Termoflores

Environmental & Social Review Summary

This Environmental and Social Review Summary is prepared and distributed in advance of the IFC Board of Directors’ consideration of the proposed transaction. Its purpose is to enhance the transparency of IFC’s activities, and this document should not be construed as presuming the outcome of the Board of Director’s decision. Board dates are estimates only.
Any documentation which is attached to this Environmental and Social Review Summary has been prepared by the project sponsor and authorization has been given for public release. IFC has reviewed this documentation and considers that it is of adequate quality to be released to the public but does not endorse the content.

Project number	27396
Country	Colombia
Sector	Utilities
Department	Infrastructure
Company name	Termoflores S.A. E.S.P.
Environmental category	B
Status	Active

Date ESRS disclosed	December 23, 2008

Previous Events	Invested: November 13, 2009 Signed: September 30, 2009 Approved: September 21, 2009

View Summary of Proposed Investment (SPI), click here

Overview

Category & Applicable Standards

Key Issues & Mitigation

Community Engagements

Client's Documentation

Overview of IFC's scope of review

IFC’s appraisal of this project consisted on an extensive desk review of environmental, social, health and safety, and labor information, including the revision of three Environmental Impact Assessments for the existing phases (Flores I, II, and III), and a new Environmental Management Plan updated for Flores IV, the “Project”.

Furthermore, an environmental specialist and a social specialist based in IFC HQ in DC performed a site visit to Termoflores in Barranquilla, and held meetings with Termoflores’ Environmental Manager, Occupational Health and Safety Manager, HHRR Manager, security personnel, the EPC’s EHS Coordinator, and with SIESCO team which is the consulting firm appointed by the Environmental Ministry to perform the Interventoría Ambiental and therefore supervises environmental compliance of both, the existing operations and the works associated with the expansion (Flores IV). During the site visit, the IFC team inspected all existing operations, visited the site where the Flores IV will be built, reviewed in-site application of the EMPs, assessed general housekeeping, and reviewed environmental monitoring data (e.g. air quality, stack emission, noise, wastewater, etc) and occupational health and safety data (e.g. accident/incident reports, training, PPE use, etc).

Project description

The project consists of the construction of a 169 MW natural gas-fired combined cycle unit by Termoflores S.A. E.S.P. (“Termoflores” or “the Company”), a generation company whose operations are located in Barranquilla, Colombia. Currently, Termoflores has three natural gas-fired units in operation, (the Flores I combined-cycle and the Flores II and III open-cycle) with a total installed capacity of 441 MW. Flores IV includes the expansion/conversion of the existing gas turbines in Flores II and III from open cycle to a combined cycle facility, by adding a new steam turbine generator, heat recovery steam generator and balance of plant equipment. Flores IV will utilize the waste heat from Flores II and III to provide 169 MW of additional capacity without using significant additional gas. After the Project is completed, Termoflores will have two operating units (Flores I and Flores IV) with a generation capacity of 610 MW. The estimated construction time is 25 months and project completion must be attained before December 1, 2010.

The cost of the project is estimated at $278.2 million. The project will be financed with $55.6 million of equity (from cash from operations) and $222.6 million of debt. The debt component includes:

- IFC A/B facility of $200 million, and
- local currency loan of $22.6 million equivalent.

In addition to the reliability charge, the company expects to generate revenues from CO2 emission reductions of about $4 million per year, based on CO2 emission reductions approximately 460,000 MT per year.

Identified applicable performance standards

While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts that must be managed in a manner consistent with the following Performance Standards:

- PS1: Social and Environmental Assessment and Management System
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health Safety and Security

The following PSs have not been triggered by the project:

PS5: Land Acquisition and Involuntary Resettlement – The new expansion required the purchase of a 17,854.02-m2-industrial plot next to existing Termoflores facilities, and two smaller plots associated with water intake infrastructure in the Magdalena River (1,960.6 m2 and 4,425.09 m2). These plots were purchased under willing-buyer-willing seller conditions, are currently owned by Termoflores, and did not require any physical or economic displacement of people. In 2005, these plots were registered together with the plot currently occupied by Flores I, II and III, and are now considered as a single industrial property with a total area of 107,952.09 m2.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management – the Project is located within an industrial highly-intervened-peri-urban area, with no ecological or conservation value. Even though the water intake from the Magdalena River will increase from 77 l/sec to 280 l/sec, it is not expected to affect the Magdalena River’s integrity as it represents less than 0.003% of its annual average flow.

PS7: Indigenous Peoples - the project is located within an industrial highly-intervened-peri-urban area, and will not affect indigenous people or territories.

PS8: Cultural Heritage - the project is located within an industrial highly intervened-peri-urban area, with no archeological and cultural value. During the preparation of the updated Environmental Management Plans, and as required by Colombian regulations, the company performed and archeological survey at the new site. This survey found no archeological evidence. At any case, the projects Environmental Management Plan, includes a Chance Find Procedure.

Environmental and social categorization and rationale

Termoflores is an existing natural gas fired power generation plan, which has been in operation for more than tens years. It is located on a highly intervened industrial zone of Barranquilla, and is currently in compliance with air, noise, wastewater, and solid waste Colombian discharge and emission standards as well as all labor and occupation health and safety regulations. The stack emissions are also in compliance with the Thermal Power: Guidelines for New Plants, included in the World Bank’s Pollution Prevention and Abatement Handbook (1998). The upgrade from simple to combined cycle of Flores II and III, will generated more energy without significantly increasing fuel consumption, and operational measures such as vapor injection in Flores II, and the installation of a wet compression in Flores II and III which reduce NOx emissions.

Therefore, given that this project will improve the environmental footprint of an existing power generation plan, and the incremental environmental, social, and health and safety impacts and risk can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, and/or design criteria, this project has been categorized as a B operation.

Key environmental and social issues and mitigation

PS 1 – Social and Environmental Assessment and Management Systems

Environmental and Social Assessment –

Termoflores has developed a total of three different Environmental Impact Assessments. The first one, prepared for Flores I as a greenfield project, was finalized in June 1993, presented to and approved by INDERENA via Resolución Ambiental No 1516 (Nov 21st, 1993). This EIA was prepared by an external consulting firm Ambiotec, which also prepared the EIAs for Flores II (1992) and Flores III (1996). The latter two were presented to and approved by the Ministry of Environment, via Resolución Ambiental No 372 (April 12th, 1996) and Resolución Ambiental No 056 (January 28th, 1997), respectively. These assessments use the original EIA as a basis, and essentially updated the environmental and social baselines (e.g. air quality, noise, socio-economic) to assess the potential impacts of the respective expansions. These EIAs appropriately identified potential impacts and risks associated to the construction and operation of the different phases of Termoflores, modeled air emission dispersion for each case, and developed environmental, social and occupational health and safety, as well as spill prevention and emergency control plans to avoid or mitigate such impacts.

For the Flores IV expansion, there was no need to develop an additional EIA, but essentially the Ministry of Environment asked for an updated version of the Environmental Management Plans (EMPs). The updated EMPs were prepared by another external consulting firm, Estudios y Proyectos Ambientales y Mecánicos (EPAM S.A. ESP) which were approved via Resolución Ambiental No 1003 (Jun 7th , 2007).

The key environmental, social, and health and safety impacts and risks associated with the Project’s construction phase are those typically associated with construction and civil works such as increased noise and air emissions, construction solid waste and waste water management, occupational health and safety of construction workers, and risks associated to the operation and handling of heavy equipment and machinery. All these impacts and risks can be managed with existing pollution prevention and control technologies and with standard environmental management practices.

In general terms, it can be stated that the environmental footprint of the operation of the plant per KWh/hour generated will be reduced, since this project involves the installation of a heat steam generator on two existing gas turbines (upgrade from simple to combined cycle), thus generating 169 MW more without significant additional fuel consumption. The key environmental, social, and health and safety impacts and risks associated with the operational phase are those related with increase in generation capacity of an already existing plant, and thus are limited to:

- Increase water use from 77 to 280 l/s
- Increase sludge generation from the process water treatment system from 1.9 to 9.0 tons/day (wet base)
- Seventy percent (70%) reduction on NOx emissions.
- Reduction of temperature of the stack emissions (412 oC and 488 oC less for Flores II and III, respectively)
- Continued generation of air emission, noise, and industrial wastewater discharges.
- Continued use and handling of HAZMAT (e.g. lubricants, oil and greases, di-electric oils, etc) and subsequent generation of hazardous waste.
- Continued generation of domestic solid waste and domestic wastewater.
- Continued existing occupational risk to plant employees (e.g. working in confined spaces, hot conditions, heights, handling heavy equipment, etc)
- Continued/increased existing nuisances to nearby communities (e.g. traffic, noise, etc).
- Continued existing risks to nearby communities, associated to any potential accident or spill.

Management Program-

As stated above, Termoflores has generated updated Environmental and Social Management Plans for Flores IV, which includes a total of 20 specific operational detailed plans and procedures to manage all the identified potential environmental and social impacts and risks. These plans are adequate and inline with standard industry practices, and include (a) a description of the issue and scope of the program, (b) objectives, (c) activities, (d) timetable, (e) supervision and monitoring, (f) responsibilities, and (g) costs. The twenty plans are:

Programs for the Construction Phase:
Localization and Sitting Plan (Ficha 1), which has the objective of assuring the topographic studies are closely followed to avoid unnecessary excavations, earth movements, and/or direct impacts on the site.

Program to manage earth movements (Ficha 2), which outlines land clearance, preparation, drainage, excavation and soil handling and disposal procedures to appropriately manage excavations, foundations, and other earth movement activities to avoid soil erosion, land slides, and/or sediment loss to surface waters.

Program to handle fuels, vehicles, machinery, and heavy equipment (Ficha 3), to avoid any impacts associated with the storage and/or handling of fuel and any spills potentially associated with the operation and maintenance of machinery and heavy equipment.

Program for construction aggregates handling and concrete manufacturing (Ficha 4), which outlines all the mitigation measures to avoid air, soil, and water contamination that could result from construction aggregate and concrete handling and manufacturing.

Program to transport and install electro-mechanic equipment (Ficha 5), to avoid negative environmental impacts that could result as a result of the inappropriate installation of the electro-mechanic equipment.

Program to handle di-electric oils (Ficha 6), to avoid negative environmental impacts associated with the mishandling of di-electric oils used in transformers and auxiliary equipment.

Environmental Mitigation Programs-

Solid waste management plan (Ficha 7), which outlines the procedures to handle and dispose domestic, industrial, and hazardous waste. This plan outlines the procedure to treat and dispose the 9 tons/day of sludge generated from the water treatment facilities, which mainly involves water removal in a sludge treatment facility and final disposal in a permitted controlled landfill.

Industrial Water and Wastewater management plan (Ficha 8), which establishes the procedures associated with the treatment of the process water (e.g. clarification, filtration, reverse osmosis, etc) and the final industrial and domestic wastewater designed treatment and discharge parameters.

Air quality management plan (Ficha 9), which outlines measures to mitigate air emission associated with construction activities and plant operation. This plan includes specific operation measures to reduce stack NOx emissions, such as vapor injection in Flores II, and the installation of a wet compression in Flores II and III, as well as the monitoring protocols to measure stack emission and air quality.

Noise mitigation program (Ficha 10), which outlines prohibited practices and standard procedures to assure compliance with noise levels for industrial zone (75dBA), as well as the protocol for the performance of noise measuring campaigns.
Landscape management program (Ficha 13), to appropriately manage the removal of existing vegetation in the construction site, and maintain a pleasant landscape within the plant.

Soil conservation and protection program (Ficha 14), which is intended to complement the procedures outlined in the Program to manage earth movements (Ficha 2), remediate any liabilities left over from the construction, and assure the appropriate maintenance of drainages and other soil erosion works.

Environmental monitoring plan (Ficha 15), establishes the monitoring protocols (e.g. parameters to measure, applicable emission/discharge limits, frequency, etc) for soil stability, process water, wastewater, air emissions, air quality, noise, etc. This plan also includes continuous training to Termoflores employees, environmental authorities, the local population and nearby communities, among other potentially interested parties.

Social Programs -
Local hiring and management program (Ficha 11), which defines the different function needed for unskilled work force (e.g. construction workers and helpers, drivers, gardeners, electrician, carpentry helpers, etc), and recommends measure to assure local hiring is performed in a transparent form, to avoid any conflicts and maximize local benefits.

Personnel and equipment transportation program (Ficha 12), which complements the Program to handle fuels, vehicles, machinery, and heavy equipment (Ficha 3), but places an emphasis on assuring appropriate code of conduct and protective driving, to avoid transportation accidents or nuances to the communities in rout of transport influence area. This program also refers to the norms associated with the transportation of personnel in-and-out of the plant/construction site, and complements the local hiring management program (Ficha 11), by emphasizing the need to hire as many as possible local transportation companies or micro-enterprises (e.g. independent vans and/or buses owners).

Archeological chance-find procedure (Ficha 16), even though the construction site is of no cultural or archeological interest, the company has developed a chance-finds procedures in case there are unexpected archeological finds during excavations.
Local community relations program (Ficha 17), geared towards maintaining the local population informed about Termoflores activities, to assure a good-neighbors attitude and the overall social viability of the project. This program includes communications associated with government and private institutions and organizations (e.g. Environmental Authorities, Secretariat of Education, solid waste management company AAA, Secretariat of Public Works, etc) to coordinate efforts and promote social responsibility initiatives.

Industrial health and safety program (Ficha 18), that lists all the different functions, their associated occupational H&S risks, any special procedures, and the personal protection equipment (PPE) required.

General Programs -

Environmental management program (Ficha 19), which describes the organizational structure and function for the appropriate execution and supervision of the EMPs.

Contingency Plan (Ficha 20), which list all the different potential emergencies and contingencies (e.g. spill, earthquakes, fires, population upheaval, among others), and defines actions to follow, communication procedures, and responsibilities.

Organization -

Termoflores has an Environmental Manager who supervises a team of four technicians. This team is in-charged of assuring the application of the EMPs, including the performance of the different emission and discharge environmental samples associate with the environmental monitoring plan. This group also writes ToRs for any contractors or consultants working on EHS related matters, and supervises compliance with the terms of the contracts. For instance in the case of Termoflores IV, the Environmental Management Unit is responsible for the supervision of the EPC’s application of the EMPs. Additionally, the Environmental Ministry has retained the consulting firm SIESCO to perform an Interventoría Ambiental. This Interventoría Ambiental involves daily supervision of the existing operations and of the construction works, to assure compliance with the EMPs approved via the Environmental License. SIESCO provides supervision reports to the environmental authorities every six months, but holds weekly meetings with Termoflores environmental management team to discuss any breaches in compliance and establish any corrective measures thereof.

Additionally, Termoflores has an Occupational Health and Safety Manager who is responsible for the application of the Industrial health and safety program (Ficha 18), keeping accidents/incidents data, provide daily safety talks/training to the employees, and issue report to insurance companies and the secretariat of health.

PS 2 – Labor and Working Conditions

Human Resource Policy and Management:

As of September, 2008 Termoflores employs 93 people directly, most of which reside in Barranquilla. As a result of construction activities linked to the proposed investment 280 short term jobs will be created. Both Termoflores and the EPC contractor give priority to hiring local people where skills match available jobs.

Termoflores has in place an Internal Labor Policy –ILP- (Reglamento Interno de Trabajo) that is consistent with Colombian law and with IFC PS2 requirements. Upon hiring, all employees receive copy of the contract and the ILP. Operative personnel at the plant work in three shifts of up to 48 hours per week, with a maximum of 12 extra hours. Work on extra hours and holidays are compensated in accordance with Colombian laws. All salaries are above the legal minimum wage and those earning less than 2 legal minimum wages receive additional subsidies for transportation. All operative personnel located at Barranquilla receive a subsidy for food. Currently, Termoflores’ workers are not unionized, but in compliance with Colombian law, workers are allowed to form or join worker’s organizations and to bargain collectively. A non-harassment policy was included in the company’s ILP in October 2006, in compliance with the terms set forth in Colombia Labor Laws. The company does not employ minors and does not engage in forced labor.

The EPC contractor and subcontractors are contractually required by Termoflores to comply with Colombian Labor Laws. The EPC contractor has in place its own ILP which is consistent with Colombian Law, but which will be updated to ensure that no person younger that eighteen (18) years old is employed for construction activities.

Occupational Health and Safety:
Termoflores has in place a management-approved Occupational Health and Safety (OH&S) Policy and has conducted an OH&S risks analysis (Panorama de Riesgo) for its operations. Based on the OH&S analysis Termoflores has developed, and is implementing, a comprehensive set of OH&S measures and procedures based on national and international standards covering, among others, the following issues: exposition to extreme temperatures; ergonomics; noise control; vision prevention care; emergency response; evacuation plan; fire safety plan; and specific procedures for activities such as working at heights or with electrical equipment.

Termoflores’ facilities are equipped with fire detectors, alarm systems, and fire-fighting equipment, including a hydraulic fire-fighting system and extinguishers. The company ensures through specialized companies that all this equipment is maintained in good working order. Termoflores has established an Occupational Health Committee (Comité Paritario de Salud Ocupacional) which includes a fire brigade that helps conduct emergency drills periodically. Additionally, Termoflores is a member of Barranquilla’s process for Awareness and Preparedness for Emergencies at Local Level –APELL- (www.apellbarranquilla.org), organized by the UN Environment Program (UNEP), that coordinates local government agencies, communities, local fire-fighters, and other private companies in the area to better respond to emergencies. As part of this process, emergency response drills are conducted periodically.

Personnel are issued appropriate Personal Protective Equipment (PPE) and provided continuous training on OH&S issues. In accordance to Colombian law, all employees including those working for the EPC contractor and subcontractors must be covered by an Occupational Risk Insurance and are required to abide by the company’s OH&S procedures. Compliance with OH&S provisions on behalf of its staff and third parties working at the plant site is constantly monitored by the company and reported to Management. According to the OH&S reports produced by the company, for the last three years, its accidentality rate has been below the national average for its sector.

PS 3 – Pollution Prevention and Abatement

Termoflores I, II and III original designs comply with the PPAH (1998) Thermal Power: Guidelines for New Plants air emission, noise emissions, and waste water discharge.

Air Emissions and Air Quality: As part of the assessment for the expansion, Termoflores has performed extensive air quality monitoring for Total Suspended Particles (TSP), SO2, NO2, O3 and CO. The most recent measurement were performed prior to the start of the earthworks for Flores IV (Jan-Feb 2008), and during the initial phases of earth movements (March-April 2008). Measurements were performed at three different sites, following the Colombian Norm 601 (2006), which requires continuous 24 hr measurement for 30 consecutive days. These sampling resulted in 24 hours average values within the PPAH recommended values for ambient air quality for Thermal Power Plants, as well as the Colombian air quality permissible limits. Air quality values indicate good climatic and geo-morphological conditions, favoring good dispersion and good ambient air quality around Termoflores’s influence area, which can be therefore be considered non-degraded even though it is within Barranquilla’s industrial zone.

The project is expected to comply with existing PPAH 1998 values, as well as with existing Colombian emission regulations. The Project does not involve the construction of a new generation plan or purchase of a new combustion gas-generated turbine, but the addition of a new steam turbine generator and heat recovery steam generator, which will result in an absolute reduction of NOx emission values, and the reduction of approximately 460,000 MT of CO2.

GHG:
The project is to convert the existing open cycle gas-fired gas turbine units into a more energy efficient combined cycle power plant. The energy efficiency of the two existing open cycle units is around 9,880 BTU/kWh (34.5% gross, Lower Heating Value basis), and for the last six years they are being operated at around 24.6% annual operating factor (generating 0.6 x 109 kWh/year), emitting CO2 emissions of about 0.348 million ton CO2 per year, with CO2 emissions performance of 575.1 g CO2/kWh. When the project is completed, the combined cycle power plant will have an improved energy efficiency of about 6,749 BTU/kWh (50.56% gross, Lower Heating Value basis), and will be operated at higher annual capacity factor of about 70%. Even with this higher utilization rate of the combined cycle power plant, the annual CO2 emission is estimated about 1.12 million ton CO2 per year (at the 70% of base load in the future combined cycle, generating 2.76 x 109 kWh/year). If we were to assume equivalent annual operating factors this improved efficiency would imply approximately 460,000 ton CO2 less per year than the current emission amounts. Due to the significant improvement of the energy efficiency of the combined cycle plant, the CO2 emissions performance is estimated to achieve 405 g CO2/kWh, about 29.6 % improvement from the current performance. This CO2 emissions performance level of the combined cycle power plant, 405 g CO2/kWh, is better than the national average of the existing gas-fired power generation sector of Colombia, which is 534 g CO2/kWh (2004-2006 average), according to the latest International Energy Agency statistics (2008).

Noise:
Noise measurements are taken every three months at nine (9) sites located at the periphery of the Plant. In accordance with Colombian Resolución Ambiental 627/2006, measurements are integrated every 60 minutes for a period of 24 hours. Noise measured values indicate compliance with the required PPAH (1998) 70 dB[A] allowed limits for industrial zone.
It must be noted that even though Termoflores is located in an area classified as an industrial zone, there are many residences in the plant’s immediate area of influence, which have been constructed over time as the industrial pole has continued to grow, and as a result of poor urban zoning enforcement. This “residential” growth is mostly of people associated to the local industries - employees or service – and has grown after Termoflores was built. The highest values are reported at the front gate and towards the road, and therefore the noise is not due to Termoflores’ operations but to traffic and other road-side activities. Flores IV will be built on the side of the plant opposite to the road, and therefore the potential noise to nearby residences is not expected to increase as a consequence of Flores IV construction or operations. However, measurement will continue to be taken, and the increased noise emissions will not exceed 3 dB [A] from current background levels.

Waste-water: There are four different potential wastewater sources:

- Domestic waste waters from employees, which have been estimated to be approximately 0.56 l/s during construction and 0.006 during the operation.

- Plan effluent, which is approximately 72,1 l/s, of which over 70% (51.05 l/s) are generated from the blow down of the cooling towers. Once in operation, Flores IV will generate about 37,8 l/s from the blow down water for the cooling towers, or approximately 72.6% of the total.

- Surface runoff waters from irrigation and installation’s clean-up estimated on 1.9 m3/d. Surface runoff is not expected to increase with Flores IV, and it will continue to be collected with the existing pluvial drainage system.

- Turbid pluvial waters from the site during construction activities.

The different effluents will be segregated, treated, and disposed according to their type and degree of contamination. Domestic wastewaters will increase on about 500 people/day during the construction phase and 5 people/day once Flores IV is in operation. The existing septic system is compliant with Colombian effluent discharge values, and is expected to be sufficient for Flores IV. Rain water and surface runoff is collected with the pluvial drainage system which is connected with Barranquilla’s pluvial collection system which directly discharges into the Magdalena River. This system is not expected to change for Flores IV. Industrial wastewaters are mostly composed of process from water blow down of the cooling towers, and it is sent to a sedimentation pond prior to it disposal back into the Magdalena River. Industrial effluent discharge values meet Colombian norm, with heavy metal reported values of 0,012 mg/l of Zinc, 0.64 mg/l of iron, 0.212 mg/l of copper, and chromium below detection limits. Oil and greases and BOD5 are also fairly low at values of 0.754 mg/l and 14.6 mg/l, respectively.

Solid waste: The bulk of the solid waste generated will be sludge from the process water treatment. This will be dehydrated and disposed off in a controlled landfill. The rest of the non-hazardous and hazardous solid waste generated is limited and will be managed in accordance with the Solid Waste Management Program (Ficha 7), and disposed in compliance with local regulations.

PS4 – Community Health, Safety and Security

Impacts related to community health and safety generated by transport of construction materials, equipment, and workers to and from the construction sites are limited and the company and EPC contractor will adhere to its “Personnel and equipment transportation program”, included in the EMP and with Municipal traffic regulations. The project will not require the construction of labor camps. Workers will originate or be housed in space available in Barranquilla. All construction activities will be conducted within company’s premises that have been fenced for safety reasons and to avoid impacts on surrounding communities. As mentioned under PS2 the company has prepared emergency response plans, in addition to its participation in the APELL process, which includes provisions for continuous community engagement.

The company receives security services from a security firm that provides guards, who receive training on emergency and security procedures and on how to respond commensurate with the risk or security issue at hand. The security company is supervised by the National Superintendence for Security Companies and abides by Colombian regulations.

Since the 1990’s a small armed contingent of the National Army has been based within Termoflores’ premises and it provides additional safety to its facilities. This contingent acts in close coordination with Termoflores’ Security Department. To enhance this coordination and to ensure that potential risks associated with this issue are mitigated, the company will conduct a risk assessment on the presence of government security personnel within the plant and will define appropriate measures to ensure compliance with PS4 requirements. These measures will be aimed at communicating the company’s intent that the security personnel act in manner consistent with the company’s principles of conduct, including proportionality and appropriate conduct toward workers and the local community, and require them to act within the applicable law.

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