verify the documents of those providing security.Security personnel arrangements is provided at the site and the 3accommodations managed by ELDORADO. Those providing security are incharge to supervise the access to the site and accommodation.ELDORADO does not provide training to security personnel, neither there isa systemic procedure to verify if those providing security are not involved inpast abuses.NOT APPLICABLEThe project will not use government security personnel to provide securityservices.PARTIALLY COMPLIANTThere is a grievance mechanism to workers that can receive complaint aboutsecurity personnel abuses. ELDORADO informed that all grievancesreceived are treated and investigated. If the abuse or inadequate behavior isproved, the person providing security might be removed to another positionor dismissed.ELDORADO has no procedure to investigate and treat cases of human rightabuses, if committed by those providing security personnel, neither tocommunicate public authority about it.Recommended further actionsEnsure the grievance procedure and Stakeholder Engagement Plan (PS1Paragh 25) are designed to identify any concerns from local government,communities and workers regarding security activities.Define procedures on the correct code of conduct and use of the force bysecurity personnel. This shall include measures to investigate and addressany complaints regarding potential human right abuses committed by thoseproviding security.To monitor those providing security arrangement to identify compliancewith the above mentioned procedures.Refer to PS4, paragraph 12.Review against IFC Performance Standard 5 (Land Acquisition and Involuntary Resettlement)No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsGeneralProject Design8. The client will consider feasible alternative project designs to avoid orminimize physical and/or economic displacement, while balancingenvironmental, social, and financial costs and benefits, payingparticular attention to impacts on the poor and vulnerable.Compliance Status/ FindingsCOMPLIANTELDORADO is installed in a 900 hectare area. This area was bought byELDORADO and was part of a cattle raising farm.ELDORADO informed that there were 3 houses in the farm in which 3workers families leaved in. According to ELDORADO, those families wereremoved to the part of the farm that still belongs to the farm’s previousowner.The EIA has no information about resettlement, physical or economical,which suggests that no resettlement was carried about to ELDORADOinstallation.Reportedly, there is no judicial land dispute.Recommended further actionsNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsCompensation and Benefits for Displaced Persons9. When displacement cannot be avoided, the client will offer displacedcommunities and person’s compensation for loss of assets at fullreplacement cost and other assistance to help them improve or restoretheir standards of living or livelihoods, as provided in thisPerformance Standard. Compensation standards will be transparentand applied consistently to all communities and persons affected bythe displacement. Where livelihoods of displaced persons are landbased,or where land is collectively owned, the client will, wherefeasible, offer the displaced land-based compensation. The client willtake possession of acquired land and related assets only aftercompensation has been made available and, where applicable,resettlement sites and moving allowances have been provided to thedisplaced persons in addition to compensation. The client will alsoprovide opportunities to displaced communities and persons to deriveappropriate development benefits from the project.Community Engagement10. The client will engage with Affected Communities, including hostcommunities, through the process of stakeholder engagementdescribed in Performance Standard 1. Decision-making processesrelated to resettlement and livelihood restoration should includeoptions and alternatives, where applicable. Disclosure of relevantinformation and participation of Affected Communities and personswill continue during the planning, implementation, monitoring, andevaluation of compensation payments, livelihood restoration activities,and resettlement to achieve outcomes that are consistent with theobjectives of this Performance Standard.16 Additional provisionsapply to consultations with Indigenous Peoples, in accordance withPerformance Standard 7.Grievance Mechanism11. The client will establish a grievance mechanism consistent withPerformance Standard 1 as early as possible in the project developmentphase. This will allow the client to receive and address specificconcerns about compensation and relocation raised by displacedpersons or members of host communities in a timely fashion, includinga recourse mechanism designed to resolve disputes in an impartialmanner.Resettlement and Livelihood Restoration Planning and Implementation12. Where involuntary resettlement is unavoidable, either as a result of anegotiated settlement or expropriation, a census will be carried out tocollect appropriate socio-economic baseline data to identify thepersons who will be displaced by the project, determine who will beeligible for compensation and assistance, and discourage ineligiblepersons, such as opportunistic settlers, from claiming benefits. In theabsence of host government procedures, the client will establish a cutoffdate for eligibility. Information regarding the cut-off date will bewell documented and disseminated throughout the project area.13. In cases where affected persons reject compensation offers that meetthe requirements of this Performance Standard and, as a result,expropriation or other legal procedures are initiated, the client willexplore opportunities to collaborate with the responsible governmentagency, and, if permitted by the agency, play an active role inresettlement planning, implementation, and monitoring (seeparagraphs 30–32).Compliance Status/ FindingsNOT APPLICABLEItems below are not applicable because no physical or economic resettlementwas carried out.NOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLERecommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal Standards14. The client will establish procedures to monitor and evaluate theimplementation of a Resettlement Action Plan or LivelihoodRestoration Plan (see paragraphs 19 and 25) and take corrective actionas necessary. The extent of monitoring activities will be commensuratewith the project’s risks and impacts. For projects with significantinvoluntary resettlement risks, the client will retain competentresettlement professionals to provide advice on compliance with thisPerformance Standard and to verify the client’s monitoringinformation. Affected persons will be consulted during the monitoringprocess.15. Implementation of a Resettlement Action Plan or LivelihoodRestoration Plan will be considered completed when the adverseimpacts of resettlement have been addressed in a manner that isconsistent with the relevant plan as well as the objectives of thisPerformance Standard. It may be necessary for the client tocommission an external completion audit of the Resettlement ActionPlan or Livelihood Restoration Plan to assess whether the provisionshave been met, depending on the scale and/or complexity of physicaland economic displacement associated with a project. The completionaudit should be undertaken once all mitigation measures have beensubstantially completed and once displaced persons are deemed tohave been provided adequate opportunity and assistance tosustainably restore their livelihoods. The completion audit will beundertaken by competent resettlement professionals once the agreedmonitoring period is concluded. The completion audit will include, ata minimum, a review of the totality of mitigation measuresimplemented by the Client, a comparison of implementation outcomesagainst agreed objectives, and a conclusion as to whether themonitoring process can be ended16. Where the exact nature or magnitude of the land acquisition orrestrictions on land use related to a project with potential to causephysical and/or economic displacement is unknown due to the stageof project development, the client will develop a Resettlement and/orLivelihood Restoration Framework outlining general principlescompatible with this Performance Standard. Once the individualproject components are defined and the necessary informationbecomes available, such a framework will be expanded into a specificResettlement Action Plan or Livelihood Restoration Plan andprocedures in accordance with paragraphs 19 and 25 below.Displacement17. Displaced persons may be classified as persons (i) who have formallegal rights to the land or assets they occupy or use; (ii) who do nothave formal legal rights to land or assets, but have a claim to land thatis recognized or recognizable under national law; or (iii) who have norecognizable legal right or claim to the land or assets they occupy oruse. The census will establish the status of the displaced persons.18. Project-related land acquisition and/or restrictions on land use mayresult in the physical displacement of people as well as their economicdisplacement. Consequently, requirements of this PerformanceStandard in respect of physical displacement and economicdisplacement may apply simultaneously.Compliance Status/ FindingsNOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLERecommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsPhysical Displacement19. In the case of physical displacement, the client will develop aResettlement Action Plan that covers, at a minimum, the applicablerequirements of this Performance Standard regardless of the number ofpeople affected. This will include compensation at full replacementcost for land and other assets lost. The Plan will be designed tomitigate the negative impacts of displacement; identify developmentopportunities; develop a resettlement budget and schedule; andestablish the entitlements of all categories of affected persons(including host communities). Particular attention will be paid to theneeds of the poor and the vulnerable. The client will document alltransactions to acquire land rights, as well as compensation measuresand relocation activities.20. If people living in the project area are required to move to anotherlocation, the client will (i) offer displaced persons choices amongfeasible resettlement options, including adequate replacement housingor cash compensation where appropriate; and (ii) provide relocationassistance suited to the needs of each group of displaced persons. Newresettlement sites built for displaced persons must offer improvedliving conditions. The displaced persons’ preferences with respect torelocating in pre-existing communities and groups will be taken intoconsideration. Existing social and cultural institutions of the displacedpersons and any host communities will be respected.21. In the case of physically displaced persons under paragraph 17 (i) or(ii), the client will offer the choice of replacement property of equal orhigher value, security of tenure, equivalent or better characteristics,and advantages of location or cash compensation where appropriate.Compensation in kind should be considered in lieu of cash. Cashcompensation levels should be sufficient to replace the lost land andother assets at full replacement cost in local markets.22. In the case of physically displaced persons under paragraph 17 (iii), theclient will offer them a choice of options for adequate housing withsecurity of tenure so that they can resettle legally without having toface the risk of forced eviction. Where these displaced persons ownand occupy structures, the client will compensate them for the loss ofassets other than land, such as dwellings and other improvements tothe land, at full replacement cost, provided that these persons havebeen occupying the project area prior to the cut-off date for eligibility.Based on consultation with such displaced persons, the client willprovide relocation assistance sufficient for them to restore theirstandard of living at an adequate alternative site.23. The client is not required to compensate or assist those who encroachon the project area after the cut-off date for eligibility, provided thecut-off date has been clearly established and made public.24. Forced evictions will not be carried out except in accordance with lawand the requirements of this Performance Standard.Compliance Status/ FindingsNOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLERecommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsEconomic Displacement25. In the case of projects involving economic displacement only, the clientwill develop a Livelihood Restoration Plan to compensate affectedpersons and/or communities and offer other assistance that meets theobjectives of this Performance Standard. The Livelihood RestorationPlan will establish the entitlements of affected persons and/orcommunities and will ensure that these are provided in a transparent,consistent, and equitable manner. The mitigation of economicdisplacement will be considered complete when affected persons orcommunities have received compensation and other assistanceaccording to the requirements of the Livelihood Restoration Plan andthis Performance Standard, and are deemed to have been providedwith adequate opportunity to re-establish their livelihoods.26. If land acquisition or restrictions on land use result in economicdisplacement defined as loss of assets and/or means of livelihood,regardless of whether or not the affected people are physicallydisplaced, the client will meet the requirements in paragraphs 27–29below, as applicable.27. Economically displaced persons who face loss of assets or access toassets will be compensated for such loss at full replacement cost. In cases where land acquisition or restrictions on land use affectcommercial structures, affected business owners will becompensated for the cost of re-establishing commercial activitieselsewhere, for lost net income during the period of transition, andfor the costs of the transfer and reinstallation of the plant,machinery, or other equipment. In cases affecting persons with legal rights or claims to land whichare recognized or recognizable under national law (see paragraph17 (i) and (ii)), replacement property (e.g., agricultural orcommercial sites) of equal or greater value will be provided, or,where appropriate, cash compensation at full replacement cost. Economically displaced persons who are without legallyrecognizable claims to land (see paragraph 17 (iii)) will becompensated for lost assets other than land (such as crops,irrigation infrastructure and other improvements made to theland), at full replacement cost. The client is not required tocompensate or assist opportunistic settlers who encroach on theproject area after the cut-off date for eligibility.28. In addition to compensation for lost assets, if any, as required underparagraph 27, economically displaced persons whose livelihoods orincome levels are adversely affected will also be providedopportunities to improve, or at least restore, their means of incomeearningcapacity, production levels, and standards of living: For persons whose livelihoods are land-based, replacement landthat has a combination of productive potential, locationaladvantages, and other factors at least equivalent to that being lostshould be offered as a matter of priority. For persons whose livelihoods are natural resource-based andwhere project-related restrictions on access envisaged in paragraph5 apply, implementation of measures will be made to either allowcontinued access to affected resources or provide access toalternative resources with equivalent livelihood-earning potentialand accessibility. Where appropriate, benefits and compensationassociated with natural resource usage may be collective in naturerather than directly oriented towards individuals or households.Compliance Status/ FindingsNOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLERecommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsEconomic Displacement28. If circumstances prevent the client from providing land or similarresources as described above, alternative income earningopportunities may be provided, such as credit facilities, training,cash, or employment opportunities. Cash compensation alone,however, is frequently insufficient to restore livelihoods.29. Transitional support should be provided as necessary to alleconomically displaced persons, based on a reasonable estimate of thetime required to restore their income-earning capacity, productionlevels, and standards of living.Private Sector Responsibilities Under Government-Managed Resettlement30. Where land acquisition and resettlement are the responsibility of thegovernment, the client will collaborate with the responsiblegovernment agency, to the extent permitted by the agency, to achieveoutcomes that are consistent with this Performance Standard. Inaddition, where government capacity is limited, the client will play anactive role during resettlement planning, implementation, andmonitoring, as described below.31. In the case of acquisition of land rights or access to land throughcompulsory means or negotiated settlements involving physicaldisplacement, the client will identify and describe governmentresettlement measures. If these measures do not meet the relevantrequirements of this Performance Standard, the client will prepare aSupplemental Resettlement Plan that, together with the documentsprepared by the responsible government agency, will address therelevant requirements of this Performance Standard (the GeneralRequirements and requirements for Physical Displacement andEconomic Displacement above). The client will need to include in itsSupplemental Resettlement Plan, at a minimum (i) identification ofaffected people and impacts; (ii) a description of regulated activities,including the entitlements of displaced persons provided underapplicable national laws and regulations; (iii) the supplementalmeasures to achieve the requirements of this Performance Standard asdescribed in paragraphs 19–29 in a way that is permitted by theresponsible agency and implementation time schedule; and (iv) thefinancial and implementation responsibilities of the client in theexecution of its Supplemental Resettlement Plan.32. In the case of projects involving economic displacement only, the clientwill identify and describe the measures that the responsiblegovernment agency plans to use to compensate Affected Communitiesand persons. If these measures do not meet the relevant requirementsof this Performance Standard, the client will develop an Environmentaland Social Action Plan to complement government action. This mayinclude additional compensation for lost assets, and additional effortsto restore lost livelihoods where applicable.Compliance Status/ FindingsNOT APPLICABLENOT APPLICABLENOT APPLICABLENOT APPLICABLERecommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources)No: Requirements of IFC PS 6 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsGeneral6. The risks and impacts identification process as set out in PerformanceStandard 1 should consider direct and indirect project-related impactson biodiversity and ecosystem services and identify any significantresidual impacts. This process will consider relevant threats tobiodiversity and ecosystem services, especially focusing on habitatloss, degradation and fragmentation, invasive alien species,overexploitation, hydrological changes, nutrient loading, andpollution. It will also take into account the differing values attached tobiodiversity and ecosystem services by Affected Communities and,where appropriate, other stakeholders. Where paragraphs 13–19 areapplicable, the client should consider project-related impacts across thepotentially affected landscape or seascape.7. As a matter of priority, the client should seek to avoid impacts onbiodiversity and ecosystem services. When avoidance of impacts is notpossible, measures to minimize impacts and restore biodiversity andecosystem services should be implemented. Given the complexity inpredicting project impacts on biodiversity and ecosystem services overthe long term, the client should adopt a practice of adaptivemanagement in which the implementation of mitigation andmanagement measures are responsive to changing conditions and theresults of monitoring throughout the project’s lifecycle.8. Where paragraphs 13–15 are applicable, the client will retaincompetent professionals to assist in conducting the risks and impactsidentification process. Where paragraphs 16–19 are applicable, theclient should retain external experts with appropriate regionalexperience to assist in the development of a mitigation hierarchy thatcomplies with this Performance Standard and to verify theimplementation of those measures.Protection and Conservation of Biodiversity9. Habitat is defined as a terrestrial, freshwater, or marine geographicalunit or airway that supports assemblages of living organisms and theirinteractions with the non-living environment. For the purposes ofimplementation of this Performance Standard, habitats are dividedinto modified, natural, and critical. Critical habitats are a subset ofmodified or natural habitats.10. For the protection and conservation of biodiversity, the mitigationhierarchy includes biodiversity offsets, which may be considered onlyafter appropriate avoidance, minimization, and restoration measureshave been applied. A biodiversity offset should be designed andimplemented to achieve measurable conservation outcomes that canreasonably be expected to result in no net loss and preferably a netgain of biodiversity; however, a net gain is required in critical habitats.The design of a biodiversity offset must adhere to the “like-for-like orbetter” principle and must be carried out in alignment with bestavailable information and current practices. When a client isconsidering the development of an offset as part of the mitigationstrategy, external experts with knowledge in offset design andimplementation must be involved.PS 6, paragraphs 6 and 7EHS Guidelines forForest HarvestingOperationsSee PS6, paragraphs 13-15PS 6, paragraph 9 and 10EHS Guidelines forForest HarvestingOperationsCompliance Status/ FindingsPARTIALLY COMPLIANTAccording to the EIA, the studies conducted during the previous licenseshowed only the initial situation of the area of influence and allow only ageneral prediction of the impacts on biodiversity (related to the change in theland use, increase in the nuisance to native species and restrictions toresources usage). The reports of the monitoring programs (PBA) allowcomparisons of data, yet still are not related to ecosystems services.Licensing process does not require and does not include identification andanalysis of impacts on eco-system services. Therefore there is no informationregarding this issue in the documentation presented.Recommended further actionsSee PS6, paragraphs 13-15 See PS6, paragraphs 13-15COMPLIANTAccording to documentation and information provided during site visit,compensation has been done and from the legal point of view ELDORADOis in compliance. However, ERM was not able to verify if the seedlingnursery operated by City Hall (due to timing and distance constraints),which was object of the compensation, is destined to produce native speciesfor recovery of natural vegetation.Evaluate potentially impacts on ecosystem services through the existingstudies (Industrial and Forest operations) and the data obtained in theimplementation of the environmental programs.As required by this item, offset or compensation measures should achieve ameasurable conservation outcome. Although the seedling nursery belongsto the City Hall and ELDORADO financially supports it, the companyshould monitor if the seedlings are contributing to the recovery of naturalvegetation (i.e. recuperation of preservation areas, conservation units). Thismonitoring may be done through periodic audits at the seedling nursery.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsModified Habitat11. Modified habitats are areas that may contain a large proportion ofplant and/or animal species of non-native origin, and/or wherehuman activity has substantially modified an area’s primary ecologicalfunctions and species composition. Modified habitats may includeareas managed for agriculture, forest plantations, reclaimed coastalzones, and reclaimed wetlands.12. This Performance Standard applies to those areas of modified habitatthat include significant biodiversity value, as determined by the risksand impacts identification process required in Performance Standard1. The client should minimize impacts on such biodiversity andimplement mitigation measures as appropriate.Natural Habitat13. Natural habitats are areas composed of viable assemblages of plantand/or animal species of largely native origin, and/or where humanactivity has not essentially modified an area’s primary ecologicalfunctions and species composition.14. The client will not significantly convert or degrade natural habitats,unless all of the following are demonstrated: No other viable alternatives within the region exist fordevelopment of the project on modified habitat; Consultation has established the views of stakeholders, includingAffected Communities, with respect to the extent of conversion anddegradation; and Any conversion or degradation is mitigated according to themitigation hierarchy.15. In areas of natural habitat, mitigation measures will be designed toachieve no net loss of biodiversity where feasible. Appropriate actionsinclude: Avoiding impacts on biodiversity through the identification andprotection of set-asides; Implementing measures to minimize habitat fragmentation, such asbiological corridors; Restoring habitats during operations and/or after operations; and Implementing biodiversity offsets.Critical Habitat16. Critical habitats are areas with high biodiversity value, including (i)habitat of significant importance to Critically Endangered and/orEndangered species; (ii) habitat of significant importance to endemicand/or restricted-range species; (iii) habitat supporting globallysignificant concentrations of migratory species and/or congregatoryspecies; (iv) highly threatened and/or unique ecosystems; and/or (v)areas associated with key evolutionary processes.17. In areas of critical habitat, the client will not implement any projectactivities unless all of the following are demonstrated: No other viable alternatives within the region exist fordevelopment of the project on modified or natural habitats that arenot critical; The project does not lead to measurable adverse impacts on thosebiodiversity values for which the critical habitat was designated,and on the ecological processes supporting those biodiversityvalues;PS 6, paragraphs 11 and12PS 6, paragraphs 13, 14and 15Compliance Status/ FindingsPARTIALLY COMPLIANTThe EIA presents quantitative data on fauna and flora.The EIA evaluated the impacts on flora and fauna (vegetation removal), asminor, and did not evaluate impacts on biodiversity, considering that theproject is located in an area previously modified. It also presents mitigationand management actions.PBA presents monitoring programs in order to minimize the impacts andrisks identified.Some modified habitats might contain high biodiversity values or areas thattrigger a critical habitat designation.NOT APPLICABLEThe EIA reports that the area has been previously modified and thereforeconsidered as modified habitat. Therefore this item is not applicable.PS 6, paragraphs 16 to 19 NOT APPLICABLEThe EIA reports that the area has been previously modified and thereforeconsidered as modified habitat. Therefore this item is not applicable.Recommended further actionsEvaluate potentially impacts on biodiversity through the existing studies(Industrial and Forest operations) and the data obtained in theimplementation of the environmental programs.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsCritical Habitat17. The project does not lead to a net reduction in the global and/ornational/regional population of any Critically Endangered orEndangered species over a reasonable period of time; and A robust, appropriately designed, and long-term biodiversitymonitoring and evaluation program is integrated into the client’smanagement program.18. In such cases where a client is able to meet the requirements defined inparagraph 17, the project’s mitigation strategy will be described in aBiodiversity Action Plan and will be designed to achieve net gains ofthose biodiversity values for which the critical habitat was designated.Compliance Status/ FindingsRecommended further actions19. In instances where biodiversity offsets are proposed as part of themitigation strategy, the client must demonstrate through anassessment that the project’s significant residual impacts onbiodiversity will be adequately mitigated to meet the requirements ofparagraph 17.Legally Protected and Internationally Recognized Areas20. In circumstances where a proposed project is located within a legallyprotected area or an internationally recognized area, the client willmeet the requirements of paragraphs 13 through 19 of thisPerformance Standard, as applicable. In addition, the client will: Demonstrate that the proposed development in such areas islegally permitted; Act in a manner consistent with any government recognizedmanagement plans for such areas; Consult protected area sponsors and managers, AffectedCommunities, Indigenous Peoples and other stakeholders on theproposed project, as appropriate; and Implement additional programs, as appropriate, to promote andenhance the conservation aims and effective management of thearea.PS 6, paragraph 20Federal Law nº 4771,September 15 th , 1965 andalterationsFederal Law nº 6.938,August 31 st , 1981 andalterationsConama Resolution nº369, March 28th, 2006Federal Law nº 6.902,April 27th,1981COMPLIANTAccording to documentation seen on site visit and information provided byELDORADO, the Legal Reserve of the site has term of provisionalregistration of the legal reserve for existing area of 81,5336 ha. Reportedly,the area has been georeferenced, but not delimited by fence and according tothe law the company is not obliged to recover the area. Also, according tolay-out and information provided during site visit the PermanentPreservation Area (PPA), of 200m from the riverside, is being respected.ELDORADO is not actively managing the lands to bring the PPA and theLegal reserve back into their natural state, based on a report that concludesthat in Cerrado biome is better to leave them for natural reforestation.Natural regeneration of the bioma Cerrado can occur once there is a nearsources of propagates (other Cerrado areas surrounding). If naturalregeneration is the intent, then measures should be adopted toavoid/eliminate disturbing factors (eg fire, opening trails, movement ofdomesticated animals like cattle and horses).ELDORADO should adopt measures to avoid/eliminate disturbing factorsand monitor if natural regeneration occurs, and prepare a recovery plan, ifnecessary.Invasive Alien Species21. Intentional or accidental introduction of alien, or non-native, species offlora and fauna into areas where they are not normally found can be asignificant threat to biodiversity, since some alien species can becomeinvasive, spreading rapidly and out-competing native species.22. The client will not intentionally introduce any new alien species (notcurrently established in the country or region of the project) unless thisis carried out in accordance with the existing regulatory framework forsuch introduction. Notwithstanding the above, the client will notdeliberately introduce any alien species with a high risk of invasivebehavior regardless of whether such introductions are permitted underthe existing regulatory framework. All introductions of alien specieswill be subject to a risk assessment (as part of the client’senvironmental and social risks and impacts identification process) todetermine the potential for invasive behavior. The client willimplement measures to avoid the potential for accidental orunintended introductions including the transportation of substratesand vectors (such as soil, ballast, and plant materials) that may harboralien species.PS 6, paragraphs 21 to 23 NOT APPLICABLENo information about invasive species was identified in the EIA and PBApresented.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal Standards23. Where alien species are already established in the country or region ofthe proposed project, the client will exercise diligence in not spreadingthem into areas in which they have not already been established. Aspracticable, the client should take measures to eradicate such speciesfrom the natural habitats over which they have management control.Management of Ecosystem Services24. Where a project is likely to adversely impact ecosystem services, asdetermined by the risks and impacts identification process, the clientwill conduct a systematic review to identify priority ecosystemservices. Priority ecosystem services are two-fold: (i) those services onwhich project operations are most likely to have an impact and,therefore, which result in adverse impacts to Affected Communities;and/or (ii) those services on which the project is directly dependentfor its operations (e.g., water). When Affected Communities are likelyto be impacted, they should participate in the determination of priorityecosystem services in accordance with the stakeholder engagementprocess as defined in Performance Standard 1.25. With respect to impacts on priority ecosystem services of relevance toAffected Communities and where the client manages directly or havesignificant influence over such ecosystem services, adverse impactsshould be avoided. If these impacts are unavoidable, the client willminimize them and implement mitigation measures that aim tomaintain the value and functionality of priority services. With respectto impacts on priority ecosystem services on which the projectdepends, clients should minimize impacts on ecosystem services andimplement measures that increase resource efficiency of theiroperations, as described in Performance Standard 3. Additionalprovisions for ecosystem services are included in PerformanceStandards 4, 5, 7, and 8.Sustainable Management of Living Natural Resources26. Clients who are engaged in the primary production of living naturalresources, including natural and plantation forestry, agriculture,animal husbandry, aquaculture, and fisheries, will be subject to therequirements of paragraphs 26 through 30, in addition to the rest ofthis Performance Standard. Where feasible, the client will locate landbasedagribusiness and forestry projects on unforested land or landalready converted. Clients who are engaged in such industries willmanage living natural resources in a sustainable manner, through theapplication of industry-specific good management practices andavailable technologies. Where such primary production practices arecodified in globally, regionally, or nationally recognized standards, theclient will implement sustainable management practices to one ormore relevant and credible standards as demonstrated by independentverification or certification.27. Credible globally, regionally, or nationally recognized standards forsustainable management of living natural resources are those which (i)are objective and achievable; (ii) are founded on a multi-stakeholderconsultative process; (iii) encourage step-wise and continualimprovements; and (iv) provide for independent verification orcertification through appropriate accredited bodies for such standards.28. Where relevant and credible standard(s) exist, but the client has not yetobtained independent verification or certification to such standard(s),the client will conduct a pre-assessment of its conformity to theapplicable standard(s) and take actions to achieve such verification orcertification over an appropriate period of time.PS 6, paragraphs 24 and25PS 6, paragraphs 26-30Compliance Status/ FindingsConsiderations regarding the analysis of impacts on ecosystem services arepresented on PS 6 paragraphs 6 and 7.NOT APPLICABLEThe project is not engaged in the activities described in these requirements.See assessment on Forestry Operations (Annex C)Recommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal Standards29. In the absence of a relevant and credible global, regional, or nationalstandard for the particular living natural resource in the countryconcerned, the client will: Commit to applying good international industry operatingprinciples, management practices, and technologies; and Actively engage and support the development of a nationalstandard, where relevant, including studies that contribute to thedefinition and demonstration of sustainable practices.Supply Chain30. Where a client is purchasing primary production (especially but notexclusively food and fiber commodities) that is known to be producedin regions where there is a risk of significant conversion of naturaland/or critical habitats, systems and verification practices will beadopted as part of the client’s ESMS to evaluate its primarysuppliers.21 The systems and verification practices will (i) identifywhere the supply is coming from and the habitat type of this area; (ii)provide for an ongoing review of the client’s primary supply chains;(iii) limit procurement to those suppliers that can demonstrate thatthey are not contributing to significant conversion of natural and/orcritical habitats (this may be demonstrated by delivery of certifiedproduct, or progress towards verification or certification under acredible scheme in certain commodities and/or locations); and (iv)where possible, require actions to shift the client’s primary supplychain over time to suppliers that can demonstrate that they are notsignificantly adversely impacting these areas. The ability of the clientto fully address these risks will depend upon the client’s level ofmanagement control or influence over its primary suppliers.Compliance Status/ FindingsFor further information about wood supply, refer to Annex C GapAnalysis Table Forest Operation, PS6 paragraph 30.Recommended further actionsReview against IFC Performance Standard 7 (Indigenous Peoples)No: Requirements of IFC PS 7 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsGeneralAvoidance of Adverse Impacts8. The client will identify, through an environmental and social risks and PS 7, paragraphs 8 to 22impacts assessment process, all communities of Indigenous Peopleswithin the project area of influence who may be affected by the project,as well as the nature and degree of the expected direct and indirecteconomic, social, cultural (including cultural heritage), andenvironmental impacts on them.9. Adverse impacts on Affected Communities of Indigenous Peoplesshould be avoided where possible. Where alternatives have beenexplored and adverse impacts are unavoidable, the client willminimize, restore, and/or compensate for these impacts in a culturallyappropriate manner commensurate with the nature and scale of suchimpacts and the vulnerability of the Affected Communities ofIndigenous Peoples. The client’s proposed actions will be developedwith the ICP of the Affected Communities of Indigenous Peoples andcontained in a time-bound plan, such as an Indigenous Peoples Plan,or a broader community development plan with separate componentsfor Indigenous Peoples.Compliance Status/ FindingsCOMPLIANTAs described on PS1, paragraph 32, an archeological survey has beenconducted in December 2011, and identified that there was no indigenousgroups or traditional people affected by ELDORADO’s operation. Itidentified one indigenous group in the municipality of Brasilandia namedOfayé-Xavante, 96 km away from ELDORADO industrial site.NOT APPLICABLERecommended further actionsNone.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsParticipation and Consent10. The client will undertake an engagement process with the AffectedCommunities of Indigenous Peoples as required in PerformanceStandard 1. This engagement process includes stakeholder analysisand engagement planning, disclosure of information, consultation, andparticipation, in a culturally appropriate manner. In addition, thisprocess will: Involve Indigenous Peoples’ representative bodies andorganizations (e.g., councils of elders or village councils), as well asmembers of the Affected Communities of Indigenous Peoples; and Provide sufficient time for Indigenous Peoples’ decision-makingprocesses.GeneralParticipation and Consent11. Affected Communities of Indigenous Peoples may be particularlyvulnerable to the loss of, alienation from or exploitation of their landand access to natural and cultural resources. In recognition of thisvulnerability, in addition to the General Requirements of thisPerformance Standard, the client will obtain the FPIC of the AffectedCommunities of Indigenous Peoples in the circumstances described inparagraphs 13–17 of this Performance Standard. FPIC applies to projectdesign, implementation, and expected outcomes related to impactsaffecting the communities of Indigenous Peoples. When any of thesecircumstances apply, the client will engage external experts to assist inthe identification of the project risks and impacts.12. There is no universally accepted definition of FPIC. For the purposes ofPerformance Standards 1, 7 and 8, “FPIC” has the meaning describedin this paragraph. FPIC builds on and expands the process of ICPdescribed in Performance Standard 1 and will be established throughgood faith negotiation between the client and the AffectedCommunities of Indigenous Peoples. The client will document: (i) themutually accepted process between the client and AffectedCommunities of Indigenous Peoples, and (ii) evidence of agreementbetween the parties as the outcome of the negotiations. FPIC does notnecessarily require unanimity and may be achieved even whenindividuals or groups within the community explicitly disagree.Compliance Status/ FindingsNOT APPLICABLENOT APPLICABLENOT APPLICABLERecommended further actionsCircumstances Requiring Free, Prior, and Informed ConsentImpacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use13. Indigenous Peoples are often closely tied to their lands and relatednatural resources. Frequently, these lands are traditionally owned orunder customary use. While Indigenous Peoples may not possess legaltitle to these lands as defined by national law, their use of these lands,including seasonal or cyclical use, for their livelihoods, or cultural,ceremonial, and spiritual purposes that define their identity andcommunity, can often be substantiated and documented.NOT APPLICABLEENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsCircumstances Requiring Free, Prior, and Informed ConsentImpacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary UseCompliance Status/ FindingsRecommended further actions14. If the client proposes to locate a project on, or commercially developNOT APPLICABLEnatural resources on lands traditionally owned by, or under thecustomary use of, Indigenous Peoples, and adverse impacts can beexpected, the client will take the following steps: Document efforts to avoid and otherwise minimize the area of landproposed for the project; Document efforts to avoid and otherwise minimize impacts onnatural resources and natural areas of importance to IndigenousPeople; Identify and review all property interests and traditional resourceuses prior to purchasing or leasing land; Assess and document the Affected Communities of IndigenousPeoples’ resource use without prejudicing any Indigenous Peoples’land claim. The assessment of land and natural resource use shouldbe gender inclusive and specifically consider women’s role in themanagement and use of these resources; Ensure that Affected Communities of Indigenous Peoples areinformed of their land rights under national law, including anynational law recognizing customary use rights; and Offer Affected Communities of Indigenous Peoples compensationand due process in the case of commercial development of theirland and natural resources, together with culturally appropriatesustainable development opportunities, including: Providing land-based compensation or compensation-in-kind inlieu of cash compensation where feasible. Ensuring continued access to natural resources, identifying the equivalent replacement resources, or, as a last option, providingcompensation and identifying alternative livelihoods if projectdevelopment results in the loss of access to and the loss ofnatural resources independent of project land acquisition. Ensuring fair and equitable sharing of benefits associated withproject usage of the resources where the client intends to utilizenatural resources that are central to the identity and livelihoodof Affected Communities of Indigenous People and their usagethereof exacerbates livelihood risk. Providing Affected Communities of Indigenous Peoples withaccess, usage, and transit on land it is developing subject tooverriding health, safety, and security considerations.Relocation of Indigenous Peoples from Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use15. The client will consider feasible alternative project designs to avoid therelocation of Indigenous Peoples from communally held lands andnatural resources subject to traditional ownership or under customaryuse. If such relocation is unavoidable the client will not proceed withthe project unless FPIC has been obtained as described above. Anyrelocation of Indigenous Peoples will be consistent with therequirements of Performance Standard 5. Where feasible, the relocatedIndigenous Peoples should be able to return to their traditional orcustomary lands, should the cause of their relocation cease to exist.NOT APPLICABLEENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsCritical Cultural HeritageCompliance Status/ Findings16. Where a project may significantly impact on critical cultural heritageNOT APPLICABLEthat is essential to the identity and/or cultural, ceremonial, or spiritualaspects of Indigenous Peoples lives, priority will be given to theavoidance of such impacts. Where significant project impacts oncritical cultural heritage are unavoidable, the client will obtain theFPIC of the Affected Communities of Indigenous Peoples.17. Where a project proposes to use the cultural heritage includingNOT APPLICABLEknowledge, innovations, or practices of Indigenous Peoples forcommercial purposes, the client will inform the Affected Communitiesof Indigenous Peoples of (i) their rights under national law; (ii) thescope and nature of the proposed commercial development; (iii) thepotential consequences of such development; and (iv) obtain theirFPIC. The client will also ensure fair and equitable sharing of benefitsfrom commercialization of such knowledge, innovation, or practice,consistent with the customs and traditions of the Indigenous Peoples.Mitigation and Development Benefits18. The client and the Affected Communities of Indigenous Peoples willNOT APPLICABLEidentify mitigation measures in alignment with the mitigationhierarchy described in Performance Standard 1 as well asopportunities for culturally appropriate and sustainable developmentbenefits. The client will ensure the timely and equitable delivery ofagreed measures to the Affected Communities of Indigenous Peoples.19. The determination, delivery, and distribution of compensation andNOT APPLICABLEother benefit sharing measures to the Affected Communities ofIndigenous Peoples will take account of the laws, institutions, andcustoms of these communities as well as their level of interaction withmainstream society. Eligibility for compensation can either beindividually or collectively-based, or be a combination of both. Wherecompensation occurs on a collective basis, mechanisms that promotethe effective delivery and distribution of compensation to all eligiblemembers of the group will be defined and implemented.20. Various factors including, but not limited to, the nature of the project,NOT APPLICABLEthe project context and the vulnerability of the Affected Communitiesof Indigenous Peoples will determine how these communities shouldbenefit from the project. Identified opportunities should aim to addressthe goals and preferences of the Indigenous Peoples includingimproving their standard of living and livelihoods in a culturallyappropriate manner, and to foster the long-term sustainability of thenatural resources on which they depend.Private Sector Responsibilities Where Government is Responsible for Managing Indigenous Peoples Issues21. Where the government has a defined role in the management ofIndigenous Peoples issues in relation to the project, the client willcollaborate with the responsible government agency, to the extentfeasible and permitted by the agency, to achieve outcomes that areconsistent with the objectives of this Performance Standard. Inaddition, where government capacity is limited, the client will play anactive role during planning, implementation, and monitoring ofactivities to the extent permitted by the agency.NOT APPLICABLERecommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsCompliance Status/ FindingsPrivate Sector Responsibilities Where Government is Responsible for Managing Indigenous Peoples Issues22. The client will prepare a plan that, together with the documentsprepared by the responsible government agency, will address therelevant requirements of this Performance Standard. The client mayneed to include (i) the plan, implementation, and documentation of theprocess of ICP and engagement and FPIC where relevant; (ii) adescription of the government-provided entitlements of affectedIndigenous Peoples; (iii) the measures proposed to bridge any gapsbetween such entitlements, and the requirements of this PerformanceStandard; and (iv) the financial and implementation responsibilities ofthe government agency and/or the client.NOT APPLICABLERecommended further actionsReview against IFC Performance Standard 8 (Cultural Heritage)No: Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsProtection of Cultural Heritage in Project Design and Execution6. In addition to complying with applicable law on the protection of PS 8, paragraph 6 and 8cultural heritage, including national law implementing the hostcountry’s obligations under the Convention Concerning the Protectionof the World Cultural and Natural Heritage, the client will identify andprotect cultural heritage by ensuring that internationally recognizedpractices for the protection, field-based study, and documentation ofcultural heritage are implemented.7. Where the risk and identification process determines that there is achance of impacts to cultural heritage, the client will retain competentprofessionals to assist in the identification and protection of culturalheritage. The removal of nonreplicable cultural heritage is subject tothe additional requirements of paragraph 10 below. In the case ofcritical cultural heritage, the requirements of paragraphs 13–15 willapply.Chance Find Procedures8. The client is responsible for siting and designing a project to avoidsignificant adverse impacts to cultural heritage. The environmentaland social risks and impacts identification process should determinewhether the proposed location of a project is in areas where culturalheritage is expected to be found, either during construction oroperations. In such cases, as part of the client’s ESMS, the client willdevelop provisions for managing chance finds through a chance findprocedure which will be applied in the event that cultural heritage issubsequently discovered. The client will not disturb any chance findfurther until an assessment by competent professionals is made andactions consistent with the requirements of this Performance Standardare identified.PS 8, paragraph 7See PS 8, paragraph 6Compliance Status/ FindingsCOMPLIANTArcheological survey has been conducted in December 2011. The study hasrevealed a set of 10 archaeological sites and related chipped lithic remains.Both the inclusion of topographic sites on average slope, and thecharacteristics of the lithic material allow characterizing these locations ascampsites for hunter-gatherers to prehistoric hunting activities, fishing andgathering. This study has been submitted to the Institute for NationalHistorical and Artistic Heritage (IPHAN – Instituto do Patrimônio Histórico eArtístico Nacional) and waits for the issuance of technical opinion.PARTIALLY COMPLIANTWithin the archaeological study, developed by external professionals, animpact assessment of the archaeological sites has been conducted in theareas of reforestation of ELDORADO considered to have direct impact. In allsites the impacts were considered negative, direct, temporary andirreversible.Recommended further actionsThe client should apply internationally recognized practices to site surveys,excavation, preservation and publication, in addition to compliance withnational law. An internationally recognized practice is defined as theexercise of professional skill, knowledge, diligence, prudence and foresightthat would reasonably be expected from experienced professionals engagedin the same type of undertaking under the same or similar circumstancesglobally. Where the client is in doubt on what constitutes internationallyrecognized practice, international peer reviewers are able to provideguidance.Recommendations provided in the archaeological study should beimplemented by ELDORADO.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsConsultation9. Where a project may affect cultural heritage, the client will consultwith Affected Communities within the host country that use, or haveused within living memory, the cultural heritage for long-standingcultural purposes. The client will consult with the AffectedCommunities to identify cultural heritage of importance, and toincorporate into the client’s decision-making process the views of theAffected Communities on such cultural heritage. Consultation will alsoinvolve the relevant national or local regulatory agencies that areentrusted with the protection of cultural heritage.PS 8, paragraph 9Community Access10. Where the client’s project site contains cultural heritage or preventsaccess to previously accessible cultural heritage sites being used by, orthat have been used by, Affected Communities within living memoryfor long-standing cultural purposes, the client will, based onconsultations under paragraph 9, allow continued access to thecultural site or will provide an alternative access route, subject tooverriding health, safety, and security considerations.PS 8, paragraph 10Removal of Replicable Cultural Heritage11. Where the client has encountered tangible cultural heritage that is PS 8, paragraph 11replicable and not critical, the client will apply mitigation measuresthat favor avoidance. Where avoidance is not feasible, the client willapply a mitigation hierarchy as follows: Minimize adverse impacts and implement restoration measures, insitu, that ensure maintenance of the value and functionality of thecultural heritage, including maintaining or restoring any ecosystemprocesses4 needed to support it; Where restoration in situ is not possible, restore the functionality ofthe cultural heritage, in a different location, including theecosystem processes needed to support it; The permanent removal of historical and archaeological artefactsand structures is carried out according to the principles ofparagraphs 6 and 7 above; and Only where minimization of adverse impacts and restoration toensure maintenance of the value and functionality of the culturalheritage are demonstrably not feasible, and where the AffectedCommunities are using the tangible cultural heritage for longstandingcultural purposes, compensate for loss of that tangiblecultural heritage.Compliance Status/ FindingsPARTIALLY COMPLIANTStudy has been submitted to the Institute for National Historical and ArtisticHeritage (IPHAN – Instituto do Patrimônio Histórico e Artístico Nacional)however it does not involve consultations with affected communities andtherefore does not incorporate in its decision-making process theconsiderations of these affected communities.ELDORADO presented the Program “ELDORADO PES NO CHÃO”, inwhich the company preserves as a local heritage houses that were built withtiles made of the local riverbed clay. There is evidence of consultation madewith the owners of the houses.NOT APPLICABLEAccording information from archeological survey presented to IPHAN (referto Annex A) the site does not prevent access to cultural heritages orpreviously cultural heritage sites. Therefore this requirement is notapplicable.COMPLIANTWithin the archaeological study, mitigation measures, related to impactsidentified, were suggested for effective protection of archaeological heritage.These mitigation measures during the implementation of the project were:development of a program of archaeological exploration and development ofan archaeological monitoring program. The measures suggested to be takenimmediately after the implementation of the project were: the publication ofillustrated book for the general public to the socialization of knowledgearchaeological site Três Lagoas, Selvíria, Aparecida do Taboado, Inocência,Água Clara, Ribas do Rio Pardo and Santa Rita do Rio Pardo/MS , and thesecond phase of development of heritage education activities in thecommunities surrounding the project.Recommended further actionsConsultation is an important means of identifying it, documenting itspresence and significance, assessing potential impacts, and exploringmitigation options. Requirements on the community engagement ofAffected Communities can be found in paragraphs 25 through 33 ofPerformance Standard 1.ELDORADO should continue to make special efforts to consult with thehistorical or traditional users or owners of tangible cultural heritage,especially inhabitants of the area impacted by a project within the hostcountry, since the interests of these users or owners may be different thanthe desires expressed by competent experts or government officials.ELDORADO should provide early notification and engage with suchgroups regarding possible public use, relocation of or other adverse impactson cultural heritage resources. The consultation process should actively seekto identify concerns of these users or owners of tangible cultural heritage,and, where possible, ELDORADO should take these concerns into accountin the way its project manages cultural heritage.It was recommended by the archaeological survey to perform duringimplementation of the enterprise the following actions:- Archaeological survey project in 10 sites located in view of scientificrelevance and susceptibility of the sites to erosion in the area ofreforestation;- Monitoring the implementation of the project to avoid impacts on localarchaeological heritage in the area indirectly impacted by the change in soilstructure;-Continue activities related to heritage education in the communitiessurrounding the project, based on publication of a scientific communicationbook about the archaeological site.ERM recommends to expand the area of study, since there will be purchaseof wood, and partnership contracts to plant eucalyptus in other areasbeyond the areas owned by ELDORADO. Therefore these areas couldpresent cultural heritage that was not identified due to the limited areapreviously defined in the study present to IPHAN.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

No: Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (General,Pulp and Paper) andLegal StandardsRemoval of Non-Replicable Cultural Heritage12. Most cultural heritage is best protected by preservation in its place,since removal is likely to result in irreparable damage or destruction ofthe cultural heritage. The client will not remove any nonreplicablecultural heritage, unless all of the following conditions are met: There are no technically or financially feasible alternatives toremoval; The overall benefits of the project conclusively outweigh theanticipated cultural heritage loss from removal; and Any removal of cultural heritage is conducted using the bestavailable technique.Critical Cultural Heritage13. Critical cultural heritage consists of one or both of the following typesof cultural heritage: (i) the internationally recognized heritage ofcommunities who use, or have used within living memory the culturalheritage for long-standing cultural purposes; or (ii) legally protectedcultural heritage areas, including those proposed by host governmentsfor such designation.14. The client should not remove, significantly alter, or damage criticalcultural heritage. In exceptional circumstances when impacts oncritical cultural heritage are unavoidable, the client will use a processof Informed Consultation and Participation (ICP) of the AffectedCommunities as described in Performance Standard 1 and which usesa good faith negotiation process that results in a documented outcome.The client will retain external experts to assist in the assessment andprotection of critical cultural heritage.15. Legally protected cultural heritage areas are important for theprotection and conservation of cultural heritage, and additionalmeasures are needed for any projects that would be permitted underthe applicable national law in these areas. In circumstances where aproposed project is located within a legally protected area or a legallydefined buffer zone, the client, in addition to the requirements forcritical cultural heritage cited in paragraph 14 above, will meet thefollowing requirements: Comply with defined national or local cultural heritage regulationsor the protected area management plans; Consult the protected area sponsors and managers, localcommunities and other key stakeholders on the proposed project;and Implement additional programs, as appropriate, to promote andenhance the conservation aims of the protected area.Project’s Use of Cultural Heritage16. Where a project proposes to use the cultural heritage, includingknowledge, innovations, or practices of local communities forcommercial purposes, the client will inform these communities of (i)their rights under national law; (ii) the scope and nature of theproposed commercial development; and (iii) the potentialconsequences of such development. The client will not proceed withsuch commercialization unless it (i) enters into a process of ICP asdescribed in Performance Standard 1 and which uses a good faithnegotiation process that results in a documented outcome and (ii)provides for fair and equitable sharing of benefits fromcommercialization of such knowledge, innovation, or practice,consistent with their customs and traditions.PS 8, paragraph 12PS 8, paragraphs 13, 14and 15Compliance Status/ FindingsNOT APPLICABLEAccording information from archaeological survey presented to IPHAN, thesites do not present non-replicable cultural heritage.NOT APPLICABLEAccording information from archeological survey presented to IPHAN (Seedocument list) there is no critical cultural heritage and the project is notinserted in legally cultural protected areas. Therefore, these requirements arenot applicable.NOT APPLICABLEThe scope and nature of the proposed project does not involve the use ofcultural heritage, therefore this requirement is not applicable.Recommended further actionsRefer to PS 8, paragraph 11.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Annex DGap Analysis Table – ForestryOperations

Review against IFC Performance Standard 1 (Assessment and Management of Environmental and Social Risks and Impacts)No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsEnvironmental and Social Assessment and Management System5. The client, in coordination with other responsible government agenciesand third parties as appropriate, will conduct a process ofenvironmental and social assessment, and establish and maintain anESMS appropriate to the nature and scale of the project andcommensurate with the level of its environmental and social risks andimpacts. The ESMS will incorporate the following elements: (i) policy;(ii) identification of risks and impacts; (iii) management programs; (iv)organizational capacity and competency; (v) emergency preparednessand response; (vi) stakeholder engagement; and (vii) monitoring andreview.PS 1, paragraph 5Policy6. The client will establish an overarching policy defining theenvironmental and social objectives and principles that guide theproject to achieve sound environmental and social performance. Thepolicy provides a framework for the environmental and socialassessment and management process, and specifies that the project (orbusiness activities, as appropriate) will comply with the applicablelaws and regulations of the jurisdictions in which it is beingundertaken, including those laws implementing host countryobligations under international law. The policy should be consistentwith the principles of the Performance Standards. Under somecircumstances, clients may also subscribe to other internationallyrecognized standards, certification schemes, or codes of practice andthese too should be included in the policy. The policy will indicatewho, within the client’s organization, will ensure conformance with thepolicy and be responsible for its execution (with reference to anappropriate responsible government agency or third party, asnecessary). The client will communicate the policy to all levels of itsorganization.PS 1, paragraph 6Compliance Status/ FindingsCOMPLIANTRegarding management system for Forest operations, ELDORADOhas presented a document called Forest Management Plan in which includesthe environmental management system and all the tools for planning,control and development of the business. This document explains how themanagement system works and what is considered in each step. Also asoftware was presented for project management which includesenvironmental activities such as procedures regarding assessment ofplanting or wood cutting areas. A procedure has been recently defined inorder to assess economic, environmental and social aspects of the owned,leased or partnership areas. This procedure is called PTEAS – Economic,Environmental and Social Technical Project (Projeto Técnico Econômico,Ambiental e Social) and it is developed by a multidisciplinary team.A training matrix was developed to identify legal required training for eachprofessional category. The matrix was evidenced and it does not includetraining programs for employees and contractors with direct responsibilityfor relevant social and environmental performance.The PTEAS procedure states that all staff in charge of it shall be trained onthis procedures according while other staff shall be trained through intranetabout PTEAS. This training is not included on the training matrix and it wasnot evidenced the PTEAS training is in place.ERM was not able to check if there is monitoring and review of the actionsproposed and executed by the multidisciplinary team.The management system is apparently fully organized, but some of the toolsand actions are not yet being implemented.COMPLIANTAccording to information available on the company’s website and on theForest Management Plan, a sustainability policy, mission, vision and valueshave been developed and disclosed publicly.Recommended further actionsKeep the process of implementing the whole management tools.None.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsIdentification of Risks and Impacts7. The client will establish and maintain a process for identifying theenvironmental and social risks and impacts of the project (seeparagraph 18 for competency requirements). The type, scale, andlocation of the project guide the scope and level of effort devoted to therisks and impacts identification process. The scope of the risks andimpacts identification process will be consistent with goodinternational industry practice, and will determine the appropriate andrelevant methods and assessment tools. The process may comprise afull-scale environmental and social impact assessment, a limited orfocused environmental and social assessment, or straightforwardapplication of environmental siting, pollution standards, designcriteria, or construction standards. When the project involves existingassets, environmental and/or social audits or risk/hazard assessmentscan be appropriate and sufficient to identify risks and impacts. If assetsto be developed, acquired or financed have yet to be defined, theestablishment of an environmental and social due diligence processwill identify risks and impacts at a point in the future when thephysical elements, assets, and facilities are reasonably understood. Therisks and impacts identification process will be based on recentenvironmental and social baseline data at an appropriate level of detail.The process will consider all relevant environmental and social risksand impacts of the project, including the issues identified inPerformance Standards 2 through 8, and those who are likely to beaffected by such risks and impacts. The risks and impacts identificationprocess will consider the emissions of greenhouse gases, the relevantrisks associated with a changing climate and the adaptationopportunities, and potential transboundary effects, such as pollution ofair, or use or pollution of international waterways.8. Where the project involves specifically identified physical elements,aspects, and facilities that are likely to generate impacts, environmentaland social risks and impacts will be identified in the context of theproject’s area of influence. This area of influence encompasses, asappropriate: The area likely to be affected by: (i) the project and the client’sactivities and facilities that are directly owned, operated ormanaged (including by contractors) and that are a component ofthe project; (ii) impacts from unplanned but predictabledevelopments caused by the project that may occur later or at adifferent location; or (iii) indirect project impacts on biodiversity oron ecosystem services upon which Affected Communities’livelihoods are dependent. Associated facilities, which are facilities that are not funded as partof the project and that would not have been constructed orexpanded if the project did not exist and without which the projectwould not be viable. Cumulative impacts that result from the incremental impact, onareas or resources used or directly impacted by the project, fromother existing, planned or reasonably defined developments at thetime the risks and impacts identification process is conducted.PS 1, paragraphs 7-12PS 1, paragraphs 8, 9, 10and 11Compliance Status/ FindingsPARTIALLY COMPLIANTEnvironmental aspects and impacts have been assessed and are documentedin a spreadsheet provided by ELDORADO. This assessment was developedby Poyry Silviconsult in order to evaluate the impacts associated with theforest activities. Also, a document named Forest Management Plan has beenprovided and it includes monitoring activities in order to check if theimpacts are being mitigated and minimized.A social and economic diagnosis was developed for 7 municipalities whereELDORADO’s operates: Tres Lagoas, Selvíria, Água Clara, Inocencia, Ribasdo Rio Pardo, Santa Rita do Pardo, Aparecida do Taboado. This studyidentified the main vulnerabilities of the municipalities as establishesindicators to monitor ELDORADO’s contribution to local development.As a result of this study, ELDORADO will cross the main vulnerability ofthe region with the impacts of the industrial and forest operation that couldoptimize the positive impacts and mitigate de adverse impacts.Specific impacts of forest operation on land are identified through theprocedure for the Development of Environmental, Social and TechnicalProject (PTEAS) which should be applied to every farm 1 or 2 months beforeintervention (planting and harvesting) to support land management.This procedure is dated December 2011 and PTEAS was not carried out atfarms in which planting was performed before this. Those farms will beassessed through the PTEAS procedure only before harvesting.Specific gaps in the existing assessments are pointed in the PS 2 to 8.PARTIALLY COMPLIANTThe Forest Management Plan defined the area affected by the project. It doesnot include the lands at São Paulo and Minas Gerais state (that will supplywood for the first years of operation) and Dois Irmãos dos Buruti andAnastacio municipalities, where ELDORADO owns 4 land and lease 2 lands.The procedure defined (PTEAS) do not assess cumulative impacts fromother existing, planned or reasonably defined developments.Recommended further actionsConduct the PTEAS in all farms operated by ELDORADO beforeintervention.Identify areas likely to be affected by the operation at São Paulo andMinas Gerais state and Dois Irmãos dos Buruti and Anastaciomunicipalities.Cumulative impacts should be assessed. Cumulative impacts are those thatresult from the incremental impact of the project when added to otherexisting, planned and reasonably predictable future projects anddevelopments.9. In the event of risks and impacts in the project’s area of influenceresulting from a third party’s actions, the client will address those risksand impacts in a manner commensurate with the client’s control andinfluence over the third parties, and with due regard to conflict ofinterest.PS 1, paragraph 9COMPLIANTRisks and impacts of forest operation performed by rural labour contractorsare covered by the implementation of ELDORADO’s procedure in the landand covered by contract agreement.Risk and impacts from wood and land supply are covered by contractagreements.NoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandards10. Where the client can reasonably exercise control, the risks and impactsidentification process will also consider those risks and impactsassociated with primary supply chains, as defined in PerformanceStandard 2 (paragraphs 27–29) and Performance Standard 6 (paragraph30).PS 1, paragraph 10Compliance Status/ FindingsPARTIALLY COMPLIANTFor contract purpose, ELDORADO requests the wood suppliers severaldocuments and clearance certification to identify legal risks associated withthe farm and the wood transaction before contract is signed by both parts.There is no monitor procedure in place after the contract is signed, eventhough wood is supplied 2 to 4 years after it. Refer to PS2 and PS6 forfurther information about supply chain management.Reportedly, ELDORADO will persuade the certification of Chain of Custodywhich should guarantee the origin of the wood supplied by third part.Other suppliers are monitored by the person in charge of the contract toidentify if the practice of contracting workers is according to Brazilianlegislation. For payment reasons, the supplier shall provide the clearancecertification for taxes and contribution charges.Recommended further actionsMonitor significant suppliers, like wood suppliers, to identify if they arefollowing ELDORADO´s requirements.For detailed information, Refer to PS2, paragraph 25, and PS6, paragraph 30.11. Where the project involves specifically identified physical elements,aspects and facilities that are likely to generate environmental andsocial impacts, the identification of risks and impacts will take intoaccount the findings and conclusions of related and applicable plans,studies, or assessments prepared by relevant government authorities orother parties that are directly related to the project and its area ofinfluence. These include master economic development plans, countryor regional plans, feasibility studies, alternatives analyses, andcumulative, regional, sectoral, or strategic environmental assessmentswhere relevant. The risks and impacts identification will take accountof the outcome of the engagement process with Affected Communitiesas appropriate.12. Where the project involves specifically identified physical elements,aspects and facilities that are likely to generate impacts, and as part ofthe process of identifying risks and impacts, the client will identifyindividuals and groups that may be directly and differentially ordisproportionately affected by the project because of theirdisadvantaged or vulnerable status. Where individuals or groups areidentified as disadvantaged or vulnerable, the client will propose andimplement differentiated measures so that adverse impacts do not falldisproportionately on them and they are not disadvantaged in sharingdevelopment benefits and opportunities.PS 1, paragraph 11 Refer to Paragraph 8 NonePS 1, paragraph 12PARTIALLY COMPLIANTThere is a social economic diagnosis, an inventory of areas of highconservation and archeological survey that identify vulnerabilities of theareas.The social economic studies undertaken did not aim to identify vulnerablegroups that may be differentially or disproportionately affected by theproject because of their disadvantaged or vulnerable status.According to IFC disadvantage or vulnerable status may stem from anindividual’s or group’s race, color, sex, language, religion, political or otheropinion, national or social origin, property, birth, or other status. It shall alsoconsider factors such as gender, age, ethnicity, culture, literacy, sickness,physical or mental disability, poverty or economic disadvantage, anddependence on unique natural resources.There may be individuals or groups within the project’s area of influencewho are particularly vulnerable or disadvantaged and who could experienceadverse impacts from the proposed project more severely than others.Identify any potential group that may be differentially or disproportionatelyaffected by the expansion project and implement differentiated measures sothat adverse impacts do not fall disproportionately on them and they are notdisadvantaged in sharing development benefits and opportunities. If nogroup is identified as vulnerable or differentially affected document (a briefstatement to this fact is sufficient) justify so.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsManagement Programs13. Consistent with the client’s policy and the objectives and principlesdescribed therein, the client will establish management programs that,in sum, will describe mitigation and performance improvementmeasures and actions that address the identified environmental andsocial risks and impacts of the project.14. Depending on the nature and scale of the project, these programs mayconsist of some documented combination of operational procedures,practices, plans, and related supporting documents (including legalagreements) that are managed in a systematic way. The programs mayapply broadly across the client’s organization, including contractorsand primary suppliers over which the organization has control orinfluence, or to specific sites, facilities, or activities. The mitigationhierarchy to address identified risks and impacts will favor theavoidance of impacts over minimization, and, where residual impactsremain, compensation/offset, wherever technically and financiallyfeasible.15. Where the identified risks and impacts cannot be avoided, the clientwill identify mitigation and performance measures and establishcorresponding actions to ensure the project will operate in compliancewith applicable laws and regulations, and meet the requirements ofPerformance Standards 1 through 8. The level of detail and complexityof this collective management program and the priority of theidentified measures and actions will be commensurate with theproject’s risks and impacts, and will take account of the outcome of theengagement process with Affected Communities as appropriate.16. The management programs will establish environmental and socialAction Plans, which will define desired outcomes and actions toaddress the issues raised in the risks and impacts identificationprocess, as measurable events to the extent possible, with elementssuch as performance indicators, targets, or acceptance criteria that canbe tracked over defined time periods, and with estimates of theresources and responsibilities for implementation. As appropriate, themanagement program will recognize and incorporate the role ofrelevant actions and events controlled by third parties to addressidentified risks and impacts. Recognizing the dynamic nature of theproject, the management program will be responsive to changes incircumstances, unforeseen events, and the results of monitoring andreview.Organizational Capacity and Competency17. The client, in collaboration with appropriate and relevant third parties,will establish, maintain, and strengthen as necessary an organizationalstructure that defines roles, responsibilities, and authority toimplement the ESMS. Specific personnel, including managementrepresentative(s), with clear lines of responsibility and authorityshould be designated. Key environmental and social responsibilitiesshould be well defined and communicated to the relevant personneland to the rest of the client’s organization. Sufficient managementsponsorship and human and financial resources will be provided on anongoing basis to achieve effective and continuous environmental andsocial performance.PS 1, paragraphs 13-16PS 1, paragraphs 17 and18Compliance Status/ FindingsCOMPLIANTRisks and impacts have been identified, organized inside a managementprogram and implemented within the management system. Documentshave been provided in order to show compliance in this issue.These documents are: Forest Management Plan, Inventory of Areas of HighConservation Value for critic sociocultural and / or essential social functionsand Impact Assessment of the Forest activities developed by PoyrySilviconsult.The Forest Management Plan will be revised annually.PARTIALLY COMPLIANTReportedly specific personnel have been assigned for roles andresponsibilities within the environmental and social aspects of the project.A Matrix for functions and responsibilities was developed defining workerscategories, activity performed and profile.A training matrix was developed to identify legal training for each workcategory. Those legal required training does not cover the aspects treated bythis performance standard, specially the social aspects.Reportedly, rural worker’s supervisors will be training in people’smanagement.Recommended further actionsRefer to PS1, paragraph 7-12 to impact and risk identification.In addition to the Forest Management Plan, ELDORADO shall define othermeasures to address the recommendations described in this document.Develop training program to support the designated personnel to carry outtheir part of the ESMS. The training program should ensure consistency withELDORADO policies and procedures. The training can be formal, informal(on-the-job), one-time, periodic, etc. The program must include third partieswith direct responsibility with activities relevant to the environmental andsocial performance of the project, for example, wood suppliers, ruralworkers supplier, etc and include documented training records.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsOrganizational Capacity and Competency18. Personnel within the client’s organization with direct responsibility forthe project’s environmental and social performance will have theknowledge, skills, and experience necessary to perform their work,including current knowledge of the host country’s regulatoryrequirements and the applicable requirements of PerformanceStandards 1 through 8. Personnel will also possess the knowledge,skills, and experience to implement the specific measures and actionsrequired under the ESMS and the methods required to perform theactions in a competent and efficient manner.19. The process of identification of risks and impacts will consist of anadequate, accurate, and objective evaluation and presentation,prepared by competent professionals. For projects posing potentiallysignificant adverse impacts or where technically complex issues areinvolved, clients may be required to involve external experts to assistin the risks and impacts identification process.Emergency Preparedness and Response20. Where the project involves specifically identified physical elements,aspects and facilities that are likely to generate impacts, the ESMS willestablish and maintain an emergency preparedness and responsesystem so that the client, in collaboration with appropriate and relevantthird parties, will be prepared to respond to accidental and emergencysituations associated with the project in a manner appropriate toprevent and mitigate any harm to people and/or the environment.This preparation will include the identification of areas whereaccidents and emergency situations may occur, communities andindividuals that may be impacted, response procedures, provision ofequipment and resources, designation of responsibilities,communication, including that with potentially Affected Communitiesand periodic training to ensure effective response. The emergencypreparedness and response activities will be periodically reviewed andrevised, as necessary, to reflect changing conditions.21. Where applicable, the client will also assist and collaborate with thepotentially Affected Communities (see Performance Standard 4) andthe local government agencies in their preparations to respondeffectively to emergency situations, especially when their participationand collaboration are necessary to ensure effective response. If localgovernment agencies have little or no capacity to respond effectively,the client will play an active role in preparing for and responding toemergencies associated with the project. The client will document itsemergency preparedness and response activities, resources, andresponsibilities, and will provide appropriate information topotentially Affected Community and relevant government agencies.PS 1, paragraph 19PS 1, paragraph 20 and21Compliance Status/ FindingsMost of the staff interviewed reported previous experience on similar paper,pulp and forest companies.Reportedly, third parties are monitored by the person in charge of thecontract for the following issues: environmental performance, heath andsafety, operational performance, payment of taxes and contributionscharges. No evidence was provided to document this.COMPLIANTSee PS 1, paragraph 7 to 12COMPLIANTThe company has provided documentation of an EmergencyPlan procedure. It assess:-Leaks and spills of fuels and oils-Leaks and spills of pesticides in water-Forest fires-Disruption of landfill-Damage to the flora of permanent preservation areas and legal reserves-Material damage-Accident with injury or sudden illness.Also a system is in place for fire emergency. Workers are informed onemergency behavior in case of fire, there is telephone for emergency andthere is a fire combat car available. Record of firefighting training waspresented for Três Lagoas unit. (See document list).The emergency plan addresses on how information is disclosed to affectedcommunities, relevant government agencies or other relevant parties.Recommended further actionsNoneNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsMonitoring and Review22. The client will establish procedures to monitor and measure theeffectiveness of the management program, as well as compliance withany related legal and/or contractual obligations and regulatoryrequirements. Where the government or other third party hasresponsibility for managing specific risks and impacts and associatedmitigation measures, the client will collaborate in establishing andmonitoring such mitigation measures. Where appropriate, clients willconsider involving representatives from Affected Communities toparticipate in monitoring activities. The client’s monitoring programshould be overseen by the appropriate level in the organization. Forprojects with significant impacts, the client will retain external expertsto verify its monitoring information. The extent of monitoring shouldbe commensurate with the project’s environmental and social risks andimpacts and with compliance requirements.23. In addition to recording information to track performance andestablishing relevant operational controls, the client should usedynamic mechanisms, such as internal inspections and audits, whererelevant, to verify compliance and progress toward the desiredoutcomes. Monitoring will normally include recording information totrack performance and comparing this against the previouslyestablished benchmarks or requirements in the management program.Monitoring should be adjusted according to performance experienceand actions requested by relevant regulatory authorities. The client willdocument monitoring results and identify and reflect the necessarycorrective and preventive actions in the amended managementprogram and plans. The client, in collaboration with appropriate andrelevant third parties, will implement these corrective and preventiveactions, and follow up on these actions in upcoming monitoring cyclesto ensure their effectiveness.24. Senior management in the client organization will receive periodicperformance reviews of the effectiveness of the ESMS, based onsystematic data collection and analysis. The scope and frequency ofsuch reporting will depend upon the nature and scope of the activitiesidentified and undertaken in accordance with the client’s ESMS andother applicable project requirements. Based on results within theseperformance reviews, senior management will take the necessary andappropriate steps to ensure the intent of the client’s policy is met, thatprocedures, practices, and plans are being implemented, and are seento be effective.Stakeholder Engagement25. Stakeholder engagement is the basis for building strong, constructive,and responsive relationships that are essential for the successfulmanagement of a project's environmental and social impacts.Stakeholder engagement is an ongoing process that may involve, invarying degrees, the following elements: stakeholder analysis andplanning, disclosure and dissemination of information, consultationand participation, grievance mechanism, and ongoing reporting toAffected Communities. The nature, frequency, and level of effort ofstakeholder engagement may vary considerably and will becommensurate with the project’s risks and adverse impacts, and theproject’s phase of development.PS 1, paragraphs 22 and23PS 1, paragraph 24PS 1, paragraph 25Compliance Status/ FindingsPARTIALLY COMPLIANTDocuments provided do not contain the procedures to monitor and measureon a regular basis the key characteristics and performance of the socialmanagement program, including the use of external experts if required.COMPLIANTThe Sustainability Manager responds direct to ELDORADO’s CEO and hasdirect and frequent access to him. Information about license process andstakeholder relations is disclosure at the directors meetings.Once a week and once a month there are meetings about the projectinstallation and a report is disclosure. Information about forest activities arealso treated at these meetings.The management plan is reviewed once a year and it should be updatedevery time a new activity is implemented. There is also a monthly meetingamong managers and each coordinator, where targets and monitoringmeasures are discussed. Targets were implemented in December/2011.PARTIALLY COMPLIANTELDORADO has implemented the following practices on stakeholderengagement: Stakeholders mapping and identification, mostly through the socialeconomic diagnosis; Consultation with local governmentalrepresentatives to identify projects that can be supported byELDORADO; Consultation of a sample of citizens to identify vulnerability of theregion as part of the social economic diagnosis; Consultation ofcommunity members to identify areas of high conservation valueand their dependence toward it.as part of the inventory of areas ofhigh conservation value. Identification of land neighbors as part of the PTEAS; A public hearing will be carried out for the purpose of forestRecommended further actionsDevelop procedures to monitor and measure performance of the socialmanagement program including impacts on community health and safety(refer to PS4 for further recommendation).None.To comply with this performance standard ELDORADO should develop aStakeholder Engagement Plan. Such a plan should consider whetherstakeholders are:positively or negatively affected by ELDORADO;directly or indirectly impacted, particularly those directly and adverselyaffected by project activities, including those that are disadvantaged orvulnerable; stakeholders who may be able to influence the outcome of the projectbecause of their knowledge about the affected communities or politicalinfluence over them; Legitimate stakeholders representatives, including elected officials, nonelectedcommunity leaders, leader of informal or traditional communityinstitutions, and elders within the affected community;ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsStakeholder EngagementCompliance Status/ Findingscertification. The Forest Management Plan will be publiclydisclosed during the public meeting;A community relationship plan is being developed.None of the above mentioned initiatives were undertaken to 2 Irmãos doBuruti and Anastacio municipalities.ELDORADO does not have a systematic approach to consult or to engagestakeholders neither, and as such this item is rated partially completed.Recommended further actions Stakeholders not directly affected by the project but may have the abilityto influence or alter the relationship of the client with the affectedcommunity.The Stakeholder Engagement Plan should also include: engagement principles, objective and criteria, risks and impacts, identification, characterization and priority of stakeholders, focusing onthose directly affected by the project and vulnerable groups, how interaction should be formalized, consultation frequency, grievance mechanism, list of time-bound activities, resources and responsibilities, Communication channels, including those to disclosure informationabout risk and impact. The engagement process shall also support the update of risks andimpacts of the operation to affected community.Information about risks and impacts identified, mitigation measures shall beperiodically disclosure to affected community, at least annually, as long thespecific items in the management programs. ELDORADO may considerusing sustainability report on the financial, environmental and social aspectsto report so.Stakeholder Analysis and Engagement Planning26. Clients should identify the range of stakeholders that may be interestedin their actions and consider how external communications mightfacilitate a dialog with all stakeholders (paragraph 34 below). Whereprojects involve specifically identified physical elements, aspectsand/or facilities that are likely to generate adverse environmental andsocial impacts to Affected Communities the client will identify theAffected Communities and will meet the relevant requirementsdescribed below.27. The client will develop and implement a Stakeholder Engagement Planthat is scaled to the project risks and impacts and development stage,and be tailored to the characteristics and interests of the AffectedCommunities. Where applicable, the Stakeholder Engagement Planwill include differentiated measures to allow the effective participationof those identified as disadvantaged or vulnerable. When thestakeholder engagement process depends substantially on communityrepresentatives, the client will make every reasonable effort to verifythat such persons do in fact represent the views of AffectedCommunities and that they can be relied upon to faithfullycommunicate the results of consultations to their constituents.28. In cases where the exact location of the project is not known, but it isreasonably expected to have significant impacts on local communities,the client will prepare a Stakeholder Engagement Framework, as partof its management program, outlining general principles and a strategyto identify Affected Communities and other relevant stakeholders andPS 1, paragraph 26,27PARTIALLY COMPLIANTRefer to PS1, paragraph 25Refer to PS1, paragraph 25PS 1, paragraph 28PARTIALLY COMPLIANTELDORADO is still on process to acquire lands, which means that theexact location of some of the forest operation is not known yet.ELDORADO has defined that the preference area to acquire land is in aratio of 100 km away from the factory. A socio economic diagnosis wasRefer to the PS1, paragraph 25 for recommendation on StakeholderEngagement Plan.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsplan for an engagement process compatible with this PerformanceStandard that will be implemented once the physical location of theproject is known.Disclosure of Information29. Disclosure of relevant project information helps Affected Communities PS 1, paragraph 29and other stakeholders understand the risks, impacts andopportunities of the project. The client will provide AffectedCommunities with access to relevant information on: (i) the purpose,nature, and scale of the project; (ii) the duration of proposed projectactivities; (iii) any risks to and potential impacts on such communitiesand relevant mitigation measures; (iv) the envisaged stakeholderengagement process; and (v) the grievance mechanism.Compliance Status/ Findingsundertaken for this area to support the Community Relationship Plan.PARTIALLY COMPLIANTA public hearing will be held for the purpose of forest certification. TheForest Management Plan will be presented at the hearing and publicavailable at the company’s website.This item is rated partial because the public hearing was not held yet by thetime of this evaluation.Recommended further actionsProvide to affected community the following information during thehearing: the purpose, nature, and scale of the project; the duration of proposed project activities; any risks to and potential impacts on such communities andrelevant mitigation measures; the envisaged stakeholder engagement process; and the grievance mechanism.Consultation30. When Affected Communities are subject to identified risks and adverse PS 1, paragraph 30 and PARTIALLY COMPLIANTSystemize the stakeholder identification, consultation and engagementimpacts from a project, the client will undertake a process of31process, as described on Refer to PS1, paragraph 25.consultation in a manner that provides the Affected Communities with PS 8, paragraph 9 ELDORADO has the following initiatives to consultation:opportunities to express their views on project risks, impacts and For the purpose of social economic diagnosis, a sample of citizensmitigation measures, and allows the client to consider and respond towere interviewed to identify vulnerability of the region;them. The extent and degree of engagement required by the For the Inventory of Areas of High Biodiversity, stakeholders wereconsultation process should be commensurate with the project’s risksconsulted to identify the areas of high biodiversity important to theand adverse impacts and with the concerns raised by the Affectedcommunity and the use of it;Communities. Effective consultation is a two-way process that should: Neighbors of the lands were ELDORADO operates (owned lands,(i) begin early in the process of identification of environmental andleased lands and partnerships agreements) are identified throughsocial risks and impacts and continue on an ongoing basis as risks andPTEAS and information is provided by ELDORADO;impacts arise; (ii) be based on the prior disclosure and dissemination of As a result of the local vulnerabilities identified at the socialrelevant, transparent, objective, meaningful and easily accessibleeconomic diagnosis, local governmental representatives wereinformation which is in a culturally appropriate local language(s) andconsulted by ELDORADO to identify projects that could beformat and is understandable to Affected Communities; (iii) focussupported by ELDORADO;inclusive engagement on those directly affected as opposed to those A public hearing will be held for the purpose of forest certificationnot directly affected; (iv) be free of external manipulation, interference,The consultation process is not systemized and it was not defined frequencycoercion, or intimidation; (v) enable meaningful participation, whereof consultationapplicable; and (vi) be documented. The client will tailor itsconsultation process to the language preferences of the AffectedCommunities, their decision-making process, and the needs ofdisadvantaged or vulnerable groups. If clients have already engaged inNo consultation process has been carried out at Dois Irmaos do Buruti andAnastacio municipalities, were ELDORADO owns and operate lands.such a process, they will provide adequate documented evidence ofsuch engagement.Informed Consultation and Participation31. For projects with potentially significant adverse impacts on AffectedCommunities, the client will conduct an Informed Consultation andParticipation (ICP) process that will build upon the steps outlinedabove in Consultation and will result in the Affected Communities’informed participation. ICP involves a more in-depth exchange ofviews and information, and an organized and iterative consultation,leading to the client’s incorporating into their decision-making processthe views of the Affected Communities on matters that affect themdirectly, such as the proposed mitigation measures, the sharing ofdevelopment benefits and opportunities, and implementation issues.The consultation process should (i) capture both men’s and women’sviews, if necessary through separate forums or engagements, and (ii)reflect men’s and women’s different concerns and priorities aboutimpacts, mitigation mechanisms, and benefits, where appropriate. Theclient will document the process, in particular the measures taken toavoid or minimize risks to and adverse impacts on the AffectedCommunities, and will inform those affected about how their concernshave been considered.PS 1, paragraph 31 Refer to PS1, paragraph 30. Conduct the public hearing as planned..ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsIndigenous Peoples32. For projects with adverse impacts to Indigenous Peoples, the client isrequired to engage them in a process of ICP and in certaincircumstances the client is required to obtain their Free, Prior, andInformed Consent (FPIC). The requirements related to IndigenousPeoples and the definition of the special circumstances requiring FPICare described in Performance Standard 7.PS 1, paragraph 32Compliance Status/ FindingsPARTIALLY COMPLIANTAccording to ELDORADO, there is no indigenous or traditional people atELDORADO’s land. ERM did not identified indigenous or traditionalpeople in the lands visited or working for ELDORADO, which wasconfirmed by workers interviewed.A study undertook for the municipalities of Anastacio and Dois Irmaos doBuruti identified 7 indigenous land in the region, but it lacked to identifyimpacts of the operation on indigenous and traditional people located in theregion (more information on PS7). Potential impacts, if existing, will beidentified through the PTEAS, scheduled to June to December 2012.Recommended further actionsIdentify the influence of the operation at Dois Irmãos do Buruti andAnastacio municipalities over indigenous or traditional people through thePTEAS.In case impact on indigenous or traditional people is identified,ELDORADO must comply with the performance standard 7 and therecommendations described therein.Include impacted indigenous people’s representatives, if applicable, withinStakeholder Engagement Plan described in PS1, paragraph 25, 27.Indigenous people are not currently being engaged in the relationshipprocess undertook by ELDORADO.Private Sector Responsibilities Under Government-Led Stakeholder Engagement33. Where stakeholder engagement is the responsibility of the host PS 1, paragraph 33 NOT APPLICABLEgovernment, the client will collaborate with the responsiblegovernment agency, to the extent permitted by the agency, to achieveoutcomes that are consistent with the objectives of this PerformanceStandard. In addition, where government capacity is limited, the clientwill play an active role during the stakeholder engagement planning,implementation, and monitoring. If the process conducted by thegovernment does not meet the relevant requirements of thisPerformance Standard, the client will conduct a complementaryprocess and, where appropriate, identify supplemental actions.External Communications and Grievance MechanismsExternal Communications34. Clients will implement and maintain a procedure for externalcommunications that includes methods to (i) receive and registerexternal communications from the public; (ii) screen and assess theissues raised and determine how to address them; (iii) provide, track,and document responses, if any; and (iv) adjust the managementprogram, as appropriate. In addition, clients are encouraged to makepublicly available periodic reports on their environmental and socialsustainability.PS 1, paragraph 34 COMPLIANTThere is a form to register external communication from the public. Thequestionnaire is available at ELDORADO’s office in the cities of TresLagoas, Agua Clara, Silviria and Inocencia. The form is also available withrural supervisors and kept on the cars that take rounds on the farms.The form registers the name of the person, stakeholders category, reason forcontact, name of the person who receive the contact and action taken. Oncecomplete, the form is delivered a signed person from Social Area thatprovides feedback.Reportedly a public hearing will be held for certification purpose and theForest Management Plan will be presented and public available.Grievance Mechanism for Affected Communities35. Where there are Affected Communities, the client will establish agrievance mechanism to receive and facilitate resolution of AffectedCommunities’ concerns and grievances about the client’senvironmental and social performance. The grievance mechanismshould be scaled to the risks and adverse impacts of the project andhave Affected Communities as its primary user. It should seek toresolve concerns promptly, using an understandable and transparentconsultative process that is culturally appropriate and readilyaccessible, and at no cost and without retribution to the party thatoriginated the issue or concern. The mechanism should not impedeaccess to judicial or administrative remedies. The client will inform theAffected Communities about the mechanism in the course of thestakeholder engagement process.PS 1, paragraph 35PARTIALLY COMPLIANT There are two mechanism in place for grievance: The Program “Human Resouce in the field”, in which arepresentative from Human Resource visits workers in the fieldtwice a month, register workers complains. For more information,please see PS2, paragraph 20. A form to register external communication from the public.Community and neighbor might contact ELDORADO’s office ineach municipality, a telephone number, the supervisor of the farmor those responsible to perform rounds on the farms. The form isdelivered to the responsible person and included in a spreadsheetthat contains the name of the person, data, who received thecomplaint, a description of the complaint, action taken, feedbackand data. ERM reviewed the spreadsheet and it contained 13The grievance mechanism must be part of the Stakeholder Engagement Plan.Refer to PS1, paragraph 25.It is recommended to expand the disclosure on how community andstakeholders can complain to ELDORADO.ELDORADO should guarantee that the grievance mechanism for affectedcommunity contains the following: the grievance mechanism must be available to all stakeholders:workers (employee, contractors, suppliers), suppliers, affectedcommunity, and other significant categories identified byELDORADO; it shall be culturally appropriate, readily accessible to all workers,; it must be defined roles and responsibilities for receiving thegrievance and communication flow; it must also define the channel for provision of feedback and timeENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 1 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ Findingscomplains related to request of finance support to social programs,neighbor broken fence, measure to combat fire and ELDORADO’sworkers performing maintenance activities in a neighbor land.Recommended further actionsto do so;the mechanism should be able to receive and treat all grievances,including those related to security personnel abuses.Both mechanism have, a communication treatment Flow.Ongoing Reporting to Affected Communities36. The client will provide periodic reports to the Affected Communitiesthat describe progress with implementation of the project Action Planson issues that involve ongoing risk to or impacts on AffectedCommunities and on issues that the consultation process or grievancemechanism have identified as a concern to those Communities. If themanagement program results in material changes in or additions to themitigation measures or actions described in the Action Plans on issuesof concern to the Affected Communities, the updated relevantmitigation measures or actions will be communicated to them. Thefrequency of these reports will be proportionate to the concerns ofAffected Communities but not less than annually.PS 1, paragraph 36PARTIALLY COMPLIANTReportedly a public hearing will be held for certification purpose and theForest Management Plan will be presented and public available.Conduct the public hearing and to disclosure information about the Forestmanagement Plan.Develop a systematic approach to inform community about risk andimpacts. Refer to PS1, paragraph 25, for the Stakeholder Development Plan.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

Review against IFC Performance Standard 2 (Labor and Working Conditions)No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsWorking Conditions and Management of Worker RelationshipHuman Resources Policies and Procedures7. The client will adopt and implement human resources policies andprocedures appropriate to its size and workforce that set out itsapproach to managing workers consistent with the requirements of thisPerformance Standard and national law.8. The client will provide workers with documented information that isclear and understandable, regarding their rights under national laborand employment law and any applicable collective agreements,including their rights related to hours of work, wages, overtime,compensation, and benefits upon beginning the working relationshipand when any material changes occur.Working Conditions and Terms of Employment9. Where the client is a party to a collective bargaining agreement with aworkers’ organization, such agreement will be respected. Where suchagreements do not exist, or do not address working conditions andterms of employment, the client will provide reasonable workingPS 2, paragraph 7PS 2, paragraph 8Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).Federal Decree58.826/66 - Promulgatesthe ILO Convention 110:Worker's recruitmentLaw 9777/98 - Changeon the Law 2848/40(Criminal Code) -Labour rights: SlavelabourFederal Standard SIT76/09 - Rural workspolice: Workersrecruitment/transport.Union Conventionissued by the Federationof Rural Workers ofMato Grosso do Sul StatePS 2, paragraph 9Compliance Status/ FindingsPARTIALLY COMPLIANTThere is no human resource police that set out its approach to managingworkers as required by this Performance Standard.There is current a Policy for Remuneration that states the salaries andbenefits by professional category. This Policy is not available to theemployees and general public.There is also Policy for Training developed to be applied for industrial andrural workers, however, the policy has not being validated by the managersin charge of the forest activityELDORADO reported to be developing an ethical code.PRATIALLY COMPLIANTDuring the Inductions process, staff is provide with information associatedwith legal rights and other information about working conditions: workerspermit; working hours and working hours register; identification to accessthe site, legal absences, medical leave, salary and variable remuneration,payment conditions, vacations and benefits (medical assistance, lifeinsurance, alimentation, workers transportation). This was confirmed byworkers interviewed.Some workers interviewed reported not being aware about unionrepresentation and how to join the union. Information about freedom ofassociation is not included on the induction for rural workers.Workers documentation was reviewed and a contract was signed betweenELDORADO and the workers.ERM interviewed 16 workers and 10 workers hired by contractors.ELDORADO has currently 1556 workers on forest activities, 88% of them arerural workers, around 1370.PARTIALLY COMPLIANTThere is currently a Union Agreement with the Union of Rural Workers ofAndradina in place and Union Convention issued by the Federation ofRural Workers of Mato Grosso do Sul State.Recommended further actionsDevelop a Human Resource Policy, procedures or ethical code appropriateto the ELDORADO, to be applied for workers, contracted workers andsupply chain workers. The policy, procedures or ethical code shall cover allissues treated by this performance standard, as exemplified bellow: Working conditions: e.g physical environmental, health and safetyprecautions, treatment of workers, disciplinary practices, respect toworkers’s personal dignity (such as refraining from physicalpunishment or abusive language), terms of employment (wages,benefits, wage deduction, hours of work, breaks, rest days,overtime arrangement, overtime compensation, medical insurance,pension, and leave for illness, vacation, maternity and holiday. Collective bargain and freedom of association; Non discrimination and Equal Opportunity; Grievance mechanism; Child Labour; Forced Labour; Right to privacy about surveillance methods (being filmed andbody and personal belongs search) and personal data that will bekept and how will It be used.Workers must receive information about the policy, procedure ot ethicalcode. It is recommended to public disclosure it.Include on rural workers induction information about freedom ofassociation and union representation.Please see recommendation for PS2, paragraph 10, above.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsconditions and terms of employment.10. The client will identify migrant workers and ensure that they areengaged on substantially equivalent terms and conditions to nonmigrantworkers carrying out similar work.PS 2, paragraph 10Compliance Status/ FindingsUnion Convention issued by the Federation of Rural Workers of MatoGrosso do Sul State, clause 15, state that migrant workers shall not be hiredby third part on behalf of the company, in except of if the third part is aregular and formal company as defined by law. As reported bellow onparagraph 10 one worker reported that he was hired by a third part thatcharged him with a fee.NOT COMPLYINGELDORADO has currently 1556 workers, 88% of them are rural workers,around 1370. 37% of those are migrant workers from Maranhão, Piauí andBahia States.Term of conditions and employment are the same as those provided to localworkers: remuneration, overtime, hours of work, weekly rest, health andsafety, etc. Migrant workers are also represented by the local UnionAgreement.ELDORADO reported that workers are recruited by a third part contractedby ELDORADO named Multipla.ELDORADO’s contract with Multipla was revised and it contains a clause(page 4) that states that ELDORADO will pay 30% of the worker salary toMultipla, which will not be charged from the worker. The contract does notdetail the procedure to contract migrant workers.Recommended further actionsDevelop a procedure for the recruitment of migrant workers, including: Criteria for third part recruitment; Travel conditions for workers to and from their homes; Information that must be provided to workers before traveling.Monitor recruitment to guarantee compliance with the Brazilian legislation.Guarantee that the Declaration of the transport of Workers (CDTT) is issuedto all migrant workers travelling to Tres Lagoas or back to their origin.ELDORADO’s procedure to Employees Selection and Contraction(Procedure PCH RH 001 (00) states companies hired to recruit workers areforbidden to subcontract others to the recruitment process.ERM interviewed 9 migrant workers. One of them reported that he was notrecruited by Multipla but by a local man, who charged him a fee of R$150,00for the recruitment process. The charge of a fee from migrant workers is notcomplying with the ILO Convention 110, and the Federal Decree 58.826/66,that promulgates it, and Law 9777/98 and the Union Convention issued bythe Federation of Rural Workers of Mato Grosso do Sul State, clause 15.Three migrant workers reported that they traveled to Tres Lagoas in a busrented by ELDORADO and that they did not pay for the travel.ELDORADO reported that workers came on regular bus, and the travelexpenses were paid by ELDORADO. ELDORADO informed that it did notissue the Declaration of the transport of Workers (CDTT), which does notcomply with the Federal Standard SIT 76/09. This law states that thetransport of workers recruited to work in an area other than their origin shallbe communicated to Labour regional authority (SuperintendênciasRegionais do Trabalho- SRTE), SRTE through the Declaration of thetransport of Workers (CDTT). The enticement and transport of workers todifferent location of their origin is a crime under Art. 207 of the Penal Code.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsWorking Conditions and Terms of Employment11. Where accommodation services are provided to workers covered bythe scope of this Performance Standard, the client will put in place andimplement policies on the quality and management of theaccommodation and provision of basic services. The accommodationservices will be provided in a manner consistent with the principles ofnon-discrimination and equal opportunity. Workers’ accommodationarrangements should not restrict workers’ freedom of movement or ofassociation.PS 2, paragraph 11NR 31: RegulatoryStandard for Securityand Health of workers onagriculture, cattle rising,forest exploration andothers rural activitiesNR24: Sanitary andcomfort at the work placeDecree 3.298/99 -Regulates the Law7.853/89 on the NationalPolicy for the Integrationof Disabled Person.Compliance Status/ FindingsPARTIALLY COMPLIANTELDORADO is directly in charge of 3 accommodations for employeesdirectly hired by it. A company, named Foco, was hired to build andmanage the accommodation: (1) Accommodation Agua Clara, located atAgua Clara, has capacity for 340workers; (2) Accomodation Inocencia,located at Inocencia. has capacity for 180 workers.. Currently, there is a totalof 330 workers in both accommodations.The third accommodation is a house close to Accommodation Agua Clarathat has capacity for 40 workers. For the purpose of this report, will call thisaccommodation “Agua Clara II”.ERM visited the three accommodations. .At Accommodation Agua Clara II, 1 room had no window and does notcomply with NR31 and NR 24, paragraph 24.5.26Recommended further actionsEnsure that accommodations are in compliance with NR 31 and NR24.ELDORADO informed that there is no restriction to freedom of movementand workers can leave or enter the accommodation at any time. This wasconfirmed by workers interviewed at the accommodation .Workers’ Organizations12. In countries where national law recognizes workers’ rights to form andto join workers’ organizations of their choosing without interferenceand to bargain collectively, the client will comply with national law.Where national law substantially restricts workers’ organizations, theclient will not restrict workers from developing alternativemechanisms to express their grievances and protect their rightsregarding working conditions and terms of employment. The clientshould not seek to influence or control these mechanisms13. In either case described in paragraph 13 of this Performance Standard,and where national law is silent, the client will not discourage workersfrom electing worker representatives, forming or joining workers’organizations of their choosing, or from bargaining collectively, andwill not discriminate or retaliate against workers who participate, orseek to participate, in such organizations and collective bargaining. Theclient will engage with such workers’ representatives and workers’organizations, and provide them with information needed formeaningful negotiation in a timely manner. Workers’ organizations areexpected to fairly represent the workers in the workforce.PS 2, paragraph 12Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).PS 2, paragraph 13Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).COMPLIANTELDORADO’s rural workers are represented by the Federation of RuralWorkers of Mato Grosso do Sul State and the Union of Rural Workers ofAndradina.PARTIALLY COMPLIANTLDORADO reported that workers are informed about union contributionduring the induction. Some workers interviewed reported not beinginformed about possibility to join an union or union representation.NoneInclude at the rural workers induction and other training the informationabout union contacts and union agreementENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsNon-Discrimination and Equal Opportunity14 The client will not make employment decisions on the basis of personalcharacteristics unrelated to inherent job requirements. The client willbase the employment relationship on the principle of equalopportunity and fair treatment, and will not discriminate with respectto any aspects of the employment relationship, such as recruitment andhiring, compensation (including wages and benefits), workingconditions and terms of employment, access to training, jobassignment, promotion, termination of employment or retirement, anddisciplinary practices. The client will take measures to prevent andaddress harassment, intimidation, and/or exploitation, especially inregard to women. The principles of non-discrimination apply tomigrant workers.15. In countries where national law provides for non-discrimination inemployment, the client will comply with national law. When nationallaws are silent on non-discrimination in employment, the client willmeet this Performance Standard. In circumstances where national lawis inconsistent with this Performance Standard, the client is encouragedto carry out its operations consistent with the intent of paragraph 15above without contravening applicable laws.16. Special measures of protection or assistance to remedy pastdiscrimination or selection for a particular job based on the inherentrequirements of the job will not be deemed as discrimination, providedthey are consistent with national law.Retrenchment17. Prior to implementing any collective dismissals, the client will carryout an analysis of alternatives to retrenchment. If the analysis does notidentify viable alternatives to retrenchment, a retrenchment plan willbe developed and implemented to reduce the adverse impacts ofretrenchment on workers. The retrenchment plan will be based on theprinciple of non-discrimination and will reflect the client’s consultationwith workers, their organizations, and, where appropriate, thegovernment, and comply with collective bargaining agreements if theyexist. The client will comply with all legal and contractualrequirements related to notification of public authorities, and provisionof information to, and consultation with workers and theirorganizations.PS 2, paragraph 14Federal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).PS 2, paragraph 15PS 2, paragraph 15Decree 3.298/99 -Regulates the Law7.853/89 on the NationalPolicy for the Integrationof Disabled Person.Law 8069/90 - Establishthe Child and TeenagerStatuteFederal Decree 5.598/05 -Regulates theemployment ofapprentices and othermeasures.PS 2, paragraph 17Compliance Status/ FindingsPARTIALLY COMPLIANTERM’s limited interview with workers did not identify any discriminatorypractice performed by ELDORADO or its contractors.Currently, ELDORADO has not taken measures to prevent and addressdiscrimination in employment relationship, including harassment,intimidation and/or exploitation.PARTIALLY COMPLIANTELDORADO has recently hired a doctor to identify among workers thosethat have disability and if the company is in compliance with the Law 7.853that states a quota of 5% of workers with disability for companies with morethan 1,0000 workers.ELDORADO has not developed a plan or measure to achieve the quotadefined by law at operation phase.ELDORADO informed that there is no apprentice at the site, which is a notcompliance with the Apprentice Law 5.598/05 apprentices, state a quota forapprentices. However, the company sponsors the Program My First Job,that aims to provide technical training to almost 200 students of the localhigh schools. 50% of those participants shall be contracted by ELDORADO,which should be enough to meet the Law 5598 quota.Although NON COMPLIANT with Federal Decree 5.598/05, the measureundertaken seems to be sufficient to achieve compliance with thisrequirement in the future.Brazilian companies typically face difficulty in complying with both lawsNOT APPLICABLEERM did not identify any case that demanded reparation.NOT APPLICABLEELDORADO reported that they are in contracting phase and there are noplans for collective dismissal, therefore no retrenchment plan has beendeveloped.For migrant workers, ELDORADO provides their return to the city of origin.Recommended further actionsRefer to PS2, paragraph 7,that recommends aspects to be covered by theHuman Rights Policy.Take measures to prevent any harassment, including sexual harassment orpsychological mistreatment within the workplace, e.g: Include a module about harassment for leaders, managers andrural workers supervisors; Monitor and treat cases of harassment identified throughombudsman. Include on all workers induction information about harassment. Define measures and orient contractors to prevent discriminationin employment relationship.Identify total number of employees with disability and, if not sufficient tocomply with law 3298/99, to define measures to do so at operation phase.Define measure to comply with Apprentice Law.Prior to implementing any collective dismissals, the client should carry outan analysis of alternatives to retrenchment. Retrenchment means theelimination of a number of work positions or the dismissal or layoff of anumber of worker by an employer, generally by reason of plant closing orfor cost savings.The retrenchment plan should address costs and alternative solutions toretrenchment, e.g working time reduction programs, employee capacitybuilding programs, and other those proposed by employees and; otherstakeholders.If dismissal is unavoidable, the plan shall consider schedule of the dismissal,retrenchment methods and procedure, selection criteria, severancepayments, offers to alternative employment, job placement, etc.Selection criteria shall be objective, fair, transparent and based on nondiscrimination.Workers, government and relevant stakeholders shall be consulted to theplan development.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsRetrenchment19. The client should ensure that all workers receive notice of dismissaland severance payments mandated by law and collective agreementsin a timely manner. All outstanding back pay and social securitybenefits and pension contributions and benefits will be paid (i) on orbefore termination of the working relationship to the workers, (ii)where appropriate, for the benefit of the workers, or (iii) payment willbe made in accordance with a timeline agreed through a collectiveagreement. Where payments are made for the benefit of workers,workers will be provided with evidence of such payments.Grievance Mechanism20. The client will provide a grievance mechanism for workers (and theirorganizations, where they exist) to raise workplace concerns. The clientwill inform the workers of the grievance mechanism at the time ofrecruitment and make it easily accessible to them. The mechanismshould involve an appropriate level of management and addressconcerns promptly, using an understandable and transparent processthat provides timely feedback to those concerned, without anyretribution. The mechanism should also allow for anonymouscomplaints to be raised and addressed. The mechanism should notimpede access to other judicial or administrative remedies that mightbe available under the law or through existing arbitration procedures,or substitute for grievance mechanisms provided through collectiveagreements.Protecting the Work ForceChild Labor21. The client will not employ children in any manner that is economicallyexploitative, or is likely to be hazardous or to interfere with the child’seducation, or to be harmful to the child’s health or physical, mental,spiritual, moral, or social development. The client will identify thepresence of all persons under the age of 18. Where national laws haveprovisions for the employment of minors, the client will follow thoselaws applicable to the client. Children under the age of 18 will not beemployed in hazardous work. All work of persons under the age of 18will be subject to an appropriate risk assessment and regularmonitoring of health, working conditions, and hours of work.PS 2, paragraph 19NR 31: RegulatoryStandard for Securityand Health of workers onagriculture, cattle rising,forest exploration andothers rural activitiesPS 2, paragraph 21Federal Decree 5.598/05 -Regulates theemployment ofapprentices and othermeasures.Federal Decree 3.597/00Promulgate the 182 ILOConvention and 190 ILORecommendationconcerning the worstforms of child labour andimmediate action toeliminate them,convened in Geneva,June 17 1999.Federal Decree 4.134/02Promulgate the 138 ILOConvention and 146 ILORecommendation onminimum age foradmission toemployment.Decree 6.481/2008 -Compliance Status/ FindingsCOMPLIANTFor dismissal, ELDORADO identifies if the worker has any legal restrictionto be dismissal. Human resource personnel also evaluate with the managerthe reasons for the dismissal of the workers. ELDORADO is developing aPlan to Evaluate Workers Performance.For Workers Contractors, ELDORADO verifies on a monthly basesdocuments that probes that contractors have paid social security benefitsand contributions defined by Brazilian Law for dismissal proposes.COMPLIANTThere is a grievance mechanism for rural workers named “Human Resourcein the field”. A representative from Human Resource visit workers in thefield twice a month to register their demands. ERM reviewed a spreadsheetcontaining the name of the worker, complaint, feedback provided, and timeof response.COMPLIANTELDORADO informed that there is no worker under 18 years oldperforming any activity at the site. Copies of documents related tocontractor’s worker are verified by ELDORADO, for which they believethey are not in risk of child labour.ELDORADO sponsors the Regional Program to Combat the SexualExploration of Children, leaded by the Public Ministry for Children and theTrês Lagoas’ Network for the Protection of Children.This program is part of the workers induction providing information aboutchildren’s right.Recommended further actionsNoneNoneNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsRegulates Articles 3 and4 of the ILO Convention182 concerning the worstforms of child labour andimmediate action toeliminate them,convened in Geneva,June 17 1999.Satndard (InstruçãoNormativa) SIT n° 66/06- States on workinspection to combatchild labour and protectteenager work.Compliance Status/ FindingsRecommended further actionsForced Labor ForcedLaborThe client will not employ forced labor, which consists of any work orservice not voluntarily performed that is exacted from an individualunder threat of force or penalty. This covers any kind of involuntary orcompulsory labor, such as indentured labor, bonded labor, or similarlabor-contracting arrangements. The client will not employ traffickedpersons.Occupational Health and Safety23. The client will provide a safe and healthy work environment, takinginto account inherent risks in its particular sector and specific classes ofhazards in the client’s work areas, including physical, chemical,biological, and radiological hazards, and specific threats to women.The client will take steps to prevent accidents, injury, and diseasearising from, associated with, or occurring in the course of work byminimizing, as far as reasonably practicable, the causes of hazards. In amanner consistent with good international industry practice, asreflected in various internationally recognized sources including theWorld Bank Group Environmental, Health and Safety Guidelines, theclient will address areas that include the (i) identification of potentialhazards to workers, particularly those that may be life-threatening; (ii)provision of preventive and protective measures, includingmodification, substitution, or elimination of hazardous conditions orsubstances; (iii) training of workers; (iv) documentation and reportingof occupational accidents, diseases, and incidents; and (v) emergencyprevention, preparedness, and response arrangements. For additionalinformation related to emergency preparedness and response refer toPerformance Standard 1.PS 2, paragraph 22Law 9777/98 - Changeon the Law 2848/40(Criminal Code) - Labourrights: Slave labourPS 2, paragraph 23IFC General EHS –Occupational Health andsafetyCOMPLIANTELDORADO informed that the operation is not in risk of employment ofslave like conditions. All workers directly hired by ELDORADO are formalregistered and ELDORADO verifies the documentation of contractor’sworkers. This was evidenced by documents verification.ELDORADO informed that total hours of work are 8 plus 2 hours ofemployment commuting to work. The supervisor worker is in charge toregister working hours.Workers reported to perform overtime occasionally on Saturday, for whichovertime is paid.COMPLIANTERM visited workers in the field, working on eucalyptus plantation at BarraMansa farm. Bathrooms were available, as long as potable water, a coveredplace to have meals, in compliance with NR31.According to reviewed documents and information provided to ERMduring interviews with health and safety technicians and workers,ELDORADO is in compliance with this requirement. This was confirmed byvisual inspection of workers using adequate PPE and review of documentson field.ELDORADO informed that there were no occupational diseases amongworkers. ERM also could not identify studies that assessed potentialoccupational diseases.NoneNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsWorkers Engaged by Third Parties24. With respect to contracted workers the client will take commerciallyreasonable efforts to ascertain that the third parties who engage theseworkers are reputable and legitimate enterprises and have anappropriate ESMS that will allow them to operate in a mannerconsistent with the requirements of this Performance Standard, exceptfor paragraphs 18–19, and 27–29.25. The client will establish policies and procedures for managing andmonitoring the performance of such third party employers in relationto the requirements of this Performance Standard. In addition, theclient will use commercially reasonable efforts to incorporate theserequirements in contractual agreements with such third partyemployers.NR 31: RegulatoryStandard for Securityand Health of workers onagriculture, cattle rising,forest exploration andothers rural activitiesFederal Decree (DecretoLei) 5.452/43 -"Consolidação das Leisdo Trabalho" (CLT orLabour LawConsolidation).Compliance Status/ FindingsPARTIALLY COMPLIANTThere are 577 contractors workers hired by Plantar, J&S and Ruah toperform rural activities. ELDORADO developed a procedure (ContractsVerification Items - IVC) to verify contractors in relation to labour practice(over time, salary payment, registration of employees, etc), health and safety(PPE, water and food supply, safety signs, etc), and environmental(pesticides and environmental standards). The rural workers contractors areverified on a monthly basis and a report is issued for each verification. Incase the contractor is not complying with the items, a part of the contractorpayment is retained until compliance is achieved.Reportedly, ELDORADO’s practice is to verify contractor’s workersdocumentation and health and safety conditions in place and to revisedocumentation quarterly. The person in charge of the contractor monitorscontractor’s operational performance and legal fiscal requirements.Clearance certificate for fiscal workers payment are provided monthly.Recommended further actionsRefer to PS2, paragraph 7, that recommends aspects to be covered by theHuman ResourcesPolicy.Guarantee that contractor’s workers are provided with an induction,including information about freedom of association and collective bargain.Define measures and orient contractors on prevention of discrimination inemployment relationship, and harassment.There is no policy or procedure to monitoring the contractor performanceassociated with the other aspects of this performance standard, e.g nodiscrimination, equal of opportunity,, treatment of workers, etc.26. The client will ensure that contracted workers, covered in paragraphs24–25 of this Performance Standard, have access to a grievancemechanism. In cases where the third party is not able to provide agrievance mechanism the client will extend its own grievancemechanism to serve workers engaged by the third party.PS 2, paragraph 26ERM revised documentation of five workers from Plantar, four workersfrom J&S Florestal and three for Ruah and they were in compliance with theBrazilian legislation.PARTIALLY COMPLIANT Though its own grievance mechanism, ELDORADO registerscontractor’s workers complaints and direct it to the contract company. ELDORADO does not monitor or orient contractors (J&S, Plantar andRuah) on implementing a grievance mechanism.Guarantee that contractor’s workers are provided with a grievancemechanism (developed either by the contractor or by ELDORADO).Supply Chain27. Where there is a high risk of child labor or forced labor in the primarysupply chain, the client will identify those risks consistent withparagraphs 21 and 22 above. If child labor or forced labor cases areidentified, the client will take appropriate steps to remedy them. Theclient will monitor its primary supply chain on an ongoing basis inorder to identify any significant changes in its supply chain and if newrisks or incidents of child and/or forced labor are identified, the clientwill take appropriate steps to remedy them.PS 2, paragraph 27PARTIALLY COMPLIANT Wood SupplyERM visited one supplier of wood. The supplier owns a 20,000 hectare and2,000 hectares of wood were sold to ELDORADO to be harvested at 2012,2013 and 2014. ERM interviewed the farm owner..For contract purpose, ELDORADO requests the suppliers severaldocuments and clearance certification to identify legal risks associated withthe farm and the wood transaction. Those documents and certificates could,in thesis, demonstrate any judicial action against the farm due to childlabour or forced labour.Identify categories of significant suppliers in the primary supply chain inhigh risk of child labour and forced labor.Define measures to monitor significant suppliers on employment of childlabour and forced labour. The measures shall be defined according to thesuppliers risk. High risk suppliers shall be audited.For wood suppliers that are not FSC certified, the measure shall beconducted between the contract signature and the harvesting of the wood.For Vô Fiorino Farm and Buba, it is suggested to revise the contracts or toidentify other legal measure to include the clause that both parts will notemploy child or forced labour.The contract has a clause that states that both parts are responsible to avoidto employ child or forced labour.All harvesting activity will be performed by ELDORADO.The contract is signed 2 to 4 years before the harvesting and ELDORADOdoes not monitor suppliers during this period. Not monitoring woodsuppliers that are not FSC certified poses a risk to the company.Land SupplyELDORADO’s contract with land supply has a clause that states that bothparts are responsible to avoid the employment of child or forced labour. Thefarms Vô Fiorindo and Buba were leased by the company MMX and thenENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 2 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ Findingstransferred to ELDORADO. The contract signed by MMX and the farmersdoes not contain specific clause about child and forced labour. No othermeasure has been taken to identify and avoid the employment of child andforced labour by these land suppliers.At Buba Farm, ELDORADO leases part of the property, while the rest iscattle raising.Recommended further actionsSupply Chain28. Additionally, where there is a high risk of significant safety issuesrelated to supply chain workers, the client will introduce proceduresand mitigation measures to ensure that primary suppliers within thesupply chain are taking steps to prevent or to correct life-threateningsituations.29. The ability of the client to fully address these risks will depend uponthe client’s level of management control or influence over its primarysuppliers. Where remedy is not possible, the client will shift theproject’s primary supply chain over time to suppliers that candemonstrate that they are complying with this Performance Standard.PS 2, paragraph 28 and29COMPLIANTThere is no formal procedure to classify supplier’s risks, but primarysuppliers (contractors) are verified on contractual terms and through IVC, asexplained on paragraph 25.NoneReview against IFC Performance Standard 3 (Resource Efficiency and Pollution Prevention)No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandards4. During the project life-cycle, the client will consider ambientconditions and apply technically and financially feasible resourceefficiency and pollution prevention principles and techniques that arebest suited to avoid, or where avoidance is not possible, minimizeadverse impacts on human health and the environment. The principlesand techniques applied during the project life-cycle will be tailored tothe hazards and risks associated with the nature of the project andconsistent with good international industry practice (GIIP), as reflectedin various internationally recognized sources, including the WorldBank Group Environmental, Health and Safety Guidelines (EHSGuidelines).5. The client will refer to the EHS Guidelines or other internationallyrecognized sources, as appropriate, when evaluating and selectingresource efficiency and pollution prevention and control techniques forthe project. The EHS Guidelines contain the performance levels andmeasures that are normally acceptable and applicable to projects.When host country regulations differ from the levels and measurespresented in the EHS Guidelines, clients will be required to achievewhichever is more stringent. If less stringent levels or measures thanthose provided in the EHS Guidelines are appropriate in view ofspecific project circumstances, the client will provide full and detailedjustification for any proposed alternatives through the environmentaland social risks and impacts identification and assessment process.This justification must demonstrate that the choice for any alternateperformance levels is consistent with the objectives of this PerformanceStandard.PS 3, paragraphs 4 and 5Environmental, Healthand Safety GuidelinesCompliance Status/ FindingsPARTIALLY COMPLIANTThe Environmental Management System (EMS) developed by ELDORADOis described in more detail in Performance Standard 1 (paragraph 5).The forest and harvesting techniques used by ELDORADO are based onother pulp and paper mills’ experience in Brazil and mainly in the region.The documentation regarding the EMS does not mention any EHSInternational Guideline.The analysis of environmental impacts related to the forest management wasperformed at two levels:a) Analysis of the EMS Guidelines and Procedures: ELDORADO performed a preliminary impact assessment (PoyrySilviconsult) in order to evaluate the environmental impacts associatedwith the forest activities. However, this study is not fully compliant withrisks and impacts identification process as required in PS 1; ELDORADO has developed an EMS that encompasses procedures andmeasures to control and minimize the environmental impacts of it isoperations.; ELDORADO is committed to develop and execute a PTEAS – Economic,Environmental and Social Technical Project (Projeto Técnico Econômico,Ambiental e Social) prior to any major intervention on its properties(harvest or plantation). This procedure is intended to provide an actionplan to mitigate economic, environmental and social impacts tailored foreach farm. ELDORADO established guidelines to prevent the use of areas withnative forests, legally protected areas (APP) and/or legal reserves. Theseguidelines are being applied on farms visited by ERM.Recommended further actionsELDORADO should apply the PTEAS procedure to all lands prior to theintervention (planting and harvesting). For the lands where intervention(plantation) has already occurred and no PTEAS undertaken, ELDORADOshould conduct the PTEAS considering impacts already caused by theactivity described by this performance standard (PS3).ELDORADO should also improve the EMS efficiency regarding thefollowing programs:1 – Waste Management Program2 – Hazardous Material Program3 – Monitoring and Documentation ProgramENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ FindingsRecommended further actionsThe issues of the EMS guidelines and procedures are related to: The elaboration and application of the PTEAS is still restricted to fewfarms. It was not observed a systematic and comprehensive monitoringdocumentation system.b) Efficiency of the EMS procedures:1 – Critical issues: Waste management: ERM observed issues related to the implementationof the waste management program – see PS 3 Paragraph 12. Hazardous material management: ERM observed issues related to theimplementation of the waste management program – see PS 3 Paragraph13.2 – Non-critical issues: Water management: ERM did not observed issues related to the watermanagement program – see PS 3 Paragraph 9.Resource Efficiency6. The client will implement technically and financially feasible and costeffective measures for improving efficiency in its consumption ofenergy, water, as well as other resources and material inputs, with afocus on areas that are considered core business activities. Suchmeasures will integrate the principles of cleaner production intoproduct design and production processes with the objective ofconserving raw materials, energy, and water. Where benchmarkingdata are available, the client will make a comparison to establish therelative level of efficiency.Greenhouse Gases7. In addition to the resource efficiency measures described above, theclient will consider alternatives and implement technically andfinancially feasible and cost-effective options to reduce project-relatedGHG emissions during the design and operation of the project. Theseoptions may include, but are not limited to, alternative projectlocations, adoption of renewable or low carbon energy sources,sustainable agricultural, forestry and livestock management practices,the reduction of fugitive emissions and the reduction of gas flaring.8. For projects that are expected to or currently produce more than 25,000tonnes of CO2-equivalent annually, the client will quantify directemissions from the facilities owned or controlled within the physicalproject boundary, as well as indirect emissions associated with the offsiteproduction of energy used by the project. Quantification of GHGemissions will be conducted by the client annually in accordance withinternationally recognized methodologies and good practice.Water Consumption9. When the project is a potentially significant consumer of water, inaddition to applying the resource efficiency requirements of thisPerformance Standard, the client shall adopt measures that avoid orreduce water usage so that the project’s water consumption does nothave significant adverse impacts on others. These measures include,but are not limited to, the use of additional technically feasible waterconservation measures within the client’s operations, the use ofalternative water supplies, water consumption offsets to reduce totaldemand for water resources to within the available supply, andevaluation of alternative project locations.PS 3, paragraph 6PS 3, paragraph 7 and 8PS 3, paragraph 9COMPLIANTSee PS3 Paragraphs 4 and 5.PARTIALLY COMPLIANTThe company presented the calculation of carbon sequestration in relation tothe area planted with eucalyptus. The company did not provide documentsrelating to inventory of Greenhouse Gases (GHG) as an energy balance of theproject.The project includes the use of fossil fuel sources and will result in emissionof greenhouse gases.NOT APPLICABLEReportedly, the activity is not a significant net consumer of water, orcontributes to depletion of water resources to the extent that third parties’ability to access water is adversely affected. No evidence was provided inorder to check the statement.In terms of water management, it is worth to mention: The state environmental agency does not require special permit to usewater from surface or underground sources. There is low demand for water use on forest activities at the visited farms.The company should quantify GHG emissions, not only carbonsequestration, but also emissions, as the first step in managing andultimately reducing emissions in a cost-effective manner, as required byPerformance Standard 3.The company must perform a GHG emissions inventory (scope 1 for ownsources and scope 2 for energy consumption), considering current andfuture activities. It is suggested to follow the IPCC (Intergovernmental Panelon Climate Change) methodology.Develop assessment of whether the project is a significant consumer ofwater and the impacts of this consumption.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ FindingsELDORADO prioritizes the forest plantation on rain season in order todecrease the use of this resource There is no irrigation system implemented or planned at the planted areas There is a low production of organic effluent at the farms. Mature forestplantation does not require constant maintenance; therefore, humanactivities in those farms are not constant.Recommended further actionsPollution Prevention10. The client will avoid the release of pollutants or, when avoidance is notfeasible, minimize and/or control the intensity and mass flow of theirrelease. This applies to the release of pollutants to air, water, and landdue to routine, non-routine, and accidental circumstances with thepotential for local, regional, and transboundary impacts. Wherehistorical pollution such as land or ground water contamination exists,the client will seek to determine whether it is responsible for mitigationmeasures. If it is determined that the client is legally responsible, thenthese liabilities will be resolved in accordance with national law, orwhere this is silent, with GIIP.11. To address potential adverse project impacts on existing ambientconditions, the client will consider relevant factors, including, forexample (i) existing ambient conditions; (ii) the finite assimilativecapacity of the environment; (iii) existing and future land use; (iv) theproject’s proximity to areas of importance to biodiversity; and (v) thepotential for cumulative impacts with uncertain and/or irreversibleconsequences. In addition to applying resource efficiency andpollution control measures as required in this Performance Standard,when the project has the potential to constitute a significant source ofemissions in an already degraded area, the client will consideradditional strategies and adopt measures that avoid or reduce negativeeffects. These strategies include, but are not limited to, evaluation ofproject location alternatives and emissions offsets.Wastes12. The client will avoid the generation of hazardous and non-hazardouswaste materials. Where waste generation cannot be avoided, the clientwill reduce the generation of waste, and recover and reuse waste in amanner that is safe for human health and the environment. Wherewaste cannot be recovered or reused, the client will treat, destroy, ordispose of it in an environmentally sound manner that includes theappropriate control of emissions and residues resulting from thehandling and processing of the waste material. If the generated wasteis considered hazardous, the client will adopt GIIP alternatives for itsenvironmentally sound disposal while adhering to the limitationsapplicable to its transboundary movement. When hazardous wastedisposal is conducted by third parties, the client will use contractorsthat are reputable and legitimate enterprises licensed by the relevantgovernment regulatory agencies and obtain chain of custodydocumentation to the final destination. The client should ascertainwhether licensed disposal sites are being operated to acceptablestandards and where they are, the client will use these sites. Where thisis not the case, clients should reduce waste sent to such sites andconsider alternative disposal options, including the possibility ofdeveloping their own recovery or disposal facilities at the project site.PS 3, paragraph 10 and11General EHS GuidelinesPS 3, paragraph 12CONAMA Resolution307/2002 establishprocedures for theconstruction wastemanagement;CONAMA Resolution313/2002, regulates theState and federalindustrial WasteManagement Plan;CONAMA Resolution348/2004 includesasbestos as hazardouswastes.Brazilian StandardABNT 12235, establishesrequirements for thehazardous waste storageareas.IFC General EHS – WastemanagementIFC Integrated Steel MillEHS – Solid WasteCOMPLIANTDuring site visit, it was reported that there is a procedure for handlingpossible contaminated soil with oil or other residues that might accidentallyleak from equipment maintenance on field. This procedure was confirmed bymaintenance staff during field inspection and consists on collecting thecontaminated soil, storing it in bags and requesting a third party company toadequately collect it and dispose.Relating to air pollution prevention, ELDORADO has provided thefollowing procedures: Determining the degree of black smoke emitted by stationary sources andvehicles powered by diesel oil; Preventive and corrective maintenance of equipment, vehicles andmachinery; In relation to waste handling for pollution prevention see PS 3, paragraph12. Refer to PS 3, paragraphs 13 – 17.PARTIALLY COMPLIANTCompliant procedures: Sanitary waste from chemical bathrooms temporarily installed on thefarms for field work is buried on ground along with organic waste. ERM was not able to evidence any hazardous waste storedinappropriately. Currently there are 5 companies responsible forcollecting used oil, Class I and II waste (according NBR 10004), healthcarewaste, recyclable material, empty pesticide containers and clothes used toapply pesticides. These companies are responsible to transport to finaldisposal in proper landfills the waste (Permits are listed in the documentlist). Spreadsheet for waste permitting control has been provided during sitevisits. A procedure for waste handling and also a Plan for Solid WasteManagement were provided. Information has been provided regarding Waste Transfer Permits issuedby State Environmental Agency that the site holds.Non-compliant procedures: Waste handling: during the site visits, it was observed that some types ofwaste were not adequately handled in the farms. The major issue isrelated to the aluminum disposable dishes provided to the workers aspart of their daily meal, which sometimes were disposed in an improperImprove the Waste Management Program in order to accomplish thefollowing goals: Verify if the licensed disposal sites are being operated to acceptablestandards. Develop a program to reduce waste sent to disposal sites or alternativedisposal options, including the possibility of developing their ownrecovery or disposal facilities at the project site. Improve the efficiency of the waste management procedures in order toavoid the problems identified in the site visits regarding the wastehandling and collection.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsHazardous Materials Management13. Hazardous materials are sometimes used as raw material or producedas product by the project. The client will avoid or, when avoidance isnot possible, minimize and control the release of hazardous materials.In this context, the production, transportation, handling, storage, anduse of hazardous materials for project activities should be assessed.The client will consider less hazardous substitutes where hazardousmaterials are intended to be used in manufacturing processes or otheroperations. The client will avoid the manufacture, trade, and use ofchemicals and hazardous materials subject to international bans orphase-outs due to their high toxicity to living organisms,environmental persistence, potential for bioaccumulation, or potentialfor depletion of the ozone layer.PS 3, paragraph 13PS 4, paragraph 7IFC General EHS –Hazardous MaterialsManagement;EHS Guidelines forForest HarvestingOperationsCompliance Status/ Findingsmanner. Waste collection: it was reported that, in some cases, the general waste ofthe farms was transported to the final waste disposal site by contractor’sstuff, and therefore, not following the Waste Management guidelines. ELDORADO has not provided information on whether licensed disposalsites are being operated to acceptable standards or a possible program toreduce waste sent to such sites or alternative disposal options.PARTIALLY COMPLIANTCompliant procedures: During site visit ERM was not able to identify possible sources ofPolychlorinated Biphenyl (PCBs) in electrical equipment, asbestoscontaining materials. However inside the offices there is use of airconditioning that could be a potential source of ozone depletingsubstances in refrigeration systems. Reportedly all transport of hazardous materials is held by licensedcompanies. The application of herbicides (Gliphosate) is performed by trainedemployees. It was also observed that all the EHS procedures are in placeduring the application of this product, including the use of appropriatepersonal protective equipments. The use of persistent organic pollutants is not allowed. The pesticidesused at the forestry activities were checked and are not listed in theStockholm convention, which entered into force on 17 May, 2004, withsubsequent amendments. See http://www.pops.int/ and PS 3 paragraph14 to 17. Evidences show that ELDORADO and contractor’s personnel follow theguidelines regarding the triple wash procedures of herbicides containersRecommended further actionsProvide additional, detailed information on hazardous materials to be usedthroughout the different project stages:• volumes;• characteristics/ MSDS;• handling and storage; and• chemicals storage locations.ELDORADO must inform if the current plant manipulates or uses asbestoscontaining materials, PCBs and ozone depleting substances, amounts andmeasures to reduce the use. Maintenance area must have adequatehazardous material storage, with secondary containment or drainage toavoid leakages on soil and water bodies.In addition, ELDORADO must improve the efficiency of the HazardousMaterial Management Program in order to fix the issues indicated as noncompliantproceduresNon-compliant procedures:During the site visits at the farms, it was verified the following issues relatedto the handling, storage and final destination of hazardous materials:a) Storage of Chemical and Hazard Materials:The chemical storage facilities (central warehouses) were implemented instrategic farms in order to facilitate the distribution of agricultural inputs(e.g. fertilizers, herbicides, anticides etc ) to nearby forest plantation sites. Theissues related to the operation of these warehouses are: In one warehouse were identified expired products, open and/or violatedpackages, exposed chemical materials, used products, hazardous and nonhazardous waste. At the same location was observed a wet floor, probablyderived from rain water entering through the ventilation openings. The chemical inventory control system is not efficient. There are nodocuments at these places informing the amount or type of storedproducts. The inventory control is basically done by the contractor’s stuffwhen the product is being used at the forest plantation sites The warehouse has no access restricted to qualified personnel. Anyonecan access and manipulate the products. Even though there is a central warehouse, it was observed chemical andhazard products stored at inadequate places in other farms. According to evidence on site visit, hazardous products (paint thinner andoil for example) from maintenance on cultivation of eucalyptus fields arestored inadequately. The floor is not paved, there is no secondarycontainment or drainage to avoid leakage directly on soilENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ Findingsb) Transport of Chemical and Hazard Materials from central warehouses tothe forest plantation sites The transport of hazardous and chemicals materials is performed bycontractor’s personnel. It was reported that the contractor’s personneldoes not hold the Emergency Preparedness and Response Plan during thetransportation of these products. ERM did not verify the transport operation of these productsRecommended further actionsc) Temporarily hazard waste disposal facilities It was not observed the use of adequate storage facilities to storetemporarily the used herbicides containers. There is no clear definition onhow or where to store these containers. In one farm, misinformation wasprovided regarding the location of this facility.Pesticide Use and Management14. The client will, where appropriate, formulate and implement anintegrated pest management (IPM) and/or integrated vectormanagement (IVM) approach targeting economically significantpest infestations and disease vectors of public health significance.The client’s IPM and IVM program will integrate coordinated useof pest and environmental information along with available pestcontrol methods, including cultural practices, biological, genetic,and, as a last resort, chemical means to prevent economicallysignificant pest damage and/or disease transmission to humansand animals.15. When pest management activities include the use of chemicalpesticides, the client will select chemical pesticides that are low inhuman toxicity, that are known to be effective against the targetspecies, and that have minimal effects on non-target species andthe environment. When the client selects chemical pesticides, theselection will be based upon requirements that the pesticides bepackaged in safe containers, be clearly labelled for safe and properuse, and that the pesticides have been manufactured by an entitycurrently licensed by relevant regulatory agencies.16. The client will design its pesticide application regime to (i) avoiddamage to natural enemies of the target pest, and whereavoidance is not possible, minimize, and (ii) avoid the risksassociated with the development of resistance in pests and vectors,and where avoidance is not possible minimize. In addition,pesticides will be handled, stored, applied, and disposed of inaccordance with the Food and Agriculture Organization’sInternational Code of Conduct on the Distribution and Use ofPesticides or other GIIP.17. The client will not purchase, store, use, manufacture, or trade inproducts that fall in WHO Recommended Classification ofPesticides by Hazard Class Ia (extremely hazardous); or Ib (highlyhazardous). The client will not purchase, store, use, manufactureor trade in Class II (moderately hazardous) pesticides, unless theproject has appropriate controls on manufacture, procurement, ordistribution and/or use of these chemicals. These chemicalsshould not be accessible to personnel without proper training,equipment, and facilities to handle, store, apply, and dispose ofPS 3, paragraphs 14 to 17EHS Guidelines forForest HarvestingOperationsd) Final hazard waste destination Reportedly all hazardous waste is not stored and immediately collectedby the respective contracted company for final disposal. In one farm, itwas verified that the hazard waste collection never happened, where itwas possible to count more than 200 used containers at the same place.COMPLIANTThe main products used at the forestry activities are listed below. ERMconsulted the MSDS – material safety data sheet of the materials and also thedocument “The WHO – World Health Organization RecommendedClassification of Pesticides by Hazard and Guidelines to Classification 2009”to verify the classification of the substance. Table below also shows theclassification.ProductTrop orRoundupOriginalFordor750WGEvidence700WGAtta Mexe Mirex SFertiliser(10-27-10)Fertiliser(13-00-28)ActiveingredientGliphosateIsoxaflutolImidaclopridoFunctionControl ofweedControl ofweedTermitecontrolWHOClassification*III, page 71IIIII, page 78Sulfluramide Ant control II, page 76- Fertiliser ** **- Fertiliser ** **DL50oral,for rat,>6000mg/kg-sourceMSDSdermal,for rat,>2000mg/kg-sourceMSDSdermal,for rat,>2000mg/kg-sourceMSDSNone.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 3 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ Findingsthese products properly. MAP - Fertiliser ** **AtumusandAcquafolHB10,Soilfix,HyCLimestoneandplaster-Waterconditioner** **- Polymer ** **-Soilcorrection** *** World Health Organization pesticide classificationIa = Extremely hazardous; Ib = Highly hazardous; II = Moderatelyhazardous; III = slightly hazardous; U = Unlikely to present acute hazard innormal use; FM = Fumigant, not classified; O = Obsolete as pesticide, notclassified.** Non toxic products.According to the consulted information no chemical substance used in theELDORADO forestry activities are classified as extremely hazardous orhighly hazardous by the WHO.However, Atta Mex/ Mirex and Evidence are classified as moderatelyhazardous and for these products appropriate controls are necessary such as:should not be accessible to personnel without proper training, equipment,and facilities to handle, store, apply, and dispose of these products properly.During the site visit ERM was informed that these products are handled by athird party company. Reportedly employees use proper PPEs and are trainedfor handling pesticides. ERM did not observe during the visit the transport ofthis material.Evidence has been provided of the Application and Handling of PesticidesTraining (See document list)Recommended further actionsReview against IFC Performance Standard 4 (Community Health, Safety, and Security)No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCommunity Health and Safety5. The client will evaluate the risks and impacts to the health and safety ofthe Affected Communities during the project life-cycle and willestablish preventive and control measures consistent with goodinternational industry practice (GIIP), such as in the World BankGroup Environmental, Health and Safety Guidelines (EHS Guidelines)or other internationally recognized sources. The client will identifyrisks and impacts and propose mitigation measures that arecommensurate with their nature and magnitude. These measures willfavor the avoidance of risks and impacts over minimization.PS 4, paragraph 5EHS GuidelinesForesting HarvestingOperations item 1.3Compliance Status/ FindingsPARTIALLY COMPLIANTThe increase of transport flow on the inhabitant areas are assessed andcommunity is informed about it. The PTEAS will also support theidentification of increase of transportation flow on public road.The plan for wood transportation is not developed and it should besupported by the PTEAS carried out before harvesting.There is a system to combat fire in place (fire brigade). Neighbors and localgovernment are informed on how to contact the fire brigade in case of fire.Recommended further actionsInclude workers providing transportation services on educational programsrelated to STIs and prevention of fatalities and injuries.Develop the transportation plan considering avoiding impacts oncommunity health and safety, as identified by PTEAS.There are measures in place to manage waste and to avoid dissemination ofwater-borne and endemic disease (as leishmaniasis and dengue).ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ FindingsThe assessment of public health as detailed on these performance standardsis not commonly requested on license process.Recommended further actionsELDORADO is involving in the following programs/action: participating with the health surveillance system on a program tocombat leishmaniasis; provision of information about Sexual Transmitted Illness (STIs) toworkers as part of the Program for Public Health and Safety; support the Tres Lagoas municipality to monitor Dengue and todefine measures to minimize the transition of the disease; To promote vaccination for influenza to all workers.As defined by law, ELDORADO promotes awareness programs to workersabout alcoholism, smoking, besides, monitoring workers occupational healththrough medical examinations.The social diagnosis assessment undertaken for the 7 municipalities were themain farms are located indicates as the main vulnerability the lack ofappropriate health public facilities. ELDORADO has met with publicauthorities to discuss local facility, areas that must be improved and projectsthat could be supported by ELDORADO. Minutes of these meetings werereviewed by ERM.Infrastructure and Equipment Design and Safety6. The client will design, construct, operate, and decommission the PS 4, paragraph 6 NOT APPLICABLEstructural elements or components of the project in accordance withGIIP, taking into consideration safety risks to third parties or AffectedCommunities. When new buildings and structures will be accessed bymembers of the public, the client will consider incremental risks of thepublic’s potential exposure to operational accidents and/or naturalhazards and be consistent with the principles of universal access.Structural elements will be designed and constructed by competentprofessionals, and certified or approved by competent authorities orprofessionals. When structural elements or components, such as dams,tailings dams, or ash ponds are situated in high-risk locations, andtheir failure or malfunction may threaten the safety of communities,the client will engage one or more external experts with relevant andrecognized experience in similar projects, separate from thoseresponsible for the design and construction, to conduct a review asearly as possible in project development and throughout the stages ofproject design, construction, operation, and decommissioning. Forprojects that operate moving equipment on public roads and otherforms of infrastructure, the client will seek to avoid the occurrence ofincidents and injuries to members of the public associated with theoperation of such equipment.Hazardous Materials Management and Safety7. The client will avoid or minimize the potential for communityexposure to hazardous materials and substances that may be releasedby the project. Where there is a potential for the public (includingworkers and their families) to be exposed to hazards, particularly thosethat may be life-threatening, the client will exercise special care toavoid or minimize their exposure by modifying, substituting, orPS 4, paragraph 7PS 3, paragraph 13 and14IFC General EHS –Hazardous MaterialsManagement;See PS 3, paragraphs 13 and 14eliminating the condition or material causing the potential hazards. EHS Guidelines forWhere hazardous materials are part of existing project infrastructure or Forest Harvestingcomponents, the client will exercise special care when conducting Operationsdecommissioning activities in order to avoid exposure to theNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardscommunity. The client will exercise commercially reasonable efforts tocontrol the safety of deliveries of hazardous materials, and oftransportation and disposal of hazardous wastes, and will implementmeasures to avoid or control community exposure to pesticides, inaccordance with the requirements of Performance Standard 3.Ecosystem Services8. The project’s direct impacts on priority ecosystem services may result inadverse health and safety risks and impacts to Affected Communities. Withrespect to this Performance Standard, ecosystem services are limited toprovisioning and regulating services as defined in paragraph 2 ofPerformance Standard 6. For example, land use changes or the loss ofnatural buffer areas such as wetlands, mangroves, and upland forests thatmitigate the effects of natural hazards such as flooding, landslides, and fire,may result in increased vulnerability and community safety-related risksand impacts. The diminution or degradation of natural resources, such asadverse impacts on the quality, quantity, and availability of freshwater,may result in health-related risks and impacts. Where appropriate andfeasible, the client will identify those risks and potential impacts on priorityecosystem services that may be exacerbated by climate change. Adverseimpacts should be avoided, and if these impacts are unavoidable, the clientwill implement mitigation measures in accordance with paragraphs 24 and25 of Performance Standard 6. With respect to the use of and loss of accessto provisioning services, clients will implement mitigation measures inaccordance with paragraphs 25–29 of Performance Standard 5.Community Exposure to Disease9. The client will avoid or minimize the potential for communityexposure to water-borne, water-based, water-related, and vector-bornediseases, and communicable diseases that could result from projectactivities, taking into consideration differentiated exposure to andhigher sensitivity of vulnerable groups. Where specific diseases areendemic in communities in the project area of influence, the client isencouraged to explore opportunities during the project life-cycle toimprove environmental conditions that could help minimize theirincidence.10. The client will avoid or minimize transmission of communicablediseases that may be associated with the influx of temporary orpermanent project labor.Emergency Preparedness and Response11. In addition to the emergency preparedness and response requirementsdescribed in Performance Standard 1, the client will also assist andcollaborate with the Affected Communities, local government agencies,and other relevant parties, in their preparations to respond effectivelyto emergency situations, especially when their participation andcollaboration are necessary to respond to such emergency situations. Iflocal government agencies have little or no capacity to respondeffectively, the client will play an active role in preparing for andresponding to emergencies associated with the project. The client willdocument its emergency preparedness and response activities,resources, and responsibilities, and will disclose appropriateinformation to Affected Communities, relevant government agencies,or other relevant parties.PS 4, paragraph 8EHS Guidelines forForest HarvestingOperationsCompliance Status/ FindingsRefer to PS 6, paragraphs 6 and 7PS 9, paragraph 9 and 10 Refer to PS4, paragraph 5.PS 4, paragraph 10 Refer to PS4, paragraph 5.PS 4, paragraph 11General EHS GuidelinesEHS Guidelines forForest HarvestingOperationsCOMPLIANTThe company has provided copy of their Emergency Plan procedure. Itassess:-Leaks and spills of fuels and oils-Leaks and spills of pesticides in water-Forest fires-Disruption of landfill-Damage to the flora of permanent preservation areas and legal reserves-Material damage-Accident with injury or sudden illness.Also a system is in place for fire emergency. Workers are informed onemergency behavior in case of fire, there is telephone for emergency andthere are cars for fire combat available. Record of firefighting training waspresented for Três Lagoas unit. (See document list).The emergency plan addresses on how information is disclosed toaffected communities, relevant government agencies or other relevantparties.One of the contractors (Ruah) reported not being aware of the EmergencyProcedure although he reported to know the general actions in case ofemergency.Recommended further actionsNone.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 4 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsSecurity Personnel12. When the client retains direct or contracted workers to provide securityto safeguard its personnel and property, it will assess risks posed by itssecurity arrangements to those within and outside the project site. Inmaking such arrangements, the client will be guided by the principlesof proportionality and good international practice in relation to hiring,rules of conduct, training, equipping, and monitoring of such workers,and by applicable law. The client will make reasonable inquiries toensure that those providing security are not implicated in past abuses;will train them adequately in the use of force (and where applicable,firearms), and appropriate conduct toward workers and AffectedCommunities; and require them to act within the applicable law. Theclient will not sanction any use of force except when used forpreventive and defensive purposes in proportion to the nature andextent of the threat. The client will provide a grievance mechanism forAffected Communities to express concerns about the securityarrangements and acts of security personnel.PS 4, paragraph 12Compliance Status/ FindingsPARTIALLY COMPLIANTAt most of the farms there are no security personnel but workers whoperform rounds to identify fires and infestations.The procedure PO-SIL-008 defines qualification of workers to perform theround, what is to be identified during the round and communication flow incase of an event is identified.Security personnel are provided at the accommodation by a third partcompany named Apolo Segurança Privada, hired by Foco. Foco providedevidence of Apolo certificate to operate, issued by the federal police, and thecertificate that authorizes one worker to provide security issued by acertificated school.At the farm Correntes there are security personnel hired by the previousowner of the land (the company MMX). ERM interviewed the securityworking and documentation was according to Brazilian legislation.Recommended further actionsEnsure the grievance a procedure and Stakeholder Engagement Plan (PS1Paragh 25) are designed to identify any concerns from local government,communities and workers regarding security activities.Define procedures on the correct code of conduct and use of the force bysecurity personnel. This shall include measures to investigate and addressany complaints regarding potential human right abuses committed by thoseproviding security.Monitor those providing security arrangement to identify compliance withthe above mentioned procedures.13. The client will assess and document risks arising from the project’s useof government security personnel deployed to provide securityservices. The client will seek to ensure that security personnel will actin a manner consistent with paragraph 12 above, and encourage therelevant public authorities to disclose the security arrangements for theclient’s facilities to the public, subject to overriding security concerns.Security Personnel14. The client will consider and, where appropriate, investigate allallegations of unlawful or abusive acts of security personnel, takeaction (or urge appropriate parties to take action) to preventrecurrence, and report unlawful and abusive acts to public authorities.ELDORADO reported that they do not to monitor security arrangements.PS 4, paragraph 13 NOT APPLICABLEPS 4, paragraph 14PARTYALLI COMPLIANTThere is grievance mechanism to workers in place that could receivecomplaint about security personnel abuses. ELDORADO informed that allgrievances received are treated and investigated. If the abuse or inadequatebehavior is proved, the person providing security might be removed toanother position or dismissed.ELDORADO has no procedure to investigate and treat cases of human rightabuses, if committed by those providing security personnel, neither tocommunicate public authority about it.Refer to PS4, paragraph 12Review against IFC Performance Standard 5 (Land Acquisition and Involuntary Resettlement)No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsGeneralProject Design8. The client will consider feasible alternative project designs to avoid or PS 5, paragraph 8 to32minimize physical and/or economic displacement, while balancingenvironmental, social, and financial costs and benefits, payingparticular attention to impacts on the poor and vulnerable.Compliance Status/ FindingsCOMPLIANTELDORADO informed the farm acquired and leased are voluntary landtransactions. It was also reported that ELDORADO seeks land whichprevious land use is cattle rising or eucalyptus plantation. Thus,ELDORADO informed that no physical resettlement was undertaken.For land transaction ELDORADO verifies land documentation to identifyany restriction to the land transaction, which includes land documentationand land and owner clearance certificate at federal justice, labour justice, etc.Recommended further actionsNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompensation and Benefits for Displaced Persons9. When displacement cannot be avoided, the client will offer displacedcommunities and person’s compensation for loss of assets at fullreplacement cost and other assistance to help them improve or restoretheir standards of living or livelihoods, as provided in this PerformanceStandard. Compensation standards will be transparent and appliedconsistently to all communities and persons affected by thedisplacement. Where livelihoods of displaced persons are land-based,or where land is collectively owned, the client will, where feasible,offer the displaced land-based compensation. The client will takepossession of acquired land and related assets only after compensationhas been made available and, where applicable, resettlement sites andmoving allowances have been provided to the displaced persons inaddition to compensation. The client will also provide opportunities todisplaced communities and persons to derive appropriate developmentbenefits from the project.Community Engagement10. The client will engage with Affected Communities, including hostcommunities, through the process of stakeholder engagementdescribed in Performance Standard 1. Decision-making processesrelated to resettlement and livelihood restoration should includeoptions and alternatives, where applicable. Disclosure of relevantinformation and participation of Affected Communities and personswill continue during the planning, implementation, monitoring, andevaluation of compensation payments, livelihood restoration activities,and resettlement to achieve outcomes that are consistent with theobjectives of this Performance Standard.16 Additional provisions applyto consultations with Indigenous Peoples, in accordance withPerformance Standard 7.Grievance Mechanism11. The client will establish a grievance mechanism consistent withPerformance Standard 1 as early as possible in the project developmentphase. This will allow the client to receive and address specificconcerns about compensation and relocation raised by displacedpersons or members of host communities in a timely fashion, includinga recourse mechanism designed to resolve disputes in an impartialmanner.Resettlement and Livelihood Restoration Planning and Implementation12. Where involuntary resettlement is unavoidable, either as a result of anegotiated settlement or expropriation, a census will be carried out tocollect appropriate socio-economic baseline data to identify the personswho will be displaced by the project, determine who will be eligible forcompensation and assistance, and discourage ineligible persons, suchas opportunistic settlers, from claiming benefits. In the absence of hostgovernment procedures, the client will establish a cut-off date foreligibility. Information regarding the cut-off date will be welldocumented and disseminated throughout the project area.13. In cases where affected persons reject compensation offers that meetthe requirements of this Performance Standard and, as a result,expropriation or other legal procedures are initiated, the client willexplore opportunities to collaborate with the responsible governmentagency, and, if permitted by the agency, play an active role inresettlement planning, implementation, and monitoring (seeparagraphs 30–32).Compliance Status/ FindingsELDORADO informed that visits are undertaken and in case occupiers areidentified, the transaction is not concluded. PS 5, paragraph 9 NOT APPLICABLE because no resettlement was carried out. NonePS 5, paragraph 10 NOT APPLICABLE because no resettlement was carried out. NonePS 5, paragraph 11 NOT APPLICABLE because no resettlement was carried out. NoneRecommended further actionsPS 5, paragraph 12 to 16 Refer to PS5, paragraph 8. Refer to PS5, paragraph 8.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandards14. The client will establish procedures to monitor and evaluate theimplementation of a Resettlement Action Plan or LivelihoodRestoration Plan (see paragraphs 19 and 25) and take corrective actionas necessary. The extent of monitoring activities will be commensuratewith the project’s risks and impacts. For projects with significantinvoluntary resettlement risks, the client will retain competentresettlement professionals to provide advice on compliance with thisPerformance Standard and to verify the client’s monitoringinformation. Affected persons will be consulted during the monitoringprocess.Resettlement and Livelihood Restoration Planning and Implementation15. Implementation of a Resettlement Action Plan or LivelihoodRestoration Plan will be considered completed when the adverseimpacts of resettlement have been addressed in a manner that isconsistent with the relevant plan as well as the objectives of thisPerformance Standard. It may be necessary for the client to commissionan external completion audit of the Resettlement Action Plan orLivelihood Restoration Plan to assess whether the provisions have beenmet, depending on the scale and/or complexity of physical andeconomic displacement associated with a project. The completion auditshould be undertaken once all mitigation measures have beensubstantially completed and once displaced persons are deemed tohave been provided adequate opportunity and assistance tosustainably restore their livelihoods. The completion audit will beundertaken by competent resettlement professionals once the agreedmonitoring period is concluded. The completion audit will include, at aminimum, a review of the totality of mitigation measures implementedby the Client, a comparison of implementation outcomes againstagreed objectives, and a conclusion as to whether the monitoringprocess can be ended16. Where the exact nature or magnitude of the land acquisition orrestrictions on land use related to a project with potential to causephysical and/or economic displacement is unknown due to the stageof project development, the client will develop a Resettlement and/orLivelihood Restoration Framework outlining general principlescompatible with this Performance Standard. Once the individualproject components are defined and the necessary information becomesavailable, such a framework will be expanded into a specificResettlement Action Plan or Livelihood Restoration Plan andprocedures in accordance with paragraphs 19 and 25 below.Displacement17. Displaced persons may be classified as persons (i) who have formallegal rights to the land or assets they occupy or use; (ii) who do nothave formal legal rights to land or assets, but have a claim to land thatis recognized or recognizable under national law; or (iii) who have norecognizable legal right or claim to the land or assets they occupy oruse. The census will establish the status of the displaced persons.18. Project-related land acquisition and/or restrictions on land use mayresult in the physical displacement of people as well as their economicdisplacement. Consequently, requirements of this PerformanceStandard in respect of physical displacement and economicdisplacement may apply simultaneously.PS 5, paragraph 17 and18Compliance Status/ FindingsNOT APPLICABLE because no resettlement was carried out.NOT APPLICABLE because no resettlement was carried out.Recommended further actionsNoneNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsPhysical Displacement19. In the case of physical displacement, the client will develop aResettlement Action Plan that covers, at a minimum, the applicablerequirements of this Performance Standard regardless of the number ofpeople affected. This will include compensation at full replacement costfor land and other assets lost. The Plan will be designed to mitigate thenegative impacts of displacement; identify development opportunities;develop a resettlement budget and schedule; and establish theentitlements of all categories of affected persons (including hostcommunities). Particular attention will be paid to the needs of the poorand the vulnerable. The client will document all transactions to acquireland rights, as well as compensation measures and relocation activities.Physical Displacement20. If people living in the project area are required to move to anotherlocation, the client will (i) offer displaced persons choices amongfeasible resettlement options, including adequate replacement housingor cash compensation where appropriate; and (ii) provide relocationassistance suited to the needs of each group of displaced persons. Newresettlement sites built for displaced persons must offer improvedliving conditions. The displaced persons’ preferences with respect torelocating in pre-existing communities and groups will be taken intoconsideration. Existing social and cultural institutions of the displacedpersons and any host communities will be respected.21. In the case of physically displaced persons under paragraph 17 (i) or(ii), the client will offer the choice of replacement property of equal orhigher value, security of tenure, equivalent or better characteristics,and advantages of location or cash compensation where appropriate.Compensation in kind should be considered in lieu of cash. Cashcompensation levels should be sufficient to replace the lost land andother assets at full replacement cost in local markets.22. In the case of physically displaced persons under paragraph 17 (iii), theclient will offer them a choice of options for adequate housing withsecurity of tenure so that they can resettle legally without having toface the risk of forced eviction. Where these displaced persons own andoccupy structures, the client will compensate them for the loss of assetsother than land, such as dwellings and other improvements to the land,at full replacement cost, provided that these persons have beenoccupying the project area prior to the cut-off date for eligibility. Basedon consultation with such displaced persons, the client will providerelocation assistance sufficient for them to restore their standard ofliving at an adequate alternative site.23. The client is not required to compensate or assist those who encroachon the project area after the cut-off date for eligibility, provided the cutoffdate has been clearly established and made public.24. Forced evictions will not be carried out except in accordance with lawand the requirements of this Performance Standard.Compliance Status/ FindingsPS 5, paragraph 19 to 24 NOT APPLICABLE because no resettlement was carried out. NoneNOT APPLICABLE because no resettlement was carried out.Recommended further actionsNoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsEconomic Displacement25. In the case of projects involving economic displacement only, the clientwill develop a Livelihood Restoration Plan to compensate affectedpersons and/or communities and offer other assistance that meets theobjectives of this Performance Standard. The Livelihood RestorationPlan will establish the entitlements of affected persons and/orcommunities and will ensure that these are provided in a transparent,consistent, and equitable manner. The mitigation of economicdisplacement will be considered complete when affected persons orcommunities have received compensation and other assistanceaccording to the requirements of the Livelihood Restoration Plan andthis Performance Standard, and are deemed to have been providedwith adequate opportunity to re-establish their livelihoods.PS 5, paragraph 25 to 29Compliance Status/ FindingsPARTIALLY COMPLIANTThe Inventory of Areas of High Conservation Value consulted thecommunity nearby the farms to identify common use of the biodiversityareas. This study did not aim to identify economic displacement but itidentified that there aren’t areas of common use or essential to thecommunity on ELDORADO’s farms.This study did not include the areas at 2 Irmãos do Buruti and AnastáciomunicipalitiesThe PTEAS includes the identification of use of roads by neighbors, access towater resources, closeness to neighbors, schools, churches, households, etc,which could identify economic displacement. As reported above, thisprocedure is dated December 2011 and it was not performed in farms inwhich planting was carried out before this date.Reportedly, no economic displacement has been carried out by ELDORADO.Recommended further actionsProvide adequate training for social and communication experts to identifyeconomic displacement and to develop adequate measures to avoid ormitigate it, according to this performance standard, including if the familiesremaining at the leased land are to be economic impacted by the project.Carry out the PTEAS in all farms before intervention is made. For areas inwhich intervention was made and no PTEAS was carried out, p.e thoselocated at Dois Irmaos do Buruti and Anastacio, ELDORADO must definemeasures to identify economic displacement.The item is rated partial because PTEAS was not undertaken in all farms yet.Economic Displacement26. If land acquisition or restrictions on land use result in economicdisplacement defined as loss of assets and/or means of livelihood,regardless of whether or not the affected people are physicallydisplaced, the client will meet the requirements in paragraphs 27–29below, as applicable.Refer to PS5 paragraph 25None27. Economically displaced persons who face loss of assets or access toassets will be compensated for such loss at full replacement cost. In cases where land acquisition or restrictions on land use affectcommercial structures, affected business owners will becompensated for the cost of re-establishing commercial activitieselsewhere, for lost net income during the period of transition, andfor the costs of the transfer and reinstallation of the plant,machinery, or other equipment. In cases affecting persons with legal rights or claims to land whichare recognized or recognizable under national law (see paragraph17 (i) and (ii)), replacement property (e.g., agricultural orcommercial sites) of equal or greater value will be provided, or,where appropriate, cash compensation at full replacement cost. Economically displaced persons who are without legallyrecognizable claims to land (see paragraph 17 (iii)) will becompensated for lost assets other than land (such as crops,irrigation infrastructure and other improvements made to the land),at full replacement cost. The client is not required to compensate orassist opportunistic settlers who encroach on the project area afterthe cut-off date for eligibility.28. In addition to compensation for lost assets, if any, as required underparagraph 27, economically displaced persons whose livelihoods orincome levels are adversely affected will also be providedopportunities to improve, or at least restore, their means of incomeearningcapacity, production levels, and standards of living: For persons whose livelihoods are land-based, replacement landthat has a combination of productive potential, locationaladvantages, and other factors at least equivalent to that being lostshould be offered as a matter of priority.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 5 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCompliance Status/ Findings For persons whose livelihoods are natural resource-based andwhere project-related restrictions on access envisaged in paragraph5 apply, implementation of measures will be made to either allowcontinued access to affected resources or provide access toalternative resources with equivalent livelihood-earning potentialand accessibility. Where appropriate, benefits and compensationassociated with natural resource usage may be collective in naturerather than directly oriented towards individuals or households. If circumstances prevent the client from providing land or similarresources as described above, alternative income earningopportunities may be provided, such as credit facilities, training,cash, or employment opportunities. Cash compensation alone,however, is frequently insufficient to restore livelihoods.29. Transitional support should be provided as necessary to alleconomically displaced persons, based on a reasonable estimate of thetime required to restore their income-earning capacity, productionlevels, and standards of living.Private Sector Responsibilities Under Government-Managed Resettlement30. Where land acquisition and resettlement are the responsibility of the PS 5, paragraph 30 to 32 NOT APPLICABLEgovernment, the client will collaborate with the responsiblegovernment agency, to the extent permitted by the agency, to achieveoutcomes that are consistent with this Performance Standard. Inaddition, where government capacity is limited, the client will play anactive role during resettlement planning, implementation, andmonitoring, as described below.31. In the case of acquisition of land rights or access to land throughcompulsory means or negotiated settlements involving physicaldisplacement, the client will identify and describe governmentresettlement measures. If these measures do not meet the relevantrequirements of this Performance Standard, the client will prepare aSupplemental Resettlement Plan that, together with the documentsprepared by the responsible government agency, will address therelevant requirements of this Performance Standard (the GeneralRequirements and requirements for Physical Displacement andEconomic Displacement above). The client will need to include in itsSupplemental Resettlement Plan, at a minimum (i) identification ofaffected people and impacts; (ii) a description of regulated activities,including the entitlements of displaced persons provided underapplicable national laws and regulations; (iii) the supplementalmeasures to achieve the requirements of this Performance Standard asdescribed in paragraphs 19–29 in a way that is permitted by theresponsible agency and implementation time schedule; and (iv) thefinancial and implementation responsibilities of the client in theexecution of its Supplemental Resettlement Plan.32. In the case of projects involving economic displacement only, the clientwill identify and describe the measures that the responsiblegovernment agency plans to use to compensate Affected Communitiesand persons. If these measures do not meet the relevant requirementsof this Performance Standard, the client will develop an Environmentaland Social Action Plan to complement government action. This mayinclude additional compensation for lost assets, and additional effortsto restore lost livelihoods where applicable.Recommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

Review against IFC Performance Standard 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources)No: Requirements of IFC PS 6 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsGeneral6. The risks and impacts identification process as set out in PerformanceStandard 1 should consider direct and indirect project-related impactson biodiversity and ecosystem services and identify any significantresidual impacts. This process will consider relevant threats tobiodiversity and ecosystem services, especially focusing on habitat loss,degradation and fragmentation, invasive alien species,overexploitation, hydrological changes, nutrient loading, andpollution. It will also take into account the differing values attached tobiodiversity and ecosystem services by Affected Communities and,where appropriate, other stakeholders. Where paragraphs 13–19 areapplicable, the client should consider project-related impacts across thepotentially affected landscape or seascape.7. As a matter of priority, the client should seek to avoid impacts onbiodiversity and ecosystem services. When avoidance of impacts is notpossible, measures to minimize impacts and restore biodiversity andecosystem services should be implemented. Given the complexity inpredicting project impacts on biodiversity and ecosystem services overthe long term, the client should adopt a practice of adaptivemanagement in which the implementation of mitigation andmanagement measures are responsive to changing conditions and theresults of monitoring throughout the project’s lifecycle.PS 6, paragraphs 6 and 7EHS Guidelines forForest HarvestingOperationsCompliance Status/ FindingsPARTIALLY COMPLIANTELDORADO has performed several studies that addresses impacts onbiodiversity, such as: General environmental aspects and impacts have been assessed and aredocumented in a report provided by ELDORADO entitled EnvironmentalImpacts (Impactos Ambientais). This assessment was developed by PoyrySilviconsult in order to evaluate the impacts associated with the forestactivities. A document named Forest Management Plan has been provided and itincludes monitoring activities in order to check if the impacts are beingmitigated and minimized. Two studies performed by “Casa da Floresta” on January of 2012 toidentify the areas with high conservation value inside its properties. Thesestudies are: “Selection of areas of high conservation value and planning ofenvironmental monitoring”, which identifies and classifies areas of HighConservation Value in order to protect any existing riparian areas,wetlands or other significantly affected natural or critical habitats; and“Inventory of areas of high conservation value with critic socio-culturalimportance and / or essential social functions in the regions of workdevelopment of the Eldorado Brazil, Mato Grosso do Sul”. A third study is being carried out aiming to perform a biodiversityinventory in the areas identified as high conservation value and performfauna and flora monitoring. A study called PTEAS – Economic, Environmental and Social TechnicalProject (Projeto Técnico Econômico, Ambiental e Social) is an internalprocedure that evaluates the economic, environmental and social aspectsof the land before major interferences (cultivation or harvesting). Thisstudy was performed in some farms and it will be applied to all farms thatwill have activities, such as planting or harvesting. .Recommended further actionsELDORADO should ensure that studies to be undertaken in HighConservation Value Areas include quantitative and representative samplingof animal and vegetation communities, and make integrated assessment ofall components of the biota (analyzing the communities) and then integratethe physical and biotic aspects. This study should also evaluate impacts dueto change of use and isolation of the remaining naturals inside thecultivation of eucalyptus; and the restriction of movement of animals fromthe Cerrado biome to the forest plantation.The risks and impacts identification studies should include the scoping forecosystems services, at least in a qualitative way.The available environmental studies do not include quantitative andrepresentative sampling of animal and vegetation communities, neithermake integrated assessment of all components of the biota (analyzing thecommunities) and then integrate the physical and biotic aspects. Also, itwas not reported impacts due to change of use and isolation of theremaining naturals inside the cultivation of eucalyptus; and the restrictionof movement of animals from the Cerrado biome to the forest plantation.The existing studies do not use concepts of ecosystems services.8. Where paragraphs 13–15 are applicable, the client will retaincompetent professionals to assist in conducting the risks and impactsidentification process. Where paragraphs 16–19 are applicable, theclient should retain external experts with appropriate regionalexperience to assist in the development of a mitigation hierarchy thatcomplies with this Performance Standard and to verify theimplementation of those measures.Protection and Conservation of Biodiversity9. Habitat is defined as a terrestrial, freshwater, or marine geographicalunit or airway that supports assemblages of living organisms and theirinteractions with the non-living environment. For the purposes ofimplementation of this Performance Standard, habitats are divided intomodified, natural, and critical. Critical habitats are a subset of modifiedSee PS6, paragraphs 13-15PS 6, paragraph 9 and 10EHS Guidelines forForest HarvestingOperationsSee PS6, paragraphs 13-15 See PS6, paragraphs 13-15COMPLIANTAs mentioned in PS 6 Paragraph 6 to 7, ELDORADO has land usemanagement guidelines prioritize the use of pasture lands and avoid the useof areas with native forests or legally protected areas. In addition, forestry isIf ELDORADO decides to plant eucalyptus in the Pantanal biome, it shouldbe checked with the environmental agency if biodiversity offsets arerequired.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 6 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsor natural habitats.10. For the protection and conservation of biodiversity, the mitigationhierarchy includes biodiversity offsets, which may be considered onlyafter appropriate avoidance, minimization, and restoration measureshave been applied. A biodiversity offset should be designed andimplemented to achieve measurable conservation outcomes that canreasonably be expected to result in no net loss and preferably a net gainof biodiversity; however, a net gain is required in critical habitats. Thedesign of a biodiversity offset must adhere to the “like-for-like orbetter” principle and must be carried out in alignment with bestavailable information and current practices. When a client isconsidering the development of an offset as part of the mitigationstrategy, external experts with knowledge in offset design andimplementation must be involved.Modified Habitat11. Modified habitats are areas that may contain a large proportion ofplant and/or animal species of non-native origin, and/or wherehuman activity has substantially modified an area’s primary ecologicalfunctions and species composition. Modified habitats may includeareas managed for agriculture, forest plantations, reclaimed coastalzones, and reclaimed wetlands.12. This Performance Standard applies to those areas of modified habitatthat include significant biodiversity value, as determined by the risksand impacts identification process required in Performance Standard 1.The client should minimize impacts on such biodiversity andimplement mitigation measures as appropriate.PS 6, paragraphs 11 and12Forestry Code art. 20Compliance Status/ Findingsnot subjected to environmental licensing process in the State of Mato Grossodo Sul inside the Cerrado Biome. These conditions results in a situation thatELDORADO is not legally obligated to perform biodiversity offsets in theactive forest plantations.ELDORADO has one farm located in the Pantanal biome. Based onELDORADO´s information and also satellite images from Google Earth datedfrom 2010, there is no evidences that there are forestry activities inside theMutum Piuva Farm. ELDORADO has informed that there is no intention todevelop forestry in this farm; however, if it occurs, this development must bepreceded by an environmental licensing process.COMPLIANTLand use management: The land use conversion inside the ELDORADO’s properties wasreportedly to be mostly from pasture to forest plantation. ERM did notfind evidences during the site visits that ELDORADO is converting nativeforests into forest plantation. ELDORADO has set clear guidelines to not use Protected PermanentAreas (PPA) or Legal Reserve areas to develop forestry activities. ERM observed the implementation appropriate techniques for erosioncontrol (e.g. stacking of brush and slashes).Recommended further actionsNoneNatural Habitat13. Natural habitats are areas composed of viable assemblages of plantand/or animal species of largely native origin, and/or where humanactivity has not essentially modified an area’s primary ecologicalfunctions and species composition.14. The client will not significantly convert or degrade natural habitats,unless all of the following are demonstrated: No other viable alternatives within the region exist fordevelopment of the project on modified habitat; Consultation has established the views of stakeholders, includingAffected Communities, with respect to the extent of conversion anddegradation; and Any conversion or degradation is mitigated according to themitigation hierarchy.15. In areas of natural habitat, mitigation measures will be designed toachieve no net loss of biodiversity where feasible. Appropriate actionsinclude: Avoiding impacts on biodiversity through the identification andprotection of set-asides; Implementing measures to minimize habitat fragmentation, such asbiological corridors; Restoring habitats during operations and/or after operations; and Implementing biodiversity offsets.Critical Habitat16. Critical habitats are areas with high biodiversity value, including (i)habitat of significant importance to Critically Endangered and/orPS 6, paragraphs 8, 13,14 and 15The management of the modified habitats (forest plantation) is presented atPS 3 paragraphs 4 and 5.PARTIALLY COMPLIANTAccording to site visit and information provided by ELDORADO, legallyprotected areas (Permanent preservation areas and Legal Reserves) as well asendemic or endangered species are maintained and preserved inside thevisited properties.The land use management guidelines (PS6 paragraphs 6 and 7) are being alsoapplied to leased lands, partnership agreements and wood suppliers toguarantee that natural habits are not being converted to forest plantation inthird-party farms. This requirement is imposed by contract.ERM observed that some of the legal reserve areas are isolated andsurrounded by forest plantation or are not connected with permanentprotected areas (PPA) around the riparian zones. This isolation may interferewith the ecological function of these areas. However, this land configurationwas mostly inherited from previous ownership.There are three main actions that ELDORADO could take in order toimprove the management of natural resources:1 – Try, when possible, to connect the Legal Reserves with ProtectedPermanent Areas (PPAs) in order to enhance the ecological function of theseareas, provide habitat corridors and promote the conservation of rare,threatened or endangered species.2 – Implement a Native Forest Management System in isolated LegalReserves in order to enhance their ecological function when otheralternatives are not possible (e.g. connection with PPAs)3 – Extend the PTEAS to cover every major intervention insideELDORADO’s properties.PS 6, paragraphs 8, 16, PARTIALLY COMPLIANT After the conclusion of the third study ELDORADO should consolidate theimprovement actions to be performed in these areas in a Biodiversity ActionENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 6 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsEndangered species; (ii) habitat of significant importance to endemicand/or restricted-range species; (iii) habitat supporting globallysignificant concentrations of migratory species and/or congregatoryspecies; (iv) highly threatened and/or unique ecosystems; and/or (v)areas associated with key evolutionary processes.17. In areas of critical habitat, the client will not implement any projectactivities unless all of the following are demonstrated: No other viable alternatives within the region exist fordevelopment of the project on modified or natural habitats that arenot critical; The project does not lead to measurable adverse impacts on thosebiodiversity values for which the critical habitat was designated,and on the ecological processes supporting those biodiversityvalues; The project does not lead to a net reduction in the global and/ornational/regional population of any Critically Endangered orEndangered species over a reasonable period of time; and A robust, appropriately designed, and long-term biodiversitymonitoring and evaluation program is integrated into the client’smanagement program.18. In such cases where a client is able to meet the requirements defined inparagraph 17, the project’s mitigation strategy will be described in aBiodiversity Action Plan and will be designed to achieve net gains ofthose biodiversity values for which the critical habitat was designated.19. In instances where biodiversity offsets are proposed as part of themitigation strategy, the client must demonstrate through an assessmentthat the project’s significant residual impacts on biodiversity will beadequately mitigated to meet the requirements of paragraph 17.Legally Protected and Internationally Recognized Areas20. In circumstances where a proposed project is located within a legallyprotected area or an internationally recognized area, the client willmeet the requirements of paragraphs 13 through 19 of this PerformanceStandard, as applicable. In addition, the client will:Demonstrate that the proposed development in such areas is legallypermitted;Act in a manner consistent with any government recognizedmanagement plans for such areas;Consult protected area sponsors and managers, AffectedCommunities, Indigenous Peoples and other stakeholders on theproposed project, as appropriate; andImplement additional programs, as appropriate, to promote andenhance the conservation aims and effective management of thearea.Compliance Status/ Findings17, 18 and 19 ELDORADO presented two studies performed by “Casa da Floresta” onJanuary of 2012 to identify the areas with high conservation value inside itsproperties. These studies are: “Selection of areas of high conservation value and planning ofenvironmental monitoring”. This study identifies and classifies areas ofHigh Conservation Value in order to protect any existing riparian areas,wetlands or other significantly affected natural or critical habitats. “Inventory of areas of high conservation value with critic socio-culturalimportance and / or essential social functions in the regions of workdevelopment of the Eldorado Brazil, Mato Grosso do Sul”.A third study is being carried out aiming to perform a biodiversity inventoryin the areas identified as high conservation value and perform fauna andflora monitoring.PS 6, paragraph 20Federal Law nº 4771,September 15th, 1965and amendments (ForestCode)Federal Law nº 6.938,August 31st, 1981 andamendmentsConama Resolution nº369, March 28th, 2006Federal Law nº 6.902,April 27th,1981Federal Decree nº 99.274,June 6th, 1990COMPLIANTA small fraction (less than 1 hectare) of two ELDORADO’s properties(Correntes I e II Farms) are located inside an Environmental Protected Area(EPA) called Piraputanga Park Road, in the “Dois Irmãos do Buriti”municipality. This EPA was created by the Decreto N° 9.937/2000; however,the required zoning to ordinate the land use inside the Park was never doneby the Environmental Agency. It means that there is not yet any instructionor regulation on what type of use is allowed inside the EPA. Therefore, dueto the small overlay between these areas and the lack of proper zoning, itdoes not configure a land use conflict.As described in PS 6 paragraphs 13 to 15, The land use managementguidelines (PS6 paragraphs 6 and 7) are being also applied to leased lands,partnership agreements and wood suppliers to guarantee legally protectedareas are being adequately maintained and preserved.Reportedly 13% of all legal reserves are submitted and recognized by theenvironmental agency, 53% has been submitted to the environmental agencyfor approval and 34% has signed term of commitment for proof of legalreserve within two years.ELDORADO is not actively managing the lands to bring the PPA and theLegal reserve back into their natural state, based on a report that concludesthat in Cerrado biome is better to leave them for natural reforestation.Recommended further actionsPlan, in order to guarantee net gains of biodiversity values.In addition, ELDORADO should implement or enhance the followingprocedures:• Establish monitoring and audit system to guarantee that legal reservesand PPAs are being protected. This should be performed periodically.• Implement a follow up system in order to check if the use of third-partyfarms and wood suppliers are in compliance with the ELDORADO land usemanagement guidelines and applicable environmental legislations (e.g.Forest Code). It includes the status of ongoing requests for legal reservesapproval.Natural regeneration of the bioma Cerrado can occur once there is a nearsources of propagules (other Cerrado areas surrounding) and since theoperator favors the natural regeneration it should ensure disturbing factors(eg fire, opening trails, movement of domesticated animals like cattle andhorses) are minimized or eliminated.ELDORADO should monitor if natural regeneration occurs, and prepare arecovery plan, if necessary.Finally, ELDORADO must follow the development of zoning regulationrelated to the Piraputanga Park Road, which may affect how the land is usedin two of their properties.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 6 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsInvasive Alien Species21. Intentional or accidental introduction of alien, or non-native, species offlora and fauna into areas where they are not normally found can be asignificant threat to biodiversity, since some alien species can becomeinvasive, spreading rapidly and out-competing native species.22. The client will not intentionally introduce any new alien species (notcurrently established in the country or region of the project) unless thisis carried out in accordance with the existing regulatory framework forsuch introduction. Notwithstanding the above, the client will notdeliberately introduce any alien species with a high risk of invasivebehavior regardless of whether such introductions are permitted underthe existing regulatory framework. All introductions of alien specieswill be subject to a risk assessment (as part of the client’senvironmental and social risks and impacts identification process) todetermine the potential for invasive behavior. The client willimplement measures to avoid the potential for accidental orunintended introductions including the transportation of substratesand vectors (such as soil, ballast, and plant materials) that may harboralien species.23. Where alien species are already established in the country or region ofthe proposed project, the client will exercise diligence in not spreadingthem into areas in which they have not already been established. Aspracticable, the client should take measures to eradicate such speciesfrom the natural habitats over which they have management control.Management of Ecosystem Services24. Where a project is likely to adversely impact ecosystem services, asdetermined by the risks and impacts identification process, the clientwill conduct a systematic review to identify priority ecosystemservices. Priority ecosystem services are two-fold: (i) those services onwhich project operations are most likely to have an impact and,therefore, which result in adverse impacts to Affected Communities;and/or (ii) those services on which the project is directly dependent forits operations (e.g., water). When Affected Communities are likely tobe impacted, they should participate in the determination of priorityecosystem services in accordance with the stakeholder engagementprocess as defined in Performance Standard 1.25. With respect to impacts on priority ecosystem services of relevance toAffected Communities and where the client has direct managementcontrol or significant influence over such ecosystem services, adverseimpacts should be avoided. If these impacts are unavoidable, the clientwill minimize them and implement mitigation measures that aim tomaintain the value and functionality of priority services. With respectto impacts on priority ecosystem services on which the projectdepends, clients should minimize impacts on ecosystem services andimplement measures that increase resource efficiency of theiroperations, as described in Performance Standard 3. Additionalprovisions for ecosystem services are included in PerformanceStandards 4, 5, 7, and 8.PS 6, paragraphs 21, 22and 23Federal Law nº 11.105,March 24 th , 2005Federal Decree nº 5591,November, 22 nd , 2005EHS Guidelines forForest HarvestingOperationsPS 6, paragraph 24 and25EHS Guidelines forForest HarvestingOperationsCompliance Status/ FindingsCOMPLIANTERM was informed during site visit that eucalyptus to be cultivated in leasedor owned lands are cloned. Reportedly, these types of cloning are commercialtypes, registered and not GMO – genetically modified organism. As reportedthe eucalyptus species used for forestry do not spread into surrounded areas.Procedures and Forest Management Plan do show that preservation andlegally protected areas are being preserved and maintained and during sitevisit it was not noticed the spread of eucalyptus in other areas besides thecultivation farms.Considerations regarding the analysis of impacts on ecosystem services arepresented on PS 6 paragraphs 6 and 7.Recommended further actionsENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 6 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsSustainable Management of Living Natural Resources26. Clients who are engaged in the primary production of living naturalresources, including natural and plantation forestry, agriculture,animal husbandry, aquaculture, and fisheries, will be subject to therequirements of paragraphs 26 through 30, in addition to the rest ofthis Performance Standard. Where feasible, the client will locate landbasedagribusiness and forestry projects on unforested land or landalready converted. Clients who are engaged in such industries willmanage living natural resources in a sustainable manner, through theapplication of industry-specific good management practices andavailable technologies. Where such primary production practices arecodified in globally, regionally, or nationally recognized standards, theclient will implement sustainable management practices to one or morerelevant and credible standards as demonstrated by independentverification or certification.27. Credible globally, regionally, or nationally recognized standards forsustainable management of living natural resources are those which (i)are objective and achievable; (ii) are founded on a multi-stakeholderconsultative process; (iii) encourage step-wise and continualimprovements; and (iv) provide for independent verification orcertification through appropriate accredited bodies for such standards.28. Where relevant and credible standard(s) exist, but the client has not yetobtained independent verification or certification to such standard(s),the client will conduct a pre-assessment of its conformity to theapplicable standard(s) and take actions to achieve such verification orcertification over an appropriate period of time.PS 6, paragraphs 26-29Compliance Status/ FindingsCOMPLIANTReportedly the company is starting the process to have a FSC (ForestStewardship Council) certification. This process requires an assessment ofpotential impacts. The company intends to certify the forest management andthe wood custody chain in parts.Eldorado already started to prepare the forest management certification; theyrealized trainings, formed working groups, elaborated and executed anaction plan, hired the certification company and received their technical visit.The pre-certification audit to the wood process is planned to April/2012 andthe certification audit to August/2012. After that, the company will start theprocess to certify the custody chain. This second certification process goesfrom September/2012 to November/2012, when the custody chaincertification audit is planned to occur. For more information regarding thecertification process refer to chapter 3, item 3.5 of the report.Recommended further actions29. In the absence of a relevant and credible global, regional, or nationalstandard for the particular living natural resource in the countryconcerned, the client will: Commit to applying good international industry operatingprinciples, management practices, and technologies; and Actively engage and support the development of a nationalstandard, where relevant, including studies that contribute to thedefinition and demonstration of sustainable practices.Supply Chain30. Where a client is purchasing primary production (especially but notexclusively food and fiber commodities) that is known to be producedin regions where there is a risk of significant conversion of naturaland/or critical habitats, systems and verification practices will beadopted as part of the client’s ESMS to evaluate its primarysuppliers.21 The systems and verification practices will (i) identifywhere the supply is coming from and the habitat type of this area; (ii)provide for an ongoing review of the client’s primary supply chains;(iii) limit procurement to those suppliers that can demonstrate thatthey are not contributing to significant conversion of natural and/orcritical habitats (this may be demonstrated by delivery of certifiedproduct, or progress towards verification or certification under acredible scheme in certain commodities and/or locations); and (iv)where possible, require actions to shift the client’s primary supplychain over time to suppliers that can demonstrate that they are notsignificantly adversely impacting these areas. The ability of the client tofully address these risks will depend upon the client’s level ofmanagement control or influence over its primary suppliers.COMPLIANTAccording to information provided during site visits and documentation ofwood supplier, the company has control over the supply chain and also givessupport, whenever necessary, in order to provide documentation to testifycompliance with legal standards.Reportedly, some suppliers, such as DURAFLOR, that will be used byELDORADO have FSC certification.NoneENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

Review against IFC Performance Standard 7 (Indigenous Peoples)No: Requirements of IFC PS 7 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsGeneralAvoidance of Adverse Impacts8. The client will identify, through an environmental and social risks andimpacts assessment process, all communities of Indigenous Peopleswithin the project area of influence who may be affected by the project,as well as the nature and degree of the expected direct and indirecteconomic, social, cultural (including cultural heritage), andenvironmental impacts on them.PS7, paragraph 8Compliance Status/ FindingsPARTIALLY COMPLIANTArcheological survey has been conducted in December 2011, and identifiedthat there was no indigenous groups or traditional people affected byELDORADO’s operation. The study was undertaken on 7 municipalitieswere ELDORADO operates: Três Lagoas, Selvíria, Aparecida do Taboado,Inocência, Água Clara, Santa Rita do Pardo, Ribas do Rio Pardo.The study reports that there is one indigenous group in the municipality ofBrasilândia names Ofayé-Xavante, municipality in which ELDORADO doesnot operate. ELDORADO reported that this indigenous land is 96 km awayfrom ELDORADO industrial site and 92 km away from farms operated byELDORADO at the municipality of Santa Rita do Pardo.A social territory study was undertaken for the two municipalities ,Anastacio and Dois Irmãos do Buruti, were ELDORADO possess lands. Thestudy was undertaken by the previous land owner and identified 7indigenous communities in the region, none of them at ELDORADO’s land.The study lacks to identify impacts of the operation on indigenous andtraditional people.Recommended further actionsIdentify the influence of the operation at Dois Irmãos do Buruti andAnastácio municipalities over indigenous or traditional people at PTEAS.In case impact on indigenous or traditional people is identified, ELDORADOmust develop an Action Plan to minimize, restore, and/or compensate forthese impacts in a culturally appropriate manner commensurate with thenature and scale of such impacts and the vulnerability of the AffectedCommunities of Indigenous Peoples, in compliance with this performancestandard and the Brazilian legislation.Include impacted indigenous people’s representatives, if applicable, on theStakeholder Development Plan described in PS1, paragraph 27, 28.Official information available at Indigenous National Foundation (FUNAI)website was checked and it evidenced that ELDORADO’s farm’s are not inindigenous land.Jatiúca Farm is the closest farm to an indigenous land, is it is located 22 kmaway from it.The lands have eucalyptus ready to be harvested and recently planted,maintenance is currently being performed. ELDORADO reported thatimpact on indigenous and traditional people will be identified throughPTEAS that will be carried out before harvesting (between June to December2012).9. Adverse impacts on Affected Communities of Indigenous Peoplesshould be avoided where possible. Where alternatives have beenexplored and adverse impacts are unavoidable, the client willminimize, restore, and/or compensate for these impacts in a culturallyappropriate manner commensurate with the nature and scale of suchimpacts and the vulnerability of the Affected Communities ofIndigenous Peoples. The client’s proposed actions will be developedwith the ICP of the Affected Communities of Indigenous Peoples andcontained in a time-bound plan, such as an Indigenous Peoples Plan,or a broader community development plan with separate componentsfor Indigenous Peoples.Participation and Consent10. The client will undertake an engagement process with the AffectedCommunities of Indigenous Peoples as required in PerformanceStandard 1. This engagement process includes stakeholder analysisand engagement planning, disclosure of information, consultation, andparticipation, in a culturally appropriate manner. In addition, thisprocess will:ERM visited and interviewed workers, and it was not identified indigenouswork.PS7, paragraph 9 Refer to PS7, paragraph 8. Refer to PS7, paragraph 8.PS7, paragraph 10 to 12 Refer to PS7, paragraph 8. Refer to PS7, paragraph 8.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 7 Related PSCompliance Status/ FindingsRecommended further actionsRequirements, EHSGuidelines (Generaland Forest) and LegalStandards Involve Indigenous Peoples’ representative bodies andorganizations (e.g., councils of elders or village councils), as well asmembers of the Affected Communities of Indigenous Peoples; and Provide sufficient time for Indigenous Peoples’ decision-makingprocesses.Participation and Consent11. Affected Communities of Indigenous Peoples may be particularlyRefer to PS7, paragraph 8. Refer to PS7, paragraph 8.vulnerable to the loss of, alienation from or exploitation of their landand access to natural and cultural resources. In recognition of thisvulnerability, in addition to the General Requirements of thisPerformance Standard, the client will obtain the FPIC of the AffectedCommunities of Indigenous Peoples in the circumstances described inparagraphs 13–17 of this Performance Standard. FPIC applies toproject design, implementation, and expected outcomes related toimpacts affecting the communities of Indigenous Peoples. When any ofthese circumstances apply, the client will engage external experts toassist in the identification of the project risks and impacts.12. There is no universally accepted definition of FPIC. For the purposesof Performance Standards 1, 7 and 8, “FPIC” has the meaningdescribed in this paragraph. FPIC builds on and expands the processof ICP described in Performance Standard 1 and will be establishedthrough good faith negotiation between the client and the AffectedCommunities of Indigenous Peoples. The client will document: (i) themutually accepted process between the client and AffectedCommunities of Indigenous Peoples, and (ii) evidence of agreementbetween the parties as the outcome of the negotiations. FPIC does notnecessarily require unanimity and may be achieved even whenindividuals or groups within the community explicitly disagree.Circumstances Requiring Free, Prior, and Informed ConsentImpacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use13. Indigenous Peoples are often closely tied to their lands and relatednatural resources. Frequently, these lands are traditionally owned orunder customary use. While Indigenous Peoples may not possess legaltitle to these lands as defined by national law, their use of these lands,including seasonal or cyclical use, for their livelihoods, or cultural,ceremonial, and spiritual purposes that define their identity andcommunity, can often be substantiated and documented.PS7, paragraph 13 to 14 Refer to PS7, paragraph 8. Refer to PS7, paragraph 8.14. If the client proposes to locate a project on, or commercially developnatural resources on lands traditionally owned by, or under thecustomary use of, Indigenous Peoples, and adverse impacts can beexpected, the client will take the following steps: Document efforts to avoid and otherwise minimize the area of landproposed for the project; Document efforts to avoid and otherwise minimize impacts onnatural resources and natural areas of importance to IndigenousPeople; Identify and review all property interests and traditional resourceuses prior to purchasing or leasing land; Assess and document the Affected Communities of IndigenousPeoples’ resource use without prejudicing any Indigenous Peoples’land claim. The assessment of land and natural resource use shouldbe gender inclusive and specifically consider women’s role in themanagement and use of these resources; Ensure that Affected Communities of Indigenous Peoples areinformed of their land rights under national law, including anynational law recognizing customary use rights; andENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 7 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsCircumstances Requiring Free, Prior, and Informed ConsentImpacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary UseCompliance Status/ Findings Offer Affected Communities of Indigenous Peoples compensationand due process in the case of commercial development of theirland and natural resources, together with culturally appropriatesustainable development opportunities, including: Providing land-based compensation or compensation-in-kindin lieu of cash compensation where feasible. Ensuring continued access to natural resources, identifying theequivalent replacement resources, or, as a last option,providing compensation and identifying alternative livelihoodsif project development results in the loss of access to and theloss of natural resources independent of project landacquisition. Ensuring fair and equitable sharing of benefits associated withproject usage of the resources where the client intends to utilizenatural resources that are central to the identity and livelihoodof Affected Communities of Indigenous People and their usagethereof exacerbates livelihood risk. Providing Affected Communities of Indigenous Peoples withaccess, usage, and transit on land it is developing subject tooverriding health, safety, and security considerations.Relocation of Indigenous Peoples from Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use15. The client will consider feasible alternative project designs to avoid therelocation of Indigenous Peoples from communally held lands andnatural resources subject to traditional ownership or under customaryuse. If such relocation is unavoidable the client will not proceed withthe project unless FPIC has been obtained as described above. Anyrelocation of Indigenous Peoples will be consistent with therequirements of Performance Standard 5. Where feasible, the relocatedIndigenous Peoples should be able to return to their traditional orcustomary lands, should the cause of their relocation cease to exist.Critical Cultural Heritage16. Where a project may significantly impact on critical cultural heritagethat is essential to the identity and/or cultural, ceremonial, or spiritualaspects of Indigenous Peoples lives, priority will be given to theavoidance of such impacts. Where significant project impacts oncritical cultural heritage are unavoidable, the client will obtain theFPIC of the Affected Communities of Indigenous Peoples.17. Where a project proposes to use the cultural heritage includingknowledge, innovations, or practices of Indigenous Peoples forcommercial purposes, the client will inform the Affected Communitiesof Indigenous Peoples of (i) their rights under national law; (ii) thescope and nature of the proposed commercial development; (iii) thepotential consequences of such development; and (iv) obtain theirFPIC. The client will also ensure fair and equitable sharing of benefitsfrom commercialization of such knowledge, innovation, or practice,consistent with the customs and traditions of the Indigenous Peoples.Mitigation and Development Benefits18. The client and the Affected Communities of Indigenous Peoples willidentify mitigation measures in alignment with the mitigationhierarchy described in Performance Standard 1 as well asopportunities for culturally appropriate and sustainable developmentbenefits. The client will ensure the timely and equitable delivery ofagreed measures to the Affected Communities of Indigenous Peoples.PS7, paragraph 15PS7, paragraph 16 and17NOT APPLICABLE As reported on PS7 paragraph 8, ELDORADO’s land are not located atindigenous land, therefore no resettlement was undertaken.Recommended further actionsRefer to PS7, paragraph 8. Refer to PS7, paragraph 8.PS7, paragraph 18 to 20 Refer to PS7, paragraph 8. Refer to PS7, paragraph 8.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 7 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsMitigation and Development Benefits19. The determination, delivery, and distribution of compensation andother benefit sharing measures to the Affected Communities ofIndigenous Peoples will take account of the laws, institutions, andcustoms of these communities as well as their level of interaction withmainstream society. Eligibility for compensation can either beindividually or collectively-based, or be a combination of both. Wherecompensation occurs on a collective basis, mechanisms that promotethe effective delivery and distribution of compensation to all eligiblemembers of the group will be defined and implemented.20. Various factors including, but not limited to, the nature of the project,the project context and the vulnerability of the Affected Communitiesof Indigenous Peoples will determine how these communities shouldbenefit from the project. Identified opportunities should aim toaddress the goals and preferences of the Indigenous Peoples includingimproving their standard of living and livelihoods in a culturallyappropriate manner, and to foster the long-term sustainability of thenatural resources on which they depend.Private Sector Responsibilities Where Government is Responsible for Managing Indigenous Peoples Issues21. Where the government has a defined role in the management ofIndigenous Peoples issues in relation to the project, the client willcollaborate with the responsible government agency, to the extentfeasible and permitted by the agency, to achieve outcomes that areconsistent with the objectives of this Performance Standard. Inaddition, where government capacity is limited, the client will play anactive role during planning, implementation, and monitoring ofactivities to the extent permitted by the agency.22. The client will prepare a plan that, together with the documentsprepared by the responsible government agency, will address therelevant requirements of this Performance Standard. The client mayneed to include (i) the plan, implementation, and documentation of theprocess of ICP and engagement and FPIC where relevant; (ii) adescription of the government-provided entitlements of affectedIndigenous Peoples; (iii) the measures proposed to bridge any gapsbetween such entitlements, and the requirements of this PerformanceStandard; and (iv) the financial and implementation responsibilities ofthe government agency and/or the client.PS7, paragraph 21 and22Compliance Status/ FindingsRecommended further actionsRefer to PS7, paragraph 8. Refer to PS7, paragraph 8.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

Review against IFC Performance Standard 8 (Cultural Heritage)No: Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsProtection of Cultural Heritage in Project Design and Execution6. In addition to complying with applicable law on the protection ofcultural heritage, including national law implementing the hostcountry’s obligations under the Convention Concerning the Protectionof the World Cultural and Natural Heritage, the client will identifyand protect cultural heritage by ensuring that internationallyrecognized practices for the protection, field-based study, anddocumentation of cultural heritage are implemented. PS 8, paragraph 6and 8Standard IPHAN230/02Compliance Status/ FindingsCOMPLIANTArcheological survey has been conducted in December 2011. The study hasrevealed a set of 10 archaeological sites and related chipped lithic remains.Both the inclusion of topographic sites on average slope, and thecharacteristics of the lithic material allow characterizing these locations ascampsites for hunter-gatherers to prehistoric hunting activities, fishing andgathering. This study has been submitted to the Institute for NationalHistorical and Artistic Heritage (IPHAN – Instituto do Patrimônio Histórico eArtístico Nacional) and waits for the issuance of technical opinion.For the municipalities of Anastacio and Dois irmãos do Buruti, a socialterritorial diagnosis was undertaken and identified archeological heritagearound 2 farms (Correntes e Jatiúca). This study was undertaken by thelands previous owner (company MMX) and it identified 8 archeological sitesin the region where the lands are located, 1 one of them inside the farmCorrentes that belongs to ELDORADO. As a result, the report suggests thedevelopment of a monitoring program in 7 archeological sites, a program ofarcheological prospection in 1 site, and the disclosure of the information, asdefined by Standard IPHAN 7/88.Recommended further actionsIdentify impact of ELDORADO’s operation on cultural heritage.Monitor the archeological sites identified by the studies, and follow itrecommendation:Develop a monitoring program in 7 archeological sites,Develop a program of archeological prospection in 1 site,Public disclosure information about archeological heritageidentified.Protection of Cultural Heritage in Project Design and Execution7. Where the risk and identification process determines that there is achance of impacts to cultural heritage, the client will retain competentprofessionals to assist in the identification and protection of culturalheritage. The removal of nonreplicable cultural heritage is subject to theadditional requirements of paragraph 10 below. In the case of criticalcultural heritage, the requirements of paragraphs 13–15 will apply.PS 8, paragraph 7Chance Find Procedures8. The client is responsible for siting and designing a project to avoidsignificant adverse impacts to cultural heritage. The environmental andsocial risks and impacts identification process should determinewhether the proposed location of a project is in areas where culturalheritage is expected to be found, either during construction oroperations. In such cases, as part of the client’s ESMS, the client willdevelop provisions for managing chance finds through a chance findprocedure which will be applied in the event that cultural heritage issubsequently discovered. The client will not disturb any chance findfurther until an assessment by competent professionals is made andactions consistent with the requirements of this Performance Standardare identified.See PS 8, paragraph 6COMPLIANTWithin the archaeological study, developed by external professionals, animpact assessment of the archaeological sites has been conducted in theareas of reforestation of ELDORADO considered to have direct impact. Inall sites the impacts were considered negative, direct, temporary andirreversible. Recommendations defined by this study shall be implementedby ELDORADO.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (Generaland Forest) and LegalStandardsConsultation9. Where a project may affect cultural heritage, the client will consult withAffected Communities within the host country that use, or have usedwithin living memory, the cultural heritage for long-standing culturalpurposes. The client will consult with the Affected Communities toidentify cultural heritage of importance, and to incorporate into theclient’s decision-making process the views of the AffectedCommunities on such cultural heritage. Consultation will also involvethe relevant national or local regulatory agencies that are entrustedwith the protection of cultural heritage.PS 8, paragraph 9Community Access10. Where the client’s project site contains cultural heritage or preventsaccess to previously accessible cultural heritage sites being used by, orthat have been used by, Affected Communities within living memoryfor long-standing cultural purposes, the client will, based onconsultations under paragraph 9, allow continued access to the culturalsite or will provide an alternative access route, subject to overridinghealth, safety, and security considerations.PS 8, paragraph 10Removal of Replicable Cultural Heritage11. Where the client has encountered tangible cultural heritage that is PS 8, paragraph 11replicable and not critical, the client will apply mitigation measures thatfavor avoidance. Where avoidance is not feasible, the client will apply amitigation hierarchy as follows: Minimize adverse impacts and implement restoration measures, insitu, that ensure maintenance of the value and functionality of thecultural heritage, including maintaining or restoring any ecosystemprocesses needed to support it; Where restoration in situ is not possible, restore the functionality ofthe cultural heritage, in a different location, including the ecosystemprocesses needed to support it; The permanent removal of historical and archaeological artefactsand structures is carried out according to the principles ofparagraphs 6 and 7 above; and Only where minimization of adverse impacts and restoration toensure maintenance of the value and functionality of the culturalheritage are demonstrably not feasible, and where the AffectedCommunities are using the tangible cultural heritage for longstandingcultural purposes, compensate for loss of that tangiblecultural heritage.Compliance Status/ FindingsPARTIALLY COMPLIANTStudy has been submitted to the Institute for National Historical and ArtisticHeritage (IPHAN – Instituto do Patrimônio Histórico e Artístico Nacional).However it does not involve consultations with affected communities for theidentification purpose of the restoration of historical occupation of thecultural heritage.The Inventory of Areas of High Conservation Value consulted the communitynearby the farms to identify common use of the biodiversity areas. Itidentified that there are not areas of common use or essential to thecommunity on ELDORADO’s farms.This study did not include the areas at 2 Irmãos do Buruti and AnastáciomunicipalitiesConsultation is an important means of identifying it, documenting itspresence and significance, assessing potential impacts, and exploringmitigation options. Requirements on the community engagement of AffectedCommunities can be found in paragraphs 25 through 33 of PerformanceStandard 1.It was also reported that a public hearing will be carried out for the purposeof forest certification.NOT APPLICABLEAccording information from archeological survey presented to IPHAN (SeeAnnex A) the site does not prevent access to cultural heritages or previouslycultural heritage sites. Therefore this requirement is not applicable.COMPLIANTWithin the archaeological study, mitigation measures, related to impactsidentified, were suggested for effective protection of archaeological heritage.These mitigation measures during the implementation of the project were:development of a program of archaeological exploration and developmentof an archaeological monitoring program. The measures suggested to betaken immediately after the implementation of the project were: thepublication of illustrated book for the general public to the socialization ofknowledge archaeological site Três Lagoas, Selvíria, Aparecida do Taboado,Inocência, Água Clara, Ribas do Rio Pardo and Santa Rita do Rio Pardo/MS, and the second phase of development of heritage education activities in thecommunities surrounding the project.Recommended further actionsConduct the public hearing.Identify important areas of common use or essential to the community onELDORADO’s farms located at Dois Irmãos do Buruti and Anastaciomunicipalities.It was recommended by the archaeological survey that the following actionsbe performed:- Archaeological survey project in 10 sites located in view of scientificrelevance and susceptibility of the sites to erosion in the area ofreforestation;- Monitoring the implementation of the project to avoid impacts on localarchaeological heritage in the area indirectly impacted by the change in soilstructure;-Continue activities related to heritage education in the communitiessurrounding the project, based on publication of a scientific communicationbook about the archaeological site.ERM recommends to expand the area of study, since there will be purchaseof wood, and partnership contracts to plant eucalyptus in other areasbeyond the areas owned by ELDORADO. Therefore these areas couldpresent cultural heritage that was not identified due to the limited areapreviously defined in the study present to IPHAN.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

No: Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (General andForest) and LegalStandardsRemoval of Non-Replicable Cultural Heritage12. Most cultural heritage is best protected by preservation in its place,since removal is likely to result in irreparable damage or destruction ofthe cultural heritage. The client will not remove any nonreplicablecultural heritage, unless all of the following conditions are met: There are no technically or financially feasible alternatives toremoval; The overall benefits of the project conclusively outweigh theanticipated cultural heritage loss from removal; and Any removal of cultural heritage is conducted using the bestavailable technique.Critical Cultural Heritage13. Critical cultural heritage consists of one or both of the following typesof cultural heritage: (i) the internationally recognized heritage ofcommunities who use, or have used within living memory the culturalheritage for long-standing cultural purposes; or (ii) legally protectedcultural heritage areas, including those proposed by host governmentsfor such designation.14. The client should not remove, significantly alter, or damage criticalcultural heritage. In exceptional circumstances when impacts on criticalcultural heritage are unavoidable, the client will use a process ofInformed Consultation and Participation (ICP) of the AffectedCommunities as described in Performance Standard 1 and which uses agood faith negotiation process that results in a documented outcome.The client will retain external experts to assist in the assessment andprotection of critical cultural heritage.Critical Cultural Heritage15. Legally protected cultural heritage areas are important for theprotection and conservation of cultural heritage, and additionalmeasures are needed for any projects that would be permitted underthe applicable national law in these areas. In circumstances where aproposed project is located within a legally protected area or a legallydefined buffer zone, the client, in addition to the requirements forcritical cultural heritage cited in paragraph 14 above, will meet thefollowing requirements: Comply with defined national or local cultural heritage regulationsor the protected area management plans; Consult the protected area sponsors and managers, localcommunities and other key stakeholders on the proposed project;and Implement additional programs, as appropriate, to promote andenhance the conservation aims of the protected area.Project’s Use of Cultural Heritage16. Where a project proposes to use the cultural heritage, includingknowledge, innovations, or practices of local communities forcommercial purposes, the client will inform these communities of (i)their rights under national law; (ii) the scope and nature of theproposed commercial development; and (iii) the potential consequencesof such development. The client will not proceed with suchcommercialization unless it (i) enters into a process of ICP as describedin Performance Standard 1 and which uses a good faith negotiationprocess that results in a documented outcome and (ii) provides for fairand equitable sharing of benefits from commercialization of suchknowledge, innovation, or practice, consistent with their customs andtraditions.PS 8, paragraph 12PS 8, paragraphs 13, 14and 15PS 8, paragraph 16Compliance Status/ FindingsNOT APPLICABLEAccording information from archaeological survey presented to IPHAN, thesites do not present non-replicable cultural heritage.NOT APPLICABLEAccording information from archeological survey presented to IPHAN(Refer to Annex A) there is no critical cultural heritage and the project is notinserted in legally cultural protected areas. Therefore, these requirementsare not applicable.NOT APPLICABLEThe scope and nature of the proposed project does not involve the use ofcultural heritage, therefore this requirement is not applicable.Recommended further actionsRefer to PS 8, paragraph 11.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL, 2012

Annex EGap Analysis Table –Logistics project

Review against IFC Performance Standard 1 (Environmental and Social Management and Evaluation Systems)Requirements of IFC PS 1Environmental and SocialAssessment and ManagementSystemIdentification of Risks andImpactsOrganizational Capacity andCompetencyRelated PSRequirements, EHSGuidelines(General, Ports,Harbors andTerminals) andLegal StandardsParagraphs 5 – 6 and 13to 16PS 1, paragraphs 7 to12PS 1, paragraphs 17 to19Current StatusThe Simplified Environmental Report – RAS for the intermodal terminal in Aparecida do Taboado-MS was developed by a third party company providing environmental and social impactassessment. Also, an Environmental Basic Plan- PBA was presented with environmental programsforeseen for the same multimodal terminal in order to describe mitigation and performanceimprovement measures and actions that address the identified environmental and social risks andimpacts of the project.ALL – America Latina Logística, will be responsible for the transport from Aparecida do Taboadountil the Port of Santos, and a railway brunch will have to be built. All the licensing process for thisrailway brunch will be conducted and managed by ELDORADO.Regarding the company EGTM Navegação (Torque) hired by Eldorado Brazil to work in logisticswaterways of cellulose, it was reported that the Service Agreement signed by the parties onDecember 22, 2011, has an item referring that EGTM Navegação (Torque) agrees to observe andcomply with environmental legislation, being responsible for fines and notices of violation ofactivities directly related to the transportation of cellulose, as well as for obtaining and maintainingany permits or licenses required by public agencies, due to the object of the contract.As for the MRS Logística S.A., the third party company responsible for transportation of the productfrom Pederneiras to the Port of Santos, it was shown the contract agreement signed by the parties,that MRS agrees to observe and comply with environmental legislation, being responsible for finesand notices of violation of activities directly related to the transport of cellulose. It was reported thatMRS will also be responsible for the construction of a new railway branch in Santos in order tounload the products in the area leased from Hipercon as well as for obtaining and maintaining anypermits or licenses required by public agencies, due to the object of the contract.At this phase of the project, no environmental or social management system has been developed.The Simplified Environmental Report – RAS for the multimodal terminal in Aparecida do Taboado-MS was developed by a third party company, comprising environmental and social impactassessment. The report does not cover risks and impacts for all phases of the project includingdeactivation of the terminal. It should also consider the emissions of greenhouse gases and potentialtransboundary effects; the cumulative impacts and impacts on the supply chain.As for the other areas of logistics interest it was reported that an economic feasibility assessmentconsidering risks of the modals and Net Present Value was performed. Reportedly, less impacts onthe transport system was considered.Specific personnel have been assigned for development of RAS of the multimodal terminal inAparecida do Taboado-MS. PBA shows responsibilities for implementation of environmental andsocial programs regarding this multimodal terminal.However, no information has been provided regarding roles and responsibilities for the otherlogistic areas within the environmental and social aspects of the project.Recommended further actionsELDORADO should consider the risk of being co-responsible by third parties’ actions or omissions byknowingly supporting, endorsing, or benefiting from them.ELDORADO shall develop an Environmental and Social Management System (ESMS), that includes:(i) Training program for employees and contractors with direct responsibility for activities relevant tosocial and environmental performance of the project;(ii) Actions to monitor the social and environmental performance of the contractors;(iii) Engagement and community participation (as described in the item below StakeholderEngagement; and(iv) Dissemination of information on the Action Plan through internal reports for management of theorganization and external stakeholders, including affected communities.ELDORADO should establish a formal environmental and social policy with specific performanceobjectives for the project and that must be disclosed to all employees and contractors involved in thevarious phases of the project.The RAS must identify environmental and social risks and impacts for all phases of the project,including deactivation of the terminal. It should also consider the emissions of greenhouse gases andpotential transboundary effects; the cumulative impacts and impacts on the supply chain.There should also be performed a risk and impact identification process, for the other areas/parts ofthe logistics project considering all relevant environmental and social risks and impacts of the project,including the issues identified in Performance Standards 2 through 8, and stakeholders who are likelyto be affected by such risks and impacts. It should also include the emissions of greenhouse gases, therelevant risks associated with climate change, adaptation opportunities, and potential transboundaryeffects, such as air pollution, as well as use or pollution of international waterways.Cumulative impacts should be assessed. Cumulative impacts are those that result from theincremental impact of the project when added to other existing, planned and reasonably predictablefuture projects and developments. For example it could be assessed cumulative impacts relatedexpansion of the existing terminal in Pederneiras since it already has operations. There should bepointed out the other existing facilities and which will be the cumulative impacts of the inclusion ofELDORADO’s entrepreneurship.The company should establish, maintain, and strengthen, as applicable, an organizational structurethat defines roles, responsibilities and authority to implement the Environmental and SocialManagement System (ESMS).Develop training program to support the designated personnel to carry out their role in the ESMS. Thetraining program shall ensure consistence with ELDORADO’s policies and procedures. The trainingcan be formal, informal (on-the-job), one-time, periodic, etc., as convenient to the company; however,training registers should be kept.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Requirements of IFC PS 1Emergency Preparedness andResponseMonitoring and ReviewStakeholder EngagementRelated PSRequirements, EHSGuidelines(General, Ports,Harbors andTerminals) andLegal StandardsPS 1, paragraphs 20, 21PS4, paragraph 11PS 1, paragraphs 22 to24PS 1, paragraphs 25 to33Current StatusELDORADO has not yet developed an emergency preparedness and response plan for the logisticsproject.ELDORADO has not yet developed procedures to monitor and measure the effectiveness of themanagement programs.The logistic process is composed by road, waterway, railway and port. Railway and waterway willbe operated by contractors that already own the lines (ALL, MRS and Torque). ELDORADO willhave the concession to operate at the port of Santos, which is managed by CODESP. ELDORADOwill have operational control on road transport.Thus, ELDORADO should be in charge to engage communities affected by road transportation andthe terminals at Aparecida do Taboado and Pederneiras. Stakeholder engagement process at Santosshould be conducted considering the process already undertaken by CODESP.A RAS was undertaken for environmental licensing purpose of the operation at Aparecida doTaboado. The study identified one community affected by the transport of cellulose, named Vestia,located at Selvíria. This community was already identified though the socio and economicdiagnostic undertaken and the EIA for the industrial operation.Currently, there is no initiative to stakeholders engagement in place in the logistic services.Reportedly, ELDORADO’s management system will provide the building of relationship with thestakeholders once logistic operations are implemented.Recommended further actionsThe Company should keep detailed information about the storage and transportation of hazardousmaterials in its area and terminals leased to fulfill the oversight role, in order to ensure compliancewith relevant legislation and develop an accurate and feasible emergency preparedness and responseplan.Particularly in the port of Santos, the company must align its Emergency Control Plan (PCE) with theEmergency Control Plan (PCE) from CODESP. In addition, ELDORADO’s PCE must be compatiblewith the PCEs from all port facilities and CODESP’s in a Mutual Aid Plan (PAM) feasible for the entireport area. The Company must integrate their Action Plan for Prevention of Environmental Risks(PRAs) with the Managing Body of Labor (OGMO).Emergency Plan should be communicated to affected community and relevant governmentalauthorities with responsibility on emergency situations, e.g, local police, hospitals, fire department,etc. in all multimodal terminal ports (Aparecida do Taboado, Pederneiras and Santos).Develop measures to monitor mitigation/control measures for socio-economic impacts.Develop measures to evaluate effectiveness of the implemented programs.Define measures to identify and monitor impacts on community health and safety (refer to PS4 forfurther recommendations).Identify any potential group that may be differentially or disproportionately affected by the projectand implement differentiated measures so that adverse impacts do not fall disproportionately on themand they are not disadvantaged in sharing development benefits and opportunities. If no group isidentified as vulnerable or differentially affected, prepare a formal document (a brief statement to thisfact is sufficient) to justify so.It is recommended that ELDORADO checks the engagement process undertaken by ALL, MRS andCODESP, in order to identify measures that are applicable to its logistics’ project or that could beundertaken jointly, if applicable.ELDORADO should include stakeholders related to the logistic operations on the currentlystakeholders initiatives, systemizing the process as recommended on PS1 paragraph 26 and 27 forIndustrial and Forest operation, as described below:Systematize the stakeholders identification and contact information, to enable evaluation andclassification of stakeholder, according to the following: Stakeholders affected by ELDORADO, positively and negatively, directly and indirectly,particularly those directly and adversely affected by project activities, including those that aredisadvantaged or vulnerable; Stakeholders who may be able to influence the outcome of the project because of their knowledgeabout the affected communities or political influence over them; Legitimate stakeholders representatives, including elected officials, non-elected communityleaders, leader of informal or traditional community institutions, and elders within the affectedcommunity; Stakeholders not directly affected by the project but may have the ability to influence or alter therelationship of the client with the affected community.If the complete impact and risk identification process that needs to be completed defines that thecommunity will be affected by ELDORADO, Stakeholder Engagement Plan is required. This shouldinclude: engagement principles; objective and criteria; risks and impacts; identification, characterization and priority of stakeholders, focusing on those directly affected bythe project and vulnerable groups; how interaction should be formalized; consultation frequency; grievance mechanism (refer to PS1, paragraph 35);ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Requirements of IFC PS 1Stakeholder EngagementRelated PSRequirements, EHSGuidelines(General, Ports,Harbors andTerminals) andLegal StandardsCurrent StatusRecommended further actionsPS 1, paragraphs 25 to33 list of time-bound activities, resources and responsibilities; communication channels, including those to disclosure information about risk and impact.The engagement process shall also support the update of risks and impacts of the operations toaffected community.Information about risks and impacts identified and mitigation measures shall be periodicallydisclosed to affected community, at least annually, as long the specific items in the managementprograms. ELDORADO may consider preparing a sustainability report on the financial,environmental and social aspects as a way to communicate and disclose relevant information tostakeholders.External Communications andGrievance MechanismsOngoing Reporting toAffected CommunitiesPS 1, paragraphs 34and 35PS 1, paragraph 36Reportedly, no grievance mechanism for logistic operations has been developed yet.For licensing purpose, public hearings are not planned or being considered by the company.Reportedly, no ongoing reporting to stakeholders is planned.It is recommended to expand the grievance mechanism currently in place for industrial and forestoperations to the logistics project. The company may also develop a specific mechanism instead,guaranteeing that it contains the following: the grievance mechanism must be available to all stakeholders: workers (employee,contractors), suppliers, affected community, and other significant categories identified byELDORADO; it shall be culturally appropriate, readily accessible to all workers; it must be defined roles and responsibilities for receiving the grievance and communicationflow; it must also define the channel for provision of feedback and time to do so; the mechanism should be able to receive and treat all grievances, including those related tosecurity personnel abuses and others.Refer to engagement process, paragraph 25 to 33 above.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 2 (Labor and Working Conditions)Requirements of IFC PS 2Working Conditions andManagement of WorkerRelationship and Protectingthe Work ForceRelated PSRequirements, EHSGuidelines(General, PortsHarbors andTerminals) andLegal StandardsPS 2, paragraphs 7 to22Federal Decree5.598/05 - Regulatesthe employment ofapprentices and othermeasures.Federal Decree3.597/00 Promulgatethe 182 ILOConvention and 190ILO, Recommendationconcerning the worstforms of child labourand immediate actionto eliminate them,convened in Geneva,June 17 1999.Federal Decree4.134/02 Promulgatethe 138 ILOConvention and 146ILO, Recommendationon minimum age foradmission toemployment.Decree 6.481/2008 -Regulates Articles 3and 4 of the ILOConvention 182concerning the worstforms of child labourand immediate actionto eliminate them,convened in Geneva,June 17 1999.Current StatusMost of the logistics operations shall be conducted by third part contractors, as previouslydescribed.Reportedly, contractor’s workers and employees shall be hired locally, for which no migrant workwill be required.At this moment, ELDORADO’s employees working for logistics operations are performingadministrative routines and planning activities and no activity is performed at the logistics sites.Therefore, for this assessment, no employee was interviewed neither were assessed their workingconditions.Reportedly, labor and working conditions shall be the same as applied the industrial operation(refer to ERM Report, Environmental and Social Assessment of Industry and Forest Projects ofELDORADO, reference 0152083).Recommended further actionsRecommendations for further actions are based on the recommendations described for the employeesworking conditions for the industrial operation, detailed below:1. Develop a Human Resource Policy, procedures or ethical code appropriate to the ELDORADO, to beapplied for workers, contracted workers and supply chain workers. That covers: Working conditions: e.g physical environmental, health and safety precautions, treatment ofworkers, disciplinary practices, respect to workers’ personal dignity (such as refraining fromphysical punishment or abusive language), terms of employment (wages, benefits, wage deduction,hours of work, breaks, rest days, overtime arrangement, overtime compensation, medical insurance,pension, and leave for illness, vacation, maternity and holiday). Collective bargain and freedom of association; Nondiscrimination and Equal Opportunity; Grievance mechanism; Child Labour; Forced Labour; and Right to privacy about surveillance methods (being filmed and body and personal belongs search)and personal data that will be kept and how will it be used.Workers must receive information about the policy, procedure or ethical code. It is recommended topublic disclosure it.2. Take measures to prevent any harassment, including sexual harassment or psychologicalmistreatment within the workplace, e.g: include a module about harassment for leaders, managers; and monitor and treat cases of harassment identified through ombudsman.Include on all workers induction information about harassment.Define measures and orient contractors on prevention of discrimination in employment relationship.3. Monitor compliance with the quota for disable workers and apprentice. If applicable, consider on thecompany’s overall quota, logistics activities that could be performed by disable people and apprentices.4. Prior to implementing any collective dismissals, the client should carry out an analysis of alternativesto retrenchment, as detailed on PS2, paragraph 15 for industrial operation.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Requirements of IFC PS 2Occupational Health andSafetyWorkers Engaged by ThirdParties and Supply chainRelated PSRequirements, EHSGuidelines(General, PortsHarbors andTerminals) andLegal StandardsPS2, Paragraph 23Brazilian RegulatoryNorms (NRs) related toHealth & Safety..IFC GeneralEnvironmental, Healthand Safety (EHS)GuidelinesIFC Environmental,Health and SafetyGuidelines – Ports,Harbors and TerminalsPS 2, paragraphs 24 to29Current StatusThe logistics operations will comprise road, waterway, railway and port. Railway and waterwayoperations will be conducted by contractors that already operate the existing lines (ALL, MRS andTorque). ELDORADO will have the concession to operate at the port of Santos, which is managedby CODESP.ELDORADO will have operational control on road transport.The operation of the Aparecida do Taboado multimodal terminal will be conducted by ALL(América Latina Logística).The multimodal terminal in Pederneiras will be operated by the company that already operates agrains terminal at the area (EGTM Navegação – Torque).The operations of the port terminals will be conducted by a hired third party company. Accordingto information provided, ELDORADO is currently in process of hiring the company which willoperate the port terminals (bidding process). The request for proposal includes, among otherclauses, the requirement of a Health, Safety and Environmental management system.As for the Pederneiras Terminal, ERM was informed that a contract with EGTM Navegação –Torque was signed on December 22, 2011.No information is available about the construction stage in the port of Santos, or in Pederneiras,where the construction will be responsibility of EGTM Navegação – Torque.As previously described, most of the logistics operations shall be conducted by third partcontractors: Transport of cellulose through river to Pederneiras will be carried out by the company namedTorque; Transport of cellulose by road from Tres lagoas to Aparecida do Taboado will be carried out bya third part company, not selected yet; Railyway transportation from Pederneiras to Santos will be carried out by MRS, while fromAparecida do Taboado to Santos will be in charge of ALL, The transfer of the product between modals will be in charge of the railway’s companies andTorque, according to each modal; and Temporary transport of the cellulose from the railway to the Port of Santos’ terminal will becarried out by a third part company, not selected yet.At Aparecida do Taboado a terminal and an internal railway branch will be built. At Pederneiras,EGTM Torque will be in charge of the expansion of the existing terminal and the construction of therequired warehousing space for pulp storage. At Santos, two internal railway branches will beconstructed by MRS.At Port of Santos, workers working at the ELDORADO’s terminals will be hired by the Company.Workers in charge of shipping process are managed by port of Santos organization (OGMO).Companies operating in the port have limited supervision over it.Reportedly, all contracts signed between ELDORADO and contractors have a clause stating that nopart shall employ slavery like and/or child labor.Recommended further actionsIn the construction and operation stages, ELDORADO shall guarantee that the companiesresponsible for construction and operation are compliant with the Brazilian Health & Safetyrequirements and IFC General Environmental, Health and Safety (EHS) Guidelines and the IFCEnvironmental, Health and Safety Guidelines – Ports, Harbors and Terminals, including, amongothers, the following main programs: Occupational Risks Prevention Program (PPRA) as required by Brazilian standard NR-09, for theindustrial operations; Workplace Environmental Conditions Program (PCMAT), as required by Brazilian standard NR- Medical Surveillance and Occupational Health Program as required by Brazilian standard NR-07; Health and safety training program in accordance with Brazilian legislation; Emergency response plan for the existing facility; Accident and incident records, investigations and divulgation; Occupational diseases records, investigations and divulgation; and Personal Protective Equipment, as required by Brazilian standard NR-06.Among other documents that evidence implementation of the required programs.Refer to PS2, paragraph 7 to 22, that recommends aspects to be covered by the Human Rights Policyor code of conduct, which shall be applied to contractors’ workers as well.Include the contractor’s workers on the grievance mechanism, as described on PS 1, paragraph 34and 35Take measures to guarantee that terminal expansion and railway branch are complying with labourrights and other issues addressed by these performance standards (freedom of association andcollective bargain, non-discrimination in employment relationship, harassment, child and forcedlabour). This could be done through regular visits to the site, audit process, etc.Take measures to orient logistics contractors on compliance with labour rights mentioned above.These could be done through contractual clauses and orientation to comply with the companies codeof conduct or human right policy (as recommended on PS2 paragraph 7 to 22 , above).Include on suppliers clause that states that both parts are responsible to avoid the employment childor forced labour.Identify categories of significant suppliers and contractors in the primary supply chain in high risk ofchild labour and forced labor or other abuses to labour rights. Define measures to monitor significantsuppliers and contractors on employment of child labour and forced labour or to employ abusespractices human rights. The measures shall be defined according to the suppliers/contractors risk.High risk suppliers shall be audited on a periodic basis and registers should be kept within theEnvironmental and Social Management System.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 3 (Resource Efficiency and Pollution Prevention)Requirements of IFC PS 3Related PSRequirements, EHSGuidelines(General, Ports,Harbors andTerminals) andLegal StandardsResource Efficiency PS 3, paragraphs 4 to 9Federal Ordinance2914/2011, whichestablishes thedrinking waterstandards in Brazil.Pollution Prevention PS 3, paragraphs 10and 11IFC GeneralEnvironmental, Healthand Safety (EHS)GuidelinesIFC Environmental,Health and SafetyGuidelines – PortsHarbors and TerminalsFederal IBAMAOrdinance 85/1996,which establishes thatall company providedwith a fleet for materialor peopletransportation mustinternal program forthe fleet black smokeemission andmaintenance control.Current StatusELDORADO’s logistics operation is still in the detailing study stage.However, the process envisioned by ELDORADO will apply techniques to improve efficiency ofthe pulp transport, such as the partial transport through water way (Paraná-Tietê hydro-way) andrailway. The process is designed to minimize the transport by trucks, thus allowing the reduction offossil fuel use.When fully operational, the use of automated pulp loading and unloading will also minimize theuse of fossil fuel.ELDORADO has not yet estimated the carbon dioxide emission equivalents for the project. Asinformed, this estimate is currently being developed, in spite of not being required by the Brazilianregulations.The logistics operations are not associated with high water consumption. The main water use willbe associated with human consumption. According to information provided by ELDORADO, nomaintenance activities will be performed in the terminals.In the port of Santos terminals, water is supplied by CODESP, which has two distribution systems:drinking water and reuse water. CODESP is supposed to deliver water to the consumers complyingwith the drinking water standards established by Brazilian regulations. However, ELDORADO isresponsible for preventing water contamination inside its installations.In Aparecida do Taboado a deep well will reportedly be installed to supply water for domestic use.No details on the water distribution system are still available. Water quality in Pederneiras will beresponsibility of EGTM – Torque and in Aparecida do Taboado of ELDORADO.Reportedly, the installation of the terminals by ELDORADO will not include construction andmaintenance dredging. Therefore, no dredging planning, execution or disposal of dredged materialis applicable.Air emissions associated with the logistics operations will be restricted to the burning of fossil fuelin vehicles. Reportedly, no other sources will be present on the terminals such as combustionsources (boilers, kilns) or handling of hazardous materials that could be associated with VOCemissions. In addition, ELDORADO operations will not be associated with fugitive emissions.As reported, no maintenance activities will be conducted in the terminals operated by ELDORADOor delegated to third party companies in Santos and Pederneiras. A maintenance workshop will bereportedly be constructed in Aparecida do Taboado. Sanitary effluents will be generated in allterminals. In Santos, CODESP is responsible for wastewater collection and treatment. ELDORADOwill reportedly not receive wastewater from ships, given that there are international regulationsgoverning this issue (Marpol).In the other terminals, no details are available yet. Sanitary wastewater treatment, if required, willbe responsibility of EGTM-Torque in Pederneiras and ELDORADO in Aparecida do Taboado. Asfor maintenance effluent, ERM was informed that an oil/water separator will be installed inAparecida do Taboado.According to information provided by ELDORADO, no hazardous materials will be handled in theterminals. In the construction stage, in Santos, the demolition will generate asbestos-containingwastes, which are present in the form of roof-tiles in Warehouse XVIII, that will be demolished.Recommended further actionsWhen estimating the emission of carbon dioxide equivalents for the project, ELDORADO shouldinclude the emissions associated with the pulp transport.ELDORADO shall guarantee that no water contamination occurs inside its installations in Santos. InAparecida do Taboado and Pederneiras, ELDORADO shall guarantee that the third party companiesdistribute water for human consumption in compliance with the drinking water standards.Additionally, for the well installation in Aparecida do Taboado, ELDORADO shall apply for a waterabstraction permit.ELDORADO shall guarantee that the vehicles used inside the terminals are well tuned, bymonitoring black smoke emissions, according to applicable regulation. An internal maintenance planshall be developed.ELDORADO will not have interference in the barges, railway and ships emissions. However, wherefeasible, ELDORADO should require operators to follow national and international regulations (inthe case of ships).As good management practice, ELDORADO should monitor the wastewater treatment and disposalat Aparecida do Taboado and follow up with third party company at Pederneiras Terminals.ELDORADO should develop a procedure for asbestos-containing materials (ACM) handling orrequire the company hired for the demolition, if this is the case, to have a procedure in place, andguarantee that employees are properly trained to handle ACM.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Requirements of IFC PS 3Pollution PreventionRelated PSRequirements, EHSGuidelines(General, Ports,Harbors andTerminals) andLegal StandardsFederal CONAMAResolution 420/2009,which establishes thecriteria and soil qualityoriented values andguidance for themanagement ofcontaminated areas.CONAMA Resolution430/2011, whichestablishes the nationaleffluent dischargestandards.State DeliberationCECA/MS 03/1997,which establishes thewastewater dischargestandards in the Stateof Mato Grosso do Sul.Current StatusAs for soil/groundwater contamination, the loads to be handled in ELDORADO’s terminals(bleached kraft pulp) do not represent potential for soil/groundwater contamination. During thevisit to the Terminal Elmar in Santos, no potential for soil/groundwater contamination wasobserved by ERM.The São Paulo State Environmental Agency (CETESB) issued a statewide Contaminated AreasReport that includes the contaminated Sites in the State of Sao Paulo that are registered with theAgency. CETESB began developing this report in May 2002 and it includes only those sites wherecompanies have voluntarily disclosed information regarding soil/groundwater contamination. Ingeneral, this report is updated once a year and was last updated in November, 2010. The reportdoes not contain details regarding contaminated areas, such as results of investigation analyses,dates of investigation, remediation, sizes of the areas affected by contamination, etc. It only givesinformation on the main contaminants and status of the Sites in terms of investigation/remediationefforts.The area located out of the organized port of Santos, operated by Hipercon Terminais, with whichELDORADO will sign a service provision contract, is not listed in CETESB’s website as acontaminated area. However, it is surrounded by bulk liquid terminals, which are listed ascontaminated areas (Stolthaven Santos, Ultragaz, Tequimar, etc.). ERM understands that theoperations with ELDORADO’s finished product (bleached kraft pulp) at that area will not representan additional potential for soil/groundwater contamination in the area. Additionally, according toinformation provided by ELDORADO, Hipercon Terminais operations at the area are mostly relatedto receipt and shipment of sugar. However, regardless of the product handled on behalf ofELDORADO being a non-contaminating material, ELDORADO could be deemed co-responsible ifa contamination at the area is detected.Recommended further actionsERM considers that ELDORADO should request Hipercon Terminais to assess contamination in itsarea to establish the baseline conditions, given that migration of contaminants from surroundingareas cannot be totally ruled out.Wastes PS3, paragraph 12Brazilian StandardNBR 10004, whichclassifies the wastesinto three categories:Class I (hazardous),Class IIA (nonhazardous,non-inert)and Class IIB (inerts).Federal CONAMAResolution 362/2000,which establishesguidelines forcollection and disposalof spent lubricatingoils.Federal CONAMAResolution 358/2005,which establishescriteria for treatmentand disposal of clinicalwastes.Reportedly, ELDORADO will not receive wastes from ships, given that there are specializedcompanies designated by CODESP to conduct this activity and give proper final disposal to thewastes.In Santos, according to documents reviewed and information provided by ELDORADO, CODESPis responsible for indicating the final disposal to be given to wastes generated in the port area.According to information obtained from the environmental agency – CETESB’s website, CODESPholds the required waste transfer permits for hazardous wastes generated in the port are, includingasbestos-containing wastes.During the demolition/construction stage, potentially asbestos-containing wastes will be generatedby the removal of fiber-cement (Transite type) roof tiles in Warehouse XVIII. The final disposal to begiven will be determined by CODESP, which holds a waste transfer permit for asbestos-containingwastes issued by the State Environmental Agency (CETESB). The final disposal given by CODESP iscompliant with the applicable regulations. ELDORADO will be financially responsible to dispose ofthis waste. Other wastes, if generated, will have to be disposed of according to the applicableregulations.Regarding the Aparecida do Taboado and Pederneiras Terminals, no information on wastesgeneration is available.In Aparecida do Taboado, ELDORADO will be responsible for the disposal of the constructionwastes, during the construction stages. In the operation stage, ALL will be responsible for thewastes disposal.In Pederneiras, EGTM-Torque will be responsible for the wastes disposal, both during theconstruction and the operation stages.ELDORADO shall guarantee that wastes generated both during the construction stage and operationstage will be given adequate final disposal, according to applicable regulations, at licensed facilities.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Requirements of IFC PS 3WastesRelated PSRequirements, EHSGuidelines(General, Ports,Harbors andTerminals) andLegal StandardsCONAMA Resolution307/2002, whichestablishes thestandards to managecivil constructionwastes and classifiesthe wastes according toits origin.CONAMA Resolution348/2004, modified theCONAMA Resolution307/2002, andincluded asbestos inthe hazardous wastescategory.CONAMA Resolution05/93 – establishes theobligation to develop aPlan for Solid WasteManagement in portprojects.Federal Law nº12.305/2010 NationalWaste Policy regulatedby Federal Decree No.7404/2010.Current StatusRecommended further actionsHazardous MaterialsManagementPS3, paragraph 13InterministerialOrdinance 124/80,which gives directivesfor the storage ofpotentially pollutingmaterials.Federal Regulatorystandard NR-20, whichaddresses the storageof flammablematerials.NBR 17505, whichgives directions for thestorage of petroleumand petroleumproducts.Pesticide Use and Management PS 3, paragraphs 14,15, 16 and 17Reportedly no hazardous materials will be handled in the terminals, except for the Aparecida doTaboado terminal, where, a maintenance workshop will be operated. No details on the operationsto be conducted in the terminal are available.No use of pesticides is estimated for the logistics project.ELDORADO shall guarantee that hazardous materials to be used in Aparecida do Taboado will behandled and stored according to applicable regulations.Not applicable.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 4 (Community Health, Safety, and Security)Requirements of IFC PS 4Community Health andSafetyRelated PS Requirements,EHS Guidelines (General,Ports, Harbors andTerminals) and LegalStandardsPS4, paragraphs 5 to 11EHS Guidelines Paper andPulp item 1.3Current StatusConsidering the size of the logistics projects , that no inflow of workers is planned and that mostof the activities will be performed by contractors that already operate in the area (waterway, railway and port), ELDORADO should be in charge to identify risks and impacts to communityhealth for the road transportation, the railway branch (construction and operation at Aparecidado Taboada, Pederneiras and Santos) and terminal expansion (at Pederneiras and Santos)Reportedly, communities impacted by the road transportation are included on the EIA and thearea impacted by industrial operation. Recommendation for the communities impacted by theindustrial operation is described on the PS4 for industrial operation (Refer to ERM Report,Environmental and Social Assessment of Industry and Forest Projects of ELDORADO, reference0152083).Security Personnel PS4, paragraphs 12 to 14 Security Personnel shall be provided by those in charge of each modal of logistic operation,which include the terminals in Aparecida do Taboado and Pederneiras. At Santos Port,HIPERCOM will be in charge of hiring security personnel for their area, ELDORADO will be incharge of the area inside the organized Port called Terminal Elmar and CODESP of the generalsecurity services of the Port.As reported on the assessment of the industrial operation (PS4, paragraph 12 to 14)ELDORADO does not provide training to security personnel, neither there is a systemicprocedure to verify if those providing security are not involved in past abuses.Recommended further actionsVerify the process to identify health and safety risk and impact undertaken by ALL, MRS andCODESP, checking upon measures that are applicable to ELDORADO or that could beundertaken jointly, if applicableIdentify risks and impacts to community health and safety due to the road construction andoperation (e.g. risk of coalition and traffic incidents), the railway branch and terminals(construction/expansion and operation) and to define the appropriate measures.Provide workers with transportation services educational programs related to sexual transmittedillness STIs and prevention of fatalities and injuries.Provide workers performing activities at the port of Santos educational programs related to STIs.Verify documentation of those providing security personnel to guarantee that all workers andcompanies are authorized to perform the activity, following the verification done for industrialand forest operation.Include on the consultation process the practice to consult local government, communities,workers and those providing security personnel to identify effects of the companies securityarrangements.Define procedure about correct conduct and use of the force by security personnel. This shallinclude measures to investigate and treat denounce of human right abuse committed by thoseprovide security.Monitor those who provide security arrangement to identify compliance with the abovementioned procedure.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 5 (Land Acquisition and Involuntary Resettlement)Requirements of IFC PS 5Related PSRequirements, EHSGuidelines (General,Ports, Harbors andTerminals) and LegalStandardsPS5, paragraphs 8 to 39Current StatusRecommended further actionsGeneral Requirements andDisplacementAt Aparecida do Taboado, ELDORADO acquired a land where the terminal will be installed.The land was a part of a cattle raising farm and, reportedly, no resettlement was undertaken.At Pederneiras, no area is to be acquired or leased. The Pederneiras’ terminal will be operatedby EGTM Torque that already owns the land to operate waterway terminals. Reportedly, noresettlement will be carried out.Acquisition of other lands is not planned, as informed by ELDORADO.Not applicable.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources)Requirements of IFC PS6Related PSRequirements, EHSGuidelines (General,Ports, Harbors andTerminals) and LegalStandardsCurrent StatusRecommended further actionsGeneral PS 6, paragraphs 6 to 8 ELDORADO’s information regarding this item is reported in PS 1, paragraphs 7-12. With regards to Aparecida do Taboado, ELDORADO should:The risks and impacts identification process as set out in Performance Standard 1 should considerdirect and indirect project-related impacts on biodiversity and ecosystem services and identify anysignificant residual impacts.Make an integrated assessment of all components of the biota (analyzing the communities) and laterincorporate aspects of both the physical and biotic environment. Example: identify and characterize thenatural remnants of the project’s area of influence and perform a landscape analysis.Protection andConservation ofBiodiversityManagement ofEcosystem ServicesSustainable Managementof Living NaturalResourcesPS 6, paragraphs 9 to 23Federal Law nº 4771,September 15th, 1965 andalterations – Establishes thenew forest codeFederal Law nº 6.938,August 31st, 1981 andalterations- Provides for theNational EnvironmentalPolicyConama Resolution nº 369,March 28th, 2006 - Providesfor the exceptional cases,public utility or socialinterest low environmentalimpact, which enableintervention or suppressionof vegetation in PermanentPreservation Area-APP.Federal Law nº 6.902, April27th,1981- Provides for thecreation of EcologicalStations, EnvironmentalProtection Areas and othermeasures.PS 6, paragraphs 24 and 25PS 6, paragraphs 26-29ELDORADO has provided a document called Technical Project for Inexistent Legal ReserveRegularization for Boa Esperança farm in Aparecida do Taboado-MS. The report presentsenvironmental diagnosis of the area and the proposal to conduct recovery through naturalregeneration, improving protection measures and soil conservation, physical isolation of thelegal reserve area with the opening of clearings in the surroundings; protect the area fromhunting and predatory fishing. It was also provided the request to the state environmentalagency (IMASUL) regarding the term of commitment for recovery of the legal reserve and theterm of commitment as owner of the land submitted in November 2011.Along with the Simplified Environmental Report – RAS of Aparecida do Taboado it waspresented the identification of Protect Areas of Cerrado and Mata Atlântica Biomes (with highpriority of conservation) inside the area of influence of the project.Reportedly, the multimodal Terminal in Pederneiras will be managed by a third partycompany which will be responsible to comply with all items related to permitting, and otherenvironmental legislation issues. Refer to PS1, paragraphs 5-6.For the areas of the port terminal in Santos, the warehouses are inside already occupied areasand therefore this item is not applicable.Since the logistic activities will not cause significant impacts on ecosystem services (theselected areas do not preserve their original characteristics and are highly degraded), thereforethis requirement is not applicable.Not applicable. The logistics projects is not engaged in the primary production of livingnatural resources, including natural and plantation forestry, agriculture, animal husbandry,aquaculture, and fisheries.Supply Chain PS 6, paragraph 30 Not applicable. The client is not purchasing primary production (especially but not exclusivelyfood and fiber commodities) that is known to be produced in regions where there is a risk ofsignificant conversion of natural and/or critical habitats.With regards to Aparecida do Taboado, ELDORADO should: Evaluate the possibility of creating a non-isolated legal reserve, trying to connect it to othernatural remnants. Evaluate the effectiveness of the “natural regeneration” process. Depending on the characteristicsof the secondary vegetation, additional efforts should be taken to guarantee a proper recovery ofthe natural vegetation.ELDORADO should ensure the same requirements above for the third party company responsible foroperating and managing Pederneiras terminal.Not applicable.Not applicable.Not applicable.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 7 (Indigenous Peoples)Requirements of IFC PS 7Related PSRequirements, EHSGuidelines (General,Ports, Harbors andTerminals) and LegalStandardsPS 7, paragraphs 8 to 22Current StatusRecommended further actionsGeneral, CircumstancesRequiring Free, Prior, andInformed Consent,Mitigation andDevelopment Benefits,Private SectorResponsibilities WhereGovernment isResponsible for ManagingIndigenous Peoples IssuesFor Aparecida do Taboado terminal, a RAS was undertaken. Reportedly, to start the RASprocess, ELDORADO entered coordinates of the area in the IMASUL software named SISLA,which indicates that there was no indigenous land or traditional people near the area. Thisinformation was confirmed by ERM team.No land is planned to be acquired at Pederneiras, where Torque already operates a terminal.According to the National Indian Foundation (FUNAI) website, no indigenous people arelocated at this municipality or are near by the Tietê river.This PS is not applicable to the port of Santos due to the activities already develop ed at thesite. In addition, port of Santos is located within the municipality of Santos, an urban area.Not applicable.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Review against IFC Performance Standard 8 (Cultural Heritage)Requirements of IFC PS 8 Related PSRequirements, EHSGuidelines (General,Ports, Harbors andTerminals) and LegalStandardsProtection of CulturalHeritage in Project Designand ExecutionPS 8, paragraphs 6 to 15Decree Law nº 25/1937 -Organizes the protectionof historical and artisticheritage.Law nº 3.924/1961Provides for thearchaeological andprehistoric sites.Compliance Status/ FindingsNo evidence has been provided regarding protection of cultural heritage.Recommended further actionsIf archaeological and cultural remains are found during construction , the works must be stopped andan expert in the field should be called for inspection. It requires training of workers so they can identifythese remains during construction. This is valid for Aparecida do Taboado and Pederneiras Terminal.ELDORADO should identify and protect cultural heritage by ensuring that internationally recognizedpractices for the protection, field-based study, and documentation of cultural heritage are implemented.The Company should consult with the Affected Communities to identify cultural heritage ofimportance, and to incorporate into the client’s decision-making process the views of the AffectedCommunities on such cultural heritage. This is valid for Aparecida do Taboado and PederneirasTerminal.As for the Port Terminal in Santos, studies should have already been performed by IPHAN since theareas is already occupied for a long period of time. It is recommended to check this information withthe institute.Project’s Use of CulturalHeritagePS 8, paragraph 16Not applicable. The project does not proposes to use the cultural heritage, includingknowledge, innovations, or practices of local communities for commercial purposes.Not applicable.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Annex FPhotolog

Selected Photographs (Date 2012): ELDORADO01 View of Jatiuca Farm Main House.04 Bathroon at Taruana Farm.02 Plaque at Correntes I and II Farms.05 Contractor with PPI to apply pesticide atTaruana Farm.03 Resting and lunch area at Taruana Farm.06 Interview with rural worker (contractor).ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Selected Photographs (Date 2012): ELDORADO10 Mechanized Planting at Barraca Farm.07 Bus used to transport rural workers atTaruana Farm.08 Workers from Taruana Farm having lunch.11 Semi-mechanized irrigation at BarracaFarm.09 House from a landless movementparticipant, near to Correntes I and II Farms.12 Semi-mechanized irrigation at BarracaFarm.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Selected Photographs (Date 2012): ELDORADO13 Accomodation Inocencia.16 Accomodation Agua Clara.14 Worker being interviewed at AccomodationInocencia.17 Accomodation Agua Clara.15 Room at Accomodation Inocencia.18 Accomodation Agua Clara II.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012

Selected Photographs (Date 2012): ELDORADO19 Room without window at AccommodationAgua Clara II.22 Training Center at Santa Maria Farm.20 Manual planting at Barra Mansa Farm.21 Training Center at Santa Maria Farm.ENVIRONMENTAL RESOURCES MANAGEMENT ELDORADO – APRIL 2012