Environmental and Social Assessment According to the IFC

Transcrição

Environmental and Social Assessment
According to the IFC Performance
Standards and EHS Guidelines
Eldorado Brasil
Reference: 0152083
www.erm.com
Delivering sustainable solutions in a more competitive world
REPORT
Eldorado Brasil
Environmental and Social
Assessment of Industrial,
Forest and Logistics
Projects, According to the
IFC Performance Standards
and EHS Guidelines
April, 2012
Reference: 0152083
Verified by: Priscylla Moro do Carmo/ Leonardo
Gonçalves
Project Managers
Signed: ___________________________________
Approved by: Alastair Scott
Technical Reviewer
Signed: ___________________________________
Authorized by: Elizabeth Penhalber
Partner in Charge
Signed: ___________________________________
TABLE OF CONTENTS
1
PROJECT SUMMARY
1.1
1.2
1.3
1.4
1.5
INTRODUCTION
OVERVIEW OF THE PROJECT
METHODOLOGY OF ASSESSMENT
LIMITATIONS AND EXCEPTIONS
USE OF THIS REPORT
2
2
19
25
26
2
ENVIRONMENTAL AND SOCIAL BASELINE FOR THE PROJECT
26
3
DESCRIPTION OF COMPANY, ACTIVITIES AND PROJECT
38
3.1
3.2
3.3
3.4
3.5
OVERVIEW OF INDUSTRIAL SITE AND CURRENT STATUS
OVERVIEW OF FORESTRY OPERATIONS AND CURRENT STATUS
OVERVIEW OF THE LOGISTICS PROJECT
ENVIRONMENTAL LICENSING PROCESS
FOREST CERTIFICATION AND SOCIAL PROGRAMS
40
49
53
57
59
4
PROJECT CATEGORIZATION AND APPLICABLE IFC PERFORMANCE
STANDARDS
75
4.1
4.2
4.3
4.4
BACKGROUND TO CATEGORIZATION
BASIS FOR CATEGORIZATION
APPLICABLE IFC PERFORMANCE STANDARDS
ALIGNMENT WITH EQUATOR PRINCIPLES
75
76
76
77
5
BENCHMARK OF THE PROJECT - ALIGNMENT WITH BRAZILIAN
LEGAL REQUIREMENTS AND IFC PERFORMANCE STANDARDS
80
6
FINAL OBSERVATIONS AND RECOMMENDATION
2
108
ANNEX A
ANNEX B
ANNEX C
ANNEX D
ANNEX E
ANNEX F
LIST OF DOCUMENTS REVIEWED AND PERSONS INTERVIEWED
BRAZILIAN ENVIRONMENTAL LICENSING PROCESS DESCRIPTION
GAP ANALYSIS TABLE – PULP AND PAPER INDUSTRIAL PROJECT
GAP ANALYSIS TABLE – FORESTRY OPERATIONS
GAP ANALYSIS TABLE – LOGISTICS PROJECT
PHOTOLOG
ENVIRONMENTAL RESOURCES MANAGEMENT
ELDORADO - APRIL, 2012
1
PROJECT SUMMARY
1.1
INTRODUCTION
ERM Brazil Ltda. (ERM) was commissioned by ELDORADO BRASIL
(ELDORADO) to perform a Social and Environmental Assessment of its pulp
and paper plant project that is being installed in Três Lagoas, State of Mato
Grosso do Sul/Brazil and logistics operations destined to the transportation of
pulp produced in the industrial complex under construction, until the port of
Santos in the State of São Paulo, with the objective of providing technical
information for the financing process with FINNVERA, EKN and OeKB.
The assessment was based on the Equator Principles and the Environmental and
Social 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 PROJECT
ELDORADO BRASIL is engaged in the production of pulp and paper, being
one of the major global players in this sector. It is composed of the following
assets/activities: industrial, forest and logistics. The main characteristics of
each 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/2012
and 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 the
concept of having the BAT – Best Available Technology. The industrial
process 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 work
for the construction phase of the project): 7,750 (total workers, estimated),
out of which approximately 6,195 are workers that are not originally from
2
the area.
Figure 1.1 shows the industrial site location and layout.
3
Figure 1.1
Industrial Site Location and Layout
4
BRASIL
N
N
NW
NE
NE
W
E
E
SW
SE
S
NW
SE
Amazonas
W
SW
RN
PB
S
PE
Acre
AL
Sergipe
Tocantins
Bahia
Mato Grosso
Mato Grosso
do Sul
Minas Gerais
Rio de Janeiro
Sta. Catarina
Rio Grande
do Sul
MATO GROSSO DO SUL
N
NW
NE
W
E
SW
SE
CLIENT
DESCRIPTION
Eldorado Brasil
0
150
300
SCALE 1:15.000km
SIZE A3 - FRAME 386 x 279 mm
450km
PROJECT
Environmental and Social Assessment of Industrial,
Forest and Logistics Projects, According to the IFC
Performance Standards and EHS Guidelines
WORK ORDER
Industrial Plant Location
EDITION CONTROL
04/19/2012
04/19/2012
EDITION
REVISION
THIS DOCUMENT IS PROPERTY OF
ERM BRASIL LTDA. AND CANNOT BE COPIED,
REPRODUCED OR TRANSMITTED BY ANY OTHER
MEANS, OR USED FOR PURPOSES DIFFERENT
OF THOSE FOR WHICH IT WAS DONE.
0152083
FIGURE / ANNEX
FIGURE 1.1
EDITOR / DESIGNER
CARLOS ROBERTO
TECHNICAL RESPONSABLE
CIP
SOURCE:Google Earth Pro - 2004.
0152083-1-Plant Lo
S
 Forestry Operations: currently covers 134 farms, of which approximately
10% is owned by ELDORADO, and 90% belongs to third party companies
with whom ELDORADO has established leasing contracts or partnership
arrangements. The total managed area will be:

2012: 137,000 hectares;

2017: 361,000 hectares; and

2021: 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 1,188
men); and
 Contractors (workers engaged by third parties): 577 (50 women and 527
men).
Table 1.1 presents the list of the farms that will be used to supply wood for the
project. The table also presents information of available area for plantation,
existing planted area, type of contract (owned, leased or partnership), status of
the activity (planted, planting or available for planting) and localization of
each farm.
5
Table 1.1
Farms data
Map nº
Name of the Farm
1 - Planted
Area (ha)
-
2 -Available
Area for
Planting (ha)
202,00
Total
(1+2)
Land Contract
Status
Municipality
State
202,00

Partnership

Available for
planting

Selvíria

Mato Grosso
do Sul
1

4F**
2

08 de Dezembro
588,85
-
588,85

Partnership

Planted

Selvíria

Mato Grosso
do Sul
3

Água Azul
918,20
-
918,20

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
4

Água Sumida**
-
808,00
808,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
5

Alvorada
149,87
-
149,87

Leased

Planted

Selvíria

Mato Grosso
do Sul
6

Araça
214,99
-
214,99

Partnership

Planted

Selvíria

Mato Grosso
do Sul
7

Barra Mansa
2.184,92
-
2.184,92

Leased

Planted

Água Clara

Mato Grosso
do Sul
8

Barraca
3.420,57
288,74
3.709,31

Owned

Planting

Aparecida do
Taboado/Inocência

Mato Grosso
do Sul
9

Barranco
Vermelho
2.251,31
-
2.251,31

Partnership

Planted

Água Clara

Mato Grosso
do Sul
10

Bebedouro
190,74
-
190,74

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
11

Beira Rio**
-
540,00
540,00

Partnership

Available for
planting

Selvíria

Mato Grosso
do Sul
12

Bela VistaOtoboni**
-
706,00
706,00

Leased

Available for
planting

Inocência

Mato Grosso
do Sul
13

Belezura**
-
204,00
204,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
14

Boa Esperança
453,62
-
453,62

Partnership

Planted

Anastácio

Mato Grosso
do Sul
6
15

Boa Vista
1.356,11
2 -Available
Area for
Planting (ha)
-
16

Bonito
6.515,54
12.768,66
19.284,20

Owned

Planting

Água Clara

Mato Grosso
do Sul
17

Brasília I e II**
-
560,00
560,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
18

Buba
755,80
-
755,80

Partnership

Planted

Dois Irmãos do
Buriti

Mato Grosso
do Sul
19

Buriti
602,77
-
602,77

Partnership

Planted

Selvíria

Mato Grosso
do Sul
20

Buriti da Véstia
356,56
-
356,56

Partnership

Planted

Selvíria

Mato Grosso
do Sul
21

Buriti do
Cerrado
299,08
-
299,08

Leased

Planted

Selvíria

Mato Grosso
do Sul
22

Buriti-Aleudo**
-
590,00
590,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
23

Cabeceira Bonita
1.490,56
-
1.490,56

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
24

Cabeceira da
Estrada
83,69
-
83,69

Partnership

Planted

Selvíria

Mato Grosso
do Sul
25

Cabeceirão**
-
182,00
182,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
26

Cachoeira
1.252,94
-
1.252,94

Partnership

Planted

Selvíria

Mato Grosso
do Sul
27

Campo Limpo I
1.483,89
-
1.483,89

Partnership

Planted

Selvíria/Três
Lagoas

Mato Grosso
do Sul
28

Campo Limpo II
752,33
-
752,33

Partnership

Planted

Selvíria

Mato Grosso
Map nº
Name of the Farm
1 - Planted
Area (ha)
Total
(1+2)
Land Contract
Status
Municipality
State
1.356,11

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
do Sul
29

Canoas
30

Celina
3.717,68
-
3.717,68

Owned

Planted

Selvíria

54,41
-
54,41

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
Mato Grosso
do Sul
7
32

Conquista Três
Poderes
229,74
2 -Available
Area for
Planting (ha)
-
33/
34

Correntes I e II
3.017,81
-
3.017,81

Owned
35

Correntes III**
-
-
-

Owned
36

Cristiane**
-
436,00
436,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
37

Cristo Rei
1.219,00
-
1.219,00

Partnership

Planted

Inocência

Mato Grosso
do Sul
38

Da Mina**
-
444,00
444,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
39

Diogo**
-
300,00
300,00

Leased

Available for
planting

Selvíria

Mato Grosso
do Sul
40

Dois
Coqueiros**
-
157,00
157,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
41

Dois Irmãos
1.041,74
-
1.041,74

Partnership

Planted

Selvíria

Mato Grosso
do Sul
42

Farinazo
526,41
-
526,41

Partnership

Planted

Selvíria

Mato Grosso
do Sul
43

Douradinha
132,13
-
132,13

Leased

Planted

Santa Rita do Pardo

Mato Grosso
do Sul
44

Eldorado II
800,62
-
800,62

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
45

Esperança**
-
330,00
330,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
46

Estrela da
Mina**
-
406,00
406,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
47

FJE
144,77
-
144,77

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
48

Flor de Liz
576,86
-
576,86

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
Map nº
Name of the Farm
1 - Planted
Area (ha)
Total
(1+2)
Land Contract
Status
Municipality
State
229,74

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul

Planted

Dois Irmãos do
Buriti

Mato Grosso
do Sul

Dois Irmãos do
Buriti

Mato Grosso
do Sul
8
Map nº
Name of the Farm
1 - Planted
2 -Available
Total
Area (ha)
Area for
(1+2)
557,93
Planting (ha)
138,26
1.225,59
Land Contract
Status
Municipality
State
696,19

Partnership

Planting

Selvíria

Mato Grosso
do Sul
-
1.225,59

Partnership

Planted

Selvíria

Mato Grosso
do Sul
49

Floresta
50

Gramadão
51

Guri I
461,99
-
461,99

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
52

Guri III
117,02
-
117,02

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
53

Iracema
781,45
-
781,45

Leased

Planting

Ribas do Rio Pardo

Mato Grosso
do Sul
54

Jandaia**
-
652,00
652,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
55

Jataí
252,09
-
252,09

Owned

Planted

Selvíria

Mato Grosso
do Sul
56

Jatiúca
51,82
-
51,82

Owned

Planted

Anastácio

Mato Grosso
do Sul
57

Jatobá
575,28
-
575,28

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
58

JBS
63,34
-
63,34

No Contract

Planted

Andradina

São Paulo
59

Kokets**
-

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
60

Labor
61/

Laranja 1 e 2
286,08
-
286,08

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
1.471,77
-
1.471,77

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
62
63

Lyder
744,10
-
744,10


Leased
Planted

Ribas do Rio Pardo

Mato Grosso
do Sul
64

Madeiropólis**
-
140,00
140,00


Leased
Available for
planting
9

Selvíria

Mato Grosso
do Sul
Map nº
Name of the Farm
65

Malela**
66

Morro Vermelho
67

Mutum
68

MutumOtoboni**
69

Mutum Piuva
70

Nambú
71

Nevada**
72

73
1 - Planted
Area (ha)
-
2 -Available
Area for
Planting (ha)
240,00
157,51
Total
(1+2)
Land Contract
Status
Municipality
State
240,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
-
157,51

Partnership

Planted

Selvíria

Mato Grosso
do Sul
1.756,69
-
1.756,69

Partnership

Planted

Ribas do Rio Pardo

Mato Grosso
do Sul
-
112,00
112,00

Leased

Available for
planting

Inocência

Mato Grosso
do Sul
-

Owned

Corumbá

Mato Grosso
do Sul
375,75
-
375,75

Partnership

Planted

Selvíria

Mato Grosso
do Sul
-
1.430,00
1.430,00

Partnership

Available for
planting

Três Lagoas

Mato Grosso
do Sul
Nossa Senhora
Aparecida
444,25
-
444,25

Partnership

Planted

Selvíria

Mato Grosso
do Sul

Nova Olinda**
-
504,00
504,00

Leased

Available for
planting

Selvíria

Mato Grosso
do Sul
74

Palmeira**
-
647,00
647,00

Leased

Available for
planting

Selvíria/Aparecida
do Taboado

Mato Grosso
do Sul
75

Panorama**
-
242,00
242,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
76

Pantano
2.531,00
285,82
2.816,82

Partnership

Planting

Selvíria

Mato Grosso
do Sul
77

Papagaio
1.100,19
-
1.100,19

Partnership

Planted

Aparecida do
Taboado

Mato Grosso
do Sul
78

Prata
480,61
-
480,61

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
79

Prata 01**
-
906,00

Partnership

Available for
planting

Três Lagoas

Mato Grosso
do Sul
80

Progresso
351,11
351,11

Partnership

Planted

Aparecida do
Taboado

Mato Grosso
do Sul
-
10
Map nº
Name of the Farm
1 - Planted
Area (ha)
2 -Available
Area for
Planting (ha)
Total
(1+2)
Land Contract
Status
Municipality
State
81

Quatro IrmãosLauro Vasques**
-
317,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
82

Queixada**
-
1.053,00

Leased

Available for
planting

Inocência

Mato Grosso
do Sul
83

QueixadaSandra Rahal**
-
420,00

Leased

Available for
planting

Selvíria

Mato Grosso
do Sul
85

Rancharia
687,23
-
687,23

Leased

Planted

Aparecida do
Taboado

Mato Grosso
do Sul
86

Recanto
107,44
-
107,44

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
87

Recanto do Lobo
761,22
-
761,22

Partnership

Planted

Água Clara

Mato Grosso
do Sul
88

Retirinho
347,26
-
347,26

Leased

Planted

Selvíria

Mato Grosso
do Sul
89

Rosana**
-
886,00
886,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
90

Rosana II**
-
367,00
367,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
91

Santa Adélia
464,59
-
464,59

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
92

Santa Helena
1.212,74
-
1.212,74

Partnership

Planted

Inocência

Mato Grosso
do Sul
93

Santa Iracema
328,90
-
328,90

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
94

Santa Isabel
686,17
-
686,17

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
95

Santa Izabel
3.706,36
-
3.706,36

Owned

Planted

Pontal do Araguaia

Mato Grosso
96

Santa Livia
43,27
-
43,27

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
97

Santa Lourdes
924,40
-
924,40

Partnership

Planted

Selvíria

Mato Grosso
do Sul
98

Santa Lúcia do
Sucuriu**
-
4.150,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
11
99

Santa LuziaDalila Soares**
-
2 -Available
Area for
Planting (ha)
130,00
100

Santa LuziaDurval**
-
288,00
288,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
101

Santa Maria
1.279,19
-
1.279,19

Partnership/
Leased

Planted

Três Lagoas

Mato Grosso
do Sul
102

Santa Marina
640,37
317,01
957,38

Leased

Planting

Três Lagoas

Mato Grosso
do Sul
103

Santa
Mercedes**
509,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
104

Santa Rita
356,09
-
356,09

Partnership

Planted

Inocência

Mato Grosso
do Sul
105

Santa Rosa
799,76
-
799,76

Partnership

Planted

Selvíria

Mato Grosso
do Sul
106

Santa Terezinha
1.132,57
-
1.132,57

Partnership

Planted

Selvíria

Mato Grosso
do Sul
107

Santa Terezinha
998,48
-
998,48

Leased

Planted

Aparecida do
Taboado

Mato Grosso
do Sul
108

Santa Terezinha
1
754,61
-
754,61

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
109

Santo Antonio**
-
626,00
626,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
110

Santo Expedito
111,55
133,00
244,55

Partnership

Planting

Inocência

Mato Grosso
do Sul
111

Santo André
1.659,89
-
1.659,89

Partnership

Planted

Ribas do Rio Pardo

Mato Grosso
do Sul
112

São João
852,24
-
852,24

Leased

Planted

Ribas do Rio Pardo

Mato Grosso
do Sul
113

São João da
Vestia
619,73
-
619,73

Partnership

Planted

Selvíria

Mato Grosso
do Sul
114

São Jorge
776,22
-
776,22

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
Map nº
Name of the Farm
1 - Planted
Area (ha)
-
Total
(1+2)
Land Contract
Status
Municipality
State
130,00

Leased

Available for
planting

Selvíria

Mato Grosso
do Sul
12
Map nº
Name of the Farm
1 - Planted
Area (ha)
256,17
2 -Available
Area for
Planting (ha)
-
Total
(1+2)
Land Contract
Status
Municipality
State
256,17

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
115

São José
116

São Judas Tadeu
4.179,24
-
4.179,24

Partnership

Planted

Santa Rita do Pardo

Mato Grosso
do Sul
117

São Judas Tadeu
233,45
-
233,45

Leased

Planted

Água Clara

Mato Grosso
do Sul
118

São Lourenço
434,94
-
434,94

Partnership

Planted

Selvíria

Mato Grosso
do Sul
119

São Manoel
898,35
-
898,35

Partnership

Planted

Aparecida do
Taboado

Mato Grosso
do Sul
120

São Paulo
121

São PedroHumberto
Jacob**
122

São Vicente VII
2.747,99
123

Savana
124

Serrinha
125

Shestese**
-
126

Sítio Favú**
-
127

Sítio Santa
Rita**
-
128

Sobradinho
129

Sobradinho I**
130

Tanaka

Owned

Alto Araguaia

Mato Grosso
630,00

Leased

Available for
planting

Selvíria

Mato Grosso
do Sul
-
2.747,99

Partnership

Planted

Água Clara

Mato Grosso
do Sul
5.265,39
-
5.265,39

Partnership

Planted

Santa Rita do Pardo

Mato Grosso
do Sul
319,64
-
319,64

Partnership

Planted

Três Lagoas

Mato Grosso
do Sul
256,00

Partnership

Available for
planting

Três Lagoas

Mato Grosso
do Sul
47,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
110,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
152,14

Leased

Planted

Aparecida do
Taboado

Mato Grosso
do Sul
578,30

Owned

Available for
planting

Inocência

Mato Grosso
do Sul
139,33

Leased

Planted

Selvíria

Mato Grosso
do Sul
-
152,14
47,00
-
139,33
-
13
Map nº
Name of the Farm
1 - Planted
Area (ha)
2 -Available
Area for
Planting (ha)
-
Total
(1+2)
Land Contract
Status
Municipality
State
1.365,90

Owned

Planted

Dois Irmãos do
Buriti

Mato Grosso
do Sul
189,00

Leased

Available for
planting

Três Lagoas

Mato Grosso
do Sul
131

Taruana
1.365,90
132

Traipu**
-
133

Três Amigos**
-
370,00
370,00

Leased

Available for
planting

Inocência

Mato Grosso
do Sul
134

Três Irmãos
150,98
-
150,98

Partnership

Planted

Selvíria

Mato Grosso
do Sul
135

Três Meninas**
1.134,00

Leased

Available for
planting

Aparecida do
Taboado

Mato Grosso
do Sul
136

Uere Mirim
389,18
-
389,18

Leased

Planted

Santa Rita do Pardo

Mato Grosso
do Sul
137

Vo Fiorindo
842,01
-
842,01

Partnership

Planted

Dois Irmãos do
Buriti

Mato Grosso
do Sul
138

Vo Nhonho
709,18
-
709,18

Leased

Planted

Três Lagoas

Mato Grosso
do Sul
-
** Estimated area of plantation, contract in process of formalization.
14
The Forestry Operations are described in item 3.2. Figure 1.2 shows the
location map of the farms described in table 1.1.
15
Figure 1.2
Location Map of the Farms
16
.
Mato Grosso
Goias
Boíivia
Minas Gerais
5
!
Aparecida do Taboado
Mato Grosso do Sul
5
!
Campo Grande
5
!
Três Lagoas
Sao Paulo
5
!
Paraguai
Parana
Legend
5
!
Biome
Cities
CLIENT
Conservation Units
Cerrado
Main Rivers
Indigenous Areas
Mata Atlântica
Location of Farms
Pantanal
0
45.000
90.000
Meters
DESCRIPTION
PROJECT
PROJECT NUMBER
Location of the Farms
Eldorado Brasil
0152083
FIGURE / ANNEX
FIGURE 1.2
EDITION CONTROL
04/19/2012
04/19/2012
EDITION
REVISION
EDITOR / GRAPHIC DESIGNER
TECHNICAL RESPONSIBLE
CIP
 Logistics project: described in section 3.3, will guarantee the production
transportation to clients. The majority of production will be exported
through Santos Port and, to accomplish that the Project establishes that
ELDORADO will be responsible for the construction of 2 (two) multimodal
terminals 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 do
Taboado (90km) multimodal terminal, to be built by the Company and,
then, railroad transportation to Santos Port (900 km), where the product
will be loaded into ships for exportation. ELDORADO will improve a
terminal at the existing Santos Port for its needs; and
 Model 2: transportation from the industrial plant to Pederneiras
multimodal terminal (to be built by the Company) by barges through
Tietê river (350 km) and, then, using a third party railway (MRS) to
Santos Port (520 km), where the product will be loaded into ships for
exportation.
Exportation of pulp will be mainly to Europe (45%) and China (45%), with
a minor part destined to America (10%). Figure 1.3 shows the location of
the logistics projects and related infrastructure.
17
Figure 1.3
Logistics Project Location Map
18
.
MS
-3
16
:
&
- 32
0
BR
-1
58
SP
:
&
Três Lagoas
SP
-3
MINAS GERAIS
10
MATO GROSSO
DO SUL
SÃO PAULO
RIO DE
JANEIRO
&
:
Pederneiras
&
:
São Paulo
:
&
Santos
PARANÁ
Atlantic Ocean
Legend
:
&
Cities
CLIENT
Highway
PROJECT
Possible Railway Paths
Hydrography
Eldorado Brasil
DESCRIPTION
PROJECT NUMBER
Logistics Project Location
0152083
FIGURE / ANNEX
FIGURE 1.3
EDITION CONTROL
04/19/2012
04/19/2012
EDITION
REVISION
Logistics Project Location
Source: Bing Maps.
CIP
1.3
METHODOLOGY OF ASSESSMENT
To develop the assessment according to the scope of work proposed, ERM
adopted the following methodology:
 Preliminary desk review of the environmental studies (such as
Environmental Impact Assessment and its report - EIA/RIMA) and/or
supporting documents used in their preparation, made available and sent
in advance by ELDORADO;
 Preliminary desk review of the environmental licenses made available by
ELDORADO;
 Analysis of actions performed by ELDORADO, such as plans and
programs, to comply with the conditions of the environmental licenses
pertinent to the Project;
 Preliminary desk review of secondary data about the company, considering
publicly available documents with respect to the environmental and social
themes;
 Visit to ELDORADO’s industrial site, from January 17th to 20th, 2012, where
the plant is being installed, in Três Lagoas and interviews with corporate
and industrial technicians representatives, responsible for EHS and Social
management, workers and one neighbor related to the items covered by the
IFC PSs;
 Visit to a sampling of farms (31 farms at total), from April 9th to 13th, 2012,
and interviews with corporate and forest technicians’ representatives,
responsible for EHS and Social management;
 Visit to Santos Port Terminal, on February 10th, 2012, already in operation,
where one of the ELDORADO’s terminals will be constructed (Terminal
Elmar);
 Visit to 3 (three) accommodation sites for forestry workers, located in Água
Clara and Inocência municipalities, State of Mato Grosso do Sul; and
 Visit to the accommodation site for industry workers, located in Três
Lagoas, State of Mato Grosso do Sul;
 Visit to one wood supplier farm: Mutum Group Farm (Fazenda do Grupo
Mutum), in Ribas do Rio Pardo municipality;
 Evaluation of potential environmental, health, safety and social impacts
and risks associated to the Project;
19
 Identification of legal parameters and applicable regulations to
ELDORADO’s Project; and
 Identification of gaps and recommendations for improvement, against the
applicable 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 of
this assessment, given that they are still in the project detailing phase and no
construction activities is being carried out at those sites.
Note 2: Due to the quantity of farms that are subject of the forest operations
and limitations of time, and costs in this assessment, ERM developed a sample
criterion for the site visits at the farms. The following items were considered
during 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 or
Ruah) 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 presented
below:
20
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 to
ELDORADO´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, ERM
visited 1 from JS, 1 from Plantar and 2 operated by Eldorado; and
 From the total of 23 planted areas visited, 1 had maintenance activities
performed by Ruah.
Communities and biomes
ERM 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 by
ELDORADO, ERM verified that only two farms are located outside the
Cerrado biome. One of these is located in the Pantanal biome and the other in
the Mata Atlântica biome. These farms were not visited because the farm
located in the Pantanal biome is not planted and the farm located in the Mata
Atlântica biome belongs to one of ELDORADO´s owner and as informed it
will not be used for pulp production.
Table 1.2 presents the information on the 31 farms visited by ERM, while
Figure 1.4 shows the location map of the farms visited by ERM during the
visits. This map also includes information about the biome and the location of
indigenous areas.
21
Table 1.2
Visited Farms
Map nº Name of the Farm
4
7
8
9
15
18
21
26/84
33/34
Água Sumida**
Barra Mansa
Barraca
Barranco Vermelho
Boa Vista
49
50
56
57
2 -Available
Area for
Planting (ha)
-
808,00
2.184,92
-
3.420,57
288,74
2.251,31
-
1.356,11
755,80
Buba
Buriti do Cerrado
Cachoeira
Correntes I e II
35 Correntes III**
48
1 - Planted
Area (ha)
Flor de Liz
Floresta
Gramadão
Jatiúca
Jatobá
299,08
1.252,94
3.017,81
576,86
557,93
Municipality
State
Available for
planting
Mato Grosso do Sul
Planted
Água Clara
Mato Grosso do Sul
3.709,31 Owned
Planting
Aparecida do
Taboado/Inocência
Mato Grosso do Sul
2.251,31 Partnership
Planted
Água Clara
Mato Grosso do Sul
Planted
Três Lagoas
Mato Grosso do Sul
755,80 Partnership
Planted
Dois Irmãos do Buriti
Mato Grosso do Sul
299,08 Leased
Planted
Selvíria
Mato Grosso do Sul
Planted
Selvíria
Mato Grosso do Sul
3.017,81 Owned
Planted
Mato Grosso do Sul
Mato Grosso do Sul
808,00 Leased
2.184,92 Leased
-
- Owned
-
138,26
1.225,59
-
51,82
-
575,28
-
Total (1+2) Land Contract Status
576,86 Leased
Planted
Três Lagoas
Mato Grosso do Sul
696,19 Partnership
Planting
Selvíria
Mato Grosso do Sul
Planted
Selvíria
Mato Grosso do Sul
Planted
Anastácio
Mato Grosso do Sul
Planted
Três Lagoas
Mato Grosso do Sul
51,82 Owned
575,28 Partnership
22
Map nº Name of the Farm
67
77
80
87
89
90
93
101
102
107
110
119
122
129
131
137
Mutum
Papagaio
Progresso
Recanto do Lobo
Rosana**
Rosana II**
Santa Iracema
Santa Maria
Santa Marina
Santa Terezinha
Santo Expedito
São Manoel
São Vicente VII
Sobradinho I**
Taruana
Vo Fiorindo
1 - Planted
Area (ha)
2 -Available
Area for
Planting (ha)
1.756,69
-
1.756,69
1.100,19
-
1.100,19
351,11
-
351,11
761,22
-
761,22
-
886,00
367,00
Total (1+2) Land Contract
886,00
367,00
328,90
-
328,90
1.279,19
-
1.279,19
640,37
998,48
111,55
317,01
133,00
957,38
998,48
244,55
898,35
-
898,35
2.747,99
-
2.747,99
-
578,30
1.365,90
-
1.365,90
842,01
-
842,01
Status
Municipality
State
Partnership
Planted
Ribas do Rio Pardo
Mato Grosso do
Sul
Partnership
Planted
Mato Grosso do
Sul
Partnership
Planted
Mato Grosso do
Sul
Partnership
Planted
Água Clara
Mato Grosso do
Sul
Leased
Available for
planting
Mato Grosso do
Sul
Leased
Available for
planting
Mato Grosso do
Sul
Partnership
Planted
Três Lagoas
Mato Grosso do
Sul
Partnership/
Leased
Planted
Três Lagoas
Mato Grosso do
Sul
Leased
Planting
Três Lagoas
Mato Grosso do
Sul
Leased
Planted
Mato Grosso do
Sul
Partnership
Planting
Inocência
Mato Grosso do
Sul
Partnership
Planted
Mato Grosso do
Sul
Partnership
Planted
Água Clara
Mato Grosso do
Sul
Owned
Available for
planting
Inocência
Mato Grosso do
Sul
Owned
Planted
Mato Grosso do
Sul
Partnership
Planted
Mato Grosso do
Sul
23
Figure 1.4
Farms Visited by ERM During the Assessment
24
.
.
Map 1
.
Map 1
MATO GROSSO DO SUL
5
Aparecida do Taboado !
5
!
5
!
Campo Grande
120
Três Lagoas
Map 2
.
Map 2
123
43
116
136
Legend
Source: Bing Maps
116
São Judas Tadeu
120
São Paulo
123
Savana
136
Uere Mirim
Leased
Planted
Partnership
Planted
Owned
Not informed
Partnership
Planted
Leased
Planted
Biome
CLIENT
Cities
Location of Farms
Cerrado
Highways
Conservation Units
Mata Atlântica
Hydrography
Douradinha
** Estimated area planted, no formal contract or in the process of formalizing
Legend
5
!
43
Indigenous Areas
Pantanal
0
12.500
25.000
Meters
PROJECT
Eldorado Brasil
DESCRIPTION
PROJECT NUMBER
Visited Farms
0152083
FIGURE / ANNEX
FIGURE 1.4A
EDITION CONTROL
04/19/2012
04/19/2012
EDITION
REVISION
CIP
.
.
.
Map 1
MATO GROSSO DO SUL
Map 1
5
5
!
5
!
Map 2
Campo Grande
Três Lagoas
69
.
Map 2
5
!
Campo Grande
34
56
33
35 137
131
Legend
18
14
Boa Esperança
Partnership
Planted
18
Buba
Partnership
Planted
33
Correntes I e II
Owned
Planted
34
Correntes I e II
Owned
Planted
35
Correntes III**
Owned
Planted
56
Jatiúca
Owned
Planted
69
Mutum Piuva
Owned
Not informed
131
Taruana
Owned
Planted
137
Vo Fiorindo
Partnership
Planted
14
Source: Bing Maps
Legend
5
!
Cities
Location of Farms
Hydrography
Visited Farms
Highways
Conservation Units
Indigenous Areas
Biome
CLIENT
Cerrado
Mata Atlântica
Pantanal
0
12.500
25.000
Meters
PROJECT
Eldorado Brasil
DESCRIPTION
PROJECT NUMBER
Visited Farms
0152083
FIGURE / ANNEX
FIGURE 1.4B
EDITION CONTROL
04/19/2012
04/19/2012
EDITION
REVISION
CIP
.
.
.
MATO GROSSO DO SUL
5
5
!
37
68
82
12
44 23 3
32
92
114 91
78 61 62
98
79
17 71
7
138
111
67
102
112 63
53
87
117
81
124
122
9
94
60
51
133
104 106
110 8
90
38 46 4
2 64 1
20 54 36
88
77
50
121
26
74
55
89 119
84 73
11
29
76 25 107
105 70 76
39
Legend
85
1
127
19 5
49
31
6
134
97 113 21
72
66
28
42 24
47
101 27
10 41
109
115
125
48
100
132
15
108 75
57 93
5
!
Três Lagoas
Available for planting
72
Nossa Senhora Aparecida
2
08 de Dezembro
Partnership
Planted
73
Nova Olinda**
Leased
3
Água Azul
Partnership
Planted
74
Palmeira**
Leased
4
Água Sumida**
Leased
5
Alvorada
6
Araça
5
!
Partnership
Planted
75
Panorama**
Leased
Leased
Planted
76
Pantano
Partnership
Planting
Partnership
Planted
77
Papagaio
Partnership
Prata
Planted
Barra Mansa
Leased
Planted
Leased
Planted
8
Barraca
Owned
Planting
79
Prata 01**
Partnership
9
Barranco Vermelho
Partnership
Planted
80
Progresso
Partnership
Planted
10
Bebedouro
Leased
Planted
81
Quatro Irmãos-Lauro Vasques *
Leased
11
Beira Rio**
Partnership
82
Queixada**
Leased
12
Bela Vista-Otoboni**
Leased
83
Queixada-Sandra Rahal**
Leased
13
Belezura**
Leased
85
Rancharia
Leased
Planted
15
Boa Vista
Partnership
Planted
86
Recanto
Partnership
Planted
Recanto do Lobo
Partnership
Planted
Leased
Planted
16
Bonito
Owned
Planting
87
17
Brasília I e II**
Leased
88
Retirinho
19
Buriti
Partnership
Planted
89
Rosana**
Leased
20
Buriti da Véstia
Partnership
Planted
90
Rosana II**
Leased
21
Buriti do Cerrado
Leased
Planted
91
Santa Adélia
Leased
Planted
22
Buriti-Aleudo**
Leased
92
Santa Helena
Partnership
23
Cabeceira Bonita
Partnership
Planted
93
Santa Iracema
Partnership
Planted
24
Cabeceira da Estrada
Partnership
Planted
94
Santa Isabel
Leased
Planted
95
Santa Izabel
25
Leased
Owned
Planted
Cachoeira
Partnership
Planted
96
Santa Livia
Partnership
Planted
27
Campo Limpo I
Partnership
Planted
97
Santa Lourdes
Partnership
Planted
28
Campo Limpo II
Partnership
Planted
98
Santa Lúcia do Sucuriu**
Leased
29
Canoas
Owned
Planted
99
Santa Luzia-Dalila Soares**
Leased
30
Celina
Leased
32
Conquista Três Poderes
36
Cristiane**
26/84
Cabeceirão**
Planted
Planted
100
Partnership
Planted
101
Santa Maria
Leased
102
Santa Marina
Santa Mercedes**
Leased
Santa Luzia-Durval**
Partnership/ Leased
Planted
Leased
Planting
Leased
37
Cristo Rei
Partnership
Planted
103
38
Da Mina**
Leased
104
Santa Rita
Partnership
39
Diogo**
Leased
105
Santa Rosa
Partnership
Planted
40
Dois Coqueiros**
Leased
106
Santa Terezinha
Partnership
Planted
41
Dois Irmãos
Partnership
Planted
107
Santa Terezinha
Leased
Planted
42
Farinazo
Partnership
Planted
108
Santa Terezinha 1
Leased
Planted
44
Eldorado II
Partnership
Planted
109
Santo Antonio**
Leased
45
Esperança**
Leased
110
Santo Expedito
Partnership
Planting
46
Estrela da Mina**
Partnership
Planted
47
FJE
48
Flor de Liz
49
Leased
111
Santo André
Partnership
Planted
112
São João
Leased
Planted
113
São João da Vestia
Floresta
Partnership
Planting
114
50
Gramadão
Partnership
Planted
51
Guri I
Partnership
52
Guri III
Partnership
53
Iracema
54
Jandaia**
55
Jataí
57
58
59
Kokets**
60
Labor
Planted
Leased
Planted
Partnership
Planted
São Jorge
Leased
Planted
115
São José
Partnership
Planted
Planted
117
São Judas Tadeu
Leased
Planted
Planted
118
São Lourenço
Partnership
Planted
Leased
Planting
119
São Manoel
Partnership
Planted
Leased
121
São Pedro-Humberto Jacob**
Leased
Owned
Planted
122
São Vicente VII
Partnership
Jatobá
Partnership
Planted
124
Serrinha
Partnership
Planted
JBS
No Contract
Planted
125
Shestese**
Partnership
Leased
126
Sítio Favú**
Leased
Laranja 1 e 2
Lyder
Planted
Leased
Planted
127
Sítio Santa Rita**
Leased
Partnership
Planted
128
Sobradinho
Leased
Planted
Leased
Planted
129
Sobradinho I**
Owned
Leased
Tanaka
Leased
64
Madeiropólis**
130
65
Malela**
Leased
132
Traipu**
Leased
66
Morro Vermelho
Partnership
Planted
133
Três Amigos**
Leased
67
Mutum
Partnership
Planted
134
Três Irmãos
Partnership
Planted
68
Mutum-Otoboni**
Leased
135
Três Meninas**
Leased
70
Nambú
Partnership
Planted
138
Vo Nhonho
Leased
Planted
71
Nevada**
Partnership
Planted
Biome
CLIENT
Cities
Visited Farms
Cerrado
Highways
Location of Farms
Mata Atlântica
Hydrography
Partnership
78
63
Source: Bing Maps
4F**
7
61/62
Legend
Três Lagoas
129
16
103
5
!
Campo Grande
Conservation Units
Pantanal
0
12.500 25.000
Meters
PROJECT
Eldorado Brasil
DESCRIPTION
PROJECT NUMBER
Visited Farms
0152083
FIGURE / ANNEX
FIGURE 1.4C
EDITION CONTROL
04/19/2012
04/19/2012
EDITION
REVISION
CIP
Annex A presents the list of documents analyzed during this assessment,
provided by ELDORADO and also the list of representatives of ELDORADO
that were interviewed.
1.4
LIMITATIONS AND EXCEPTIONS
This report is based upon the application of scientific principles and
professional judgment to certain facts with resultant subjective interpretations.
Professional judgments expressed herein are based on the currently available
facts within the limits of the existing data, scope of work, budget and
schedule.
The scope of this evaluation was restricted to the industrial site and a
sampling of farms (as detailed in item 1.3). The visited farms were selected
using technical criteria due to the limitations of schedule and budget not all
the 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 corporate
level and is part of the Action Plan to implement the management system.
Regarding the logistics project which comprises three port terminals, the site
inspection could only be performed at one of them (Port Elmar, located in the
municipality of Santos). The other two multimodal terminals are yet to be
constructed and no activities were being carried out during the period of this
assessment. Therefore, neither Pederneiras port or Aparecida do Taboado port
could be visited/inspected.
The logistics system is in the project feasibility stage and a limited amount of
information is available. Eldorado made available to ERM the Simplified
Environmental Report (Relatório Ambiental Simplificado – RAS), required by
the State of Mato Grosso do Sul Environmental Agency – IMASUL as part of
the licensing process of the Aparecida do Taboado multimodal terminal. No
other documents were available.
As for the Pederneiras multimodal terminal, no documents were made
available, given that the construction and operation will be responsibility of a
third 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 initial
phase, and that only one port terminal could be visited/inspected, the gap
25
analysis against the Equator Principles and the IFC Performance Standards is
not complete. However recommendations of actions to mitigate potential
risks are included in this report, in order to make the project compliant with
those standards at a later stage.
Particularly with regards to Performance Standard 2 (Labor and Working
Conditions) for the Logistics Project, no interviews with employees were
conducted to assess labor and working conditions at construction sites, as
there is no activity there.
To the extent that more definitive conclusions are desired by the client than
are warranted by the currently available facts, it is specifically ERM's intent
that the conclusions stated here are understood as guidance and not
necessarily as a firm course of action, except where explicitly stated as such.
ERM makes no warranties, expressed or implied, including, without
limitation, warranties as to merchantability or fitness for a particular purpose.
In addition, the information provided in this report is not to be constructed as
legal advice.
1.5
USE OF THIS REPORT
The client agrees that none of its advertising, sales promotion, or other
publicity matter containing information obtained from this report will
mention or imply the name of ERM. The client also acknowledges that this
report has been prepared to the exclusive use of the client and acknowledged
third parties.
Nothing contained in this report shall be construed as a warranty or
affirmation by ERM that the site and property described in the report are
suitable acquisition of such property by any lender through foreclosure.
2
ENVIRONMENTAL AND SOCIAL BASELINE FOR THE PROJECT
Industrial Plant
ELDORADOs’ pulp and mill facility consist in the installation of a bleached
kraft eucalyptus pulp mill, eucalyptus homogeneous reforestation and related
infrastructure 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 and
therefore would require their own permitting process. An Environmental
Impact Assessment Study was developed only for the pulp and mill facility.
The other associated infrastructure had simplified environmental permitting
processes.
26
During the EIA analysis process by the State Environmental Agency
(IMASUL), a Public Hearing was conducted on December 3rd, 2009, at 7pm in
Três Lagoas city, in Centro de Eventos Leiloado at Road BR 262, km 11.
Forest Operations
For the forestry activities no Environmental Impact Assessment (EIA) and
Environmental Basic Plan (PBA) were developed, according to the exemption
granted by State regulations. The legislation requires ELDORADO to issue to
IMASUL a "Planting Informative" of the concerning areas for such activity as
well as the appropriate "environmental clearance for cutting of planted
forests." These documents require proof of preservation of legally protected
areas.
Logistics Project
For the logistics project, ELDORADO will be responsible for the Aparecida do
Taboado licensing process and construction. A Simplified Environmental
Report - RAS for the terminal has been developed and submitted for approval
at IMASUL.
Adjustments of the railway extension access in Aparecida do Taboado, will be
performed by ELDORADO and the licensing procedures and eventual
vegetation suppression with its compensations will be managed by this
company.
For the Pederneiras Terminal, ELDORADO has hired EGTM Navegação
(Torque) which already owns a multimodal terminal and will expand its
boundaries in other to meet the demand. EGTM Navegação will be
responsible for the waterway transportation and permitting process of
terminal and water transportation.
Adjustments of the railway extension access in Pederneiras will be performed
by MRS LOGÍSTICA S.A and the licensing procedures and eventual
vegetation suppression with its compensations will be managed by this
company, as reported by ELDORADO.
At Santos Port, ELDORADO will have the following activities:
 Temporary warehouse: owned by Hipercon Terminais de Cargas Ltda
which currently has installation license according information provided on
State Environmental Agency’s (CETESB) website. ELDORADO has
informed that the area will be operated by this company which will be
responsible for obtaining and maintaining environmental permits and
licenses, as well as for complying with the environmental legislation;
 Warehouses III, VIII, XIII and XVIII: has been purchased by ELDORADO
from Rodrimar S/A Transportes Equipamentos Industriais e Armazéns
27
Gerais; and
 Warehouses IX to XII: ELDORADO has the intention to acquire these
areas.
Table 2.1 presents the status of all the infrastructure for the project.
28
Table 2.1
Environmental Status of the Project Areas/ Infrastructure
Project Area
Pulp and Paper Mill
Environmental Project
Responsibility
ELDORADO
Brazilian Environmental License
Preliminary License nº 314/2009
(IMASUL, 2009);
Phase
Status
In
construction
Other information
In operation
since 2011
-
No
information
was
provided
The concessionaire of the fuel station is
PETROBRAS and, reportedly, this company is
responsible for issuing the documentation for the
Installation and Operation License, since they will
be operating the station.
Installation License nº 17/2011,
(IMASUL, February 24th, 2011);
Application for a Installation Permit
(plant expansion for sodium
chlorate manufacturing plant):
application done on August 31,
2011;
Application for a Commissioning
Permit: done on November 18th,
2011;
Operation License: to be obtained
after industry construction is
finished.
Power Transmission
Line and Electrical
Substation
ELDORADO
(IMASUL, July 22th, 2010);
ELDORADO has decided to include a sodium
chlorate manufacturing plant on site, instead of
transporting the sodium chlorate by tanker trucks
from market suppliers. As a result, it applied for
an Installation Permit for the plant expansion on
August 31, 2011. Additionally, it developed an
environmental study (EAP – Estudo Ambiental
Preliminar) and a risk analysis, considering the
presence of the Chlorate plant to support the
licensing process. The Installation Permit for the
Chlorate Plant has not been issued to date.
ELDORADO also applied for a permit for the
commissioning stage on November 18th, 2011 in
order to include in the Installation Permit the
commissioning of: pulp production, chemical
recovery, utilities and manufacturing systems for
sodium chlorate, chlorine dioxide and oxygen
manufacture.
Installation License nº 148/2010
(IMASUL, (October 27th, 2010);
Operation License nº 83/2011
(IMASUL, February 24th, 2011).
Fuel Station
ELDORADO /
PETROBRAS
(IMASUL, November 4th, 2010).
29
Phase
Status
Application
for
Installation
License
Other information
(IMASUL, November 4th, 2010)
Application
for
Installation
License
-
ELDORADO
Allowed to operate according to
Environmental regulations.
Already in
operation
since 2010.
No Environmental Impact Assessment (EIA) and
Environmental Basic Plan (PBA) were developed,
according to the exemption granted by State
regulations. The State issued an authorization in
case there is the need to cut vegetation for
eucalyptus plantation. In case of pasture land
conversion there is no need for previous
authorization.
Multimodal Terminal
(Aparecida do
Taboado)
ELDORADO
Application for Preliminary License:
Simplified Environmental ReportRAS was submitted to the state
environmental agency IMASUL:
application done on March/April,
2012.
Awaiting
Preliminary
License
Simplified Environmental Report - RAS is being
analyzed by IMASUL, in order to provide the
preliminary license or request further
clarifications/complementation before issuing
Preliminary License.
Increase in federal
road traffic (BR 158)
between Industrial
Plant and Aparecida
do Taboado
ELDORADO
Environmental Study included on
Multimodal Terminal (Aparecida do
Taboado): Simplified Environmental
Report - RAS was submitted to the
state environmental agency
IMASUL (application done on
March/April, 2012).
Awaiting
Preliminary
License
Simplified Environmental Report-RAS is being
analyzed by IMASUL, in order to provide the
preliminary license or request further
clarifications/complementation before issuing
Preliminary License.
Responsibility
ELDORADO
Internal railway
extension (inside
pulp mill)
ELDORADO
Forestry operations
Project Area
Pier Mooring close to
the industrial site
(IMASUL, November 4th, 2010).
30
ELDORADO has submitted to IMASUL a study
called EAP – Preliminary Environmental Study, to
change in 300m the coordinates of the pier which
were informed in the EIA.
Project Area
Multimodal Terminal
(Pederneiras)
Responsibility
EGTM Navegação
(Torque)
and
MRS LOGÍSTICA
The licensing procedures at
Multimodal Terminal will be
managed by EGTM Navegação
(Torque).
Phase
Status
-
The licensing procedures at railway
extension will be managed by MRS
LOGÍSTICA.
Other information
According to the Service Agreement signed by
Eldorado and EGTM (December 22th, 2011),
EGTM Navegação (Torque) agrees to observe and
comply with environmental legislation, being
responsible for fines and notices of violation of
activities directly related to the transportation of
cellulose, and is responsible for obtaining and
maintaining any permits or licenses required by
public agencies, due to the object of the contract.
Additionally, the adjustments of the railway
extension access in Pederneiras, will be performed
by MRS LOGÍSTICA. The licensing procedures
will be managed by this company, as reported by
ELDORADO.
Construction and
adaptation of existing
structures at the Port
of Santos
ELDORADO, Hipercon
Terminais de Carga
Ltda and
MRS LOGÍSTICA
Temporary warehouse: installation
license issued by CETESB. To be
operated by Hipercon.
Warehouse III and VIII: operating
permit under Rodrimar’s name
(previous owner) - warehouse III
nº18001394 has been issued on
28/12/2009 and is valid until
28/12/2013; operating permit for
warehouse VIII nº 18001731 has
been issued on 03/10/2011 and is
valid until 13/07/2014.
-
Temporary warehouse: the licensing procedures
are managed by Hipercon;
Warehouse III, VIII, XIII and XVIII: future
licensing procedures will be managed by
ELDORADO;
MRS Logística will be responsible for the
adjustments of the railway extension access, and
its licensing, as reported by ELDORADO.
Warehouse XIII and XVIII: not yet
licensed.
Warehouses IX and XII: in process
of acquisition.
31
Project Area
Adjustments of the
railway extension
access to Aparecida
do Taboado
Responsibility
ELDORADO
Phase
Status
Other information
The construction and licensing
procedures will be managed by
ELDORADO.
-
Adjustments of the railway extension access in
Aparecida do Taboado will be performed by
ELDORADO. The licensing procedures will be
managed by this company.
MRS Logística will construct
adjustment at the temporary area
and the railway extension access.
Existing Waterway –
Tiete River (from
Industrial Plant to
Pederneiras)
ETGM Navegação
The licensing procedures at the
waterway are managed by EGTM
Navegação (Torque).
Already in
operation.
Existing and operating waterway. Specific
responsibilities are covered by a contract.
External and existing
Railway (MRS)
MRS LOGÍSTICA
Already licensed (MRS LOGÍSTICA
responsibility).
Already in
operation.
Existing and operating railway.
External and existing
Railway (ALL)
ALL (América Latina
Logística)
Already licensed (ALL
responsibility).
Already in
operation.
Existing and operating railway.
32
Environmental and Social Setting
 Biome and Land Use
ELDORADO´s operations are mainly in the Cerrado biome. The
predominant flora is low vegetation (exotic grasses) and isolated native
trees. These are typical physiognomy of the Cerrado.
The original forest formations, belonging to the Cerrado, were reduced to
small fragments, resulting in the isolation and habitat fragmentation due to
intense agriculture activities.
According to information provided during ERM assessment, the land use
conversion inside ELDORADO’s properties was mostly from pasture to
forest plantation. In the visited sites ERM did not find evidences that
ELDORADO is converting native forests into forest plantation.
ERM observed the implementation at the visited farms that riparian zones
are 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 (rainy
region) irrigation is not planned at the planted areas.
 Social Setting
ELDORADO industrial site is located in Três Lagoas municipality and the
plantations areas are distributed mainly along Mato Grosso do Sul State.
The main municipalities of Mato Grosso do Sul State are briefly described
below in order to provide a social setting of the project.
Três Lagoas
The 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 2nd
largest industrial GDP (equal to R$ 397,500,000 according to FIEMS, 2010).
The Human Development Index (HDI) is rated 0,748, considered of
medium human development (between 0.5 and 0.8).
Because of its strategic location and availability of energy, water, raw
material 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 people
from other municipalities and regions.
33
Selvíria
Agribusiness is the largest activity at Selviria and corresponds to 46.29% of
the 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 National
Health System (SUS). The city depends of Tres Lagoas health infrastructure
service. There are public schools at Selvira, but there isn’t a technical
professional course.
Inocência
There are 7,653 inhabitants at Inocência, 64% of them living in urban area.
The local government seeks support to construct a hospital to attend 18
beds. There is no university available at the city.
Água Clara
Água Clara has 14,686 inhabitants. The city economic has been improved
by the construction of the São Domingos Hydropower. The main industry
of the city is wood extraction, soya and cattle rising. There are around 30
wood industry based on reforestation.
Consultation Activities
ELDORADO has the following consultation initiatives:
 For the purpose of social economic diagnosis, a sample of citizens and local
governmental authorities were interviewed to identify vulnerability of the
region;
 For the development of the Inventory of Areas of High Biodiversity study,
stakeholders were consulted to identify the areas of high biodiversity
important to the community and the use of it;
 As a result of the local vulnerabilities identified at the social economic
diagnosis, local governmental representatives were consulted by
ELDORADO 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 the
lands where ELDORADO operates receive information about the company
and orientation on how to contact it;
 Forums and public hearings were held for the purpose of the industry
license process, where information about the EIA and programs were
disclosure to the public (community leaders, government, police,
34
associations, etc.) and community concerns about the project were
identified; and
 A public hearing for the forestry project will be hold for certification
purpose and the Forest Management Plan will be disclosure.
A community relationship plan is being developed.
External Communications and Grievance Mechanisms
ELDORADO 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 register
communication received from stakeholders.
Name of the
Mechanism
Stakeholder
group
Description
Main complaints received
Ombudsman
Industrial
workers
(employees
and
contractor’s
worker)
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 the accommodation;
 Telephone number; and
 E-mail.
Grievances are registered and are treated by the
Ombudsman, analyzed, investigated, and
feedback is provided to the worker by the social
assistant. In case of anonymous grievance, the
respond is disclosure on a board available close to
the cafeteria.
Information about the ombudsman is disclosure
at the Manual for Induction and banners at the
site.

A representative from HR visit workers in the
field twice a month to register their demands.
ERM reviewed a spreadsheet containing the name
of the worker, complaint, feedback provided, and
time of response.
Workers interviewed reported that complains are
made through their field supervisor mostly.

Human
Resources in
the field
Rural workers






Error at payment of contract
termination;
Delay in the delivery of
payroll;
Retention of the Worker
Registration Book for over 48
hour (according to the
Brazilian legislation, the
company must retain it to
register work contract details
and return it in no longer than
48 hours);
Difficulty of relationship
between workers and
supervisors;
Error in the overtime
payment; and
Delay to reimburse workers of
travel expenses.
Access to benefits (health
insurance and feed fee); and
Error in salary payments.
Complains from contractor’s workers are
registered and directed to the Contract company.
None of the complaints registered on the
spreadsheet were related to contractor’s workers.
35
Name of the
Mechanism
Stakeholder
group
Description
Main complaints received
Form to
register
external
communicati
on from the
public
External
stakeholders,
specially local
community
and neighbor
Stakeholders might contact ELDORADO’s office
in each municipality, a telephone number, the
supervisor of the farm or those responsible to
perform rounds on the farms.
Contact numbers are provided to neighbors of the
farms during the PTEAS process, but there is no
systematic process to disclosure the information
to general community.
The form registers the name of the person,
stakeholders category, reason for contact, name of
the person who receive the contact and action
taken. Once complete, the form is delivered to one
person in charge to receive it. The complaint is
registered in a spreadsheet that contains the name
of the person, data, who received the complaint, a
description of the complaint, action taken,
feedback and data.




request of finance support to
social programs;
neighbor broken fence;
measures to combat fire at
ELDORADO’s site; and
workers performing
maintenance activities in a
neighbor land.
There is also an e-mail and telephone number on the company’s website that
stakeholders can contact.
In the forums and public hearings held for the purpose of the industry license
process, 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 and
emergency response.
Indigenous People
An archeological survey was conducted in December 2011, and identified that
there was no indigenous groups or traditional people affected by
ELDORADO’s operation. The study was undertaken on 7 municipalities were
ELDORADO 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 of
Brasilandia names Ofayé-Xavante, municipality in which ELDORADO does
36
not operate. ELDORADO reported that this indigenous land is 96 km away
from ELDORADO industrial site and 92 km away from farms operated by
ELDORADO at the municipality of Santa Rita do Pardo.
A social territory study was undertaken for the municipalities of Anastacio
and Dois Irmãos do Buruti, were ELDORADO possess lands. The study was
undertaken by the previous land owner and identified 7 indigenous
communities in the region. According to ELDORADO, there are no
indigenous or traditional people at ELDORADO’s land and Jatiúca Farm is
the closest to an indigenous land boundary, 22 km away.
The lands at Anastacio and Dois Irmãos do Buruti have eucalyptus ready to be
harvested and recently planted, maintenance is currently being performed.
ELDORADO reported that possible impact on indigenous and traditional
people, if any, will be identified through PTEAS that will be carried out before
harvesting (between June to December 2012). Reportedly ELDORADO do not
use work from indigenous people in its farms.
 Water Consumption
The EIA developed for ELDORADO pulp mill took into account water
availability as one factor for location alternatives. Water will be abstracted
from Paraná River and a flow measurement for the period of 22 years was
considered. Within this period, the average flow was 7,299 m³/s, with a
maximum flow of 28,222 ³/s and minimum of 1,597 m³/s. The
characteristic flow (Q95) was 2,070 m³/s (occurring 95% of the time).
The design water intake for industrial purposes, used for the dimensioning
of the water treatment plant to be installed in ELDORADO pulp mill is
7,500 m³/h (2.08 m³/s), what represents 0.1% of Paraná River (Q95) flow.

Ambient Air Quality
ERM reviewed two air quality monitoring reports developed by the hired
consulting company Storm & Smoke – Consultoria Ambiental e Prestadora
de 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 approximately
6.0 km East from ELDORADO Pulp Mill site); and
 24-hour monitoring at one point in the city of Três Lagoas (distant
approximately 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 and
37
total suspended particles), NO2, ozone, carbon monoxide and SOx. The area is
considered homogeneous in what refers to air quality.
The results indicated that the monitored parameters meet the air quality
standards established in Brazilian regulations and the WHO Ambient Air
Quality Guidelines, except for Particulate Matter PM10, in July, 2011, which
exceeded the guideline value of 50 µg/m³ (24-hour average concentration of
52.92µg/m³).
The second report refers to a monitoring campaign conducted in September
2011. The results show that all the parameters comply with the Brazilian
regulations and WHO Ambient Air Quality Guidelines, except for PM10,
which exceeded the Interim target 3 value of 75µg/m³ (24-hour average
concentration of 87.95µG/m³).
The PM10 concentrations are apparently related to seasonal variations. The
monitoring campaign conducted in March (rainy season) showed much lower
result (24-hour average of 8.3 µg/m³) than the campaigns conducted in July
and September (dry season).
3
DESCRIPTION OF COMPANY, ACTIVITIES AND PROJECT
ELDORADO BRASIL is engaged in the production of pulp and paper, being
one of the major global players in this sector. It is composed by the following
assets/activities: industrial, forest and logistics.
Figure 3.1 presents the location of all activities and assets described above.
38
Figure 3.1
Project Location Map



Forestry Operations and Industrial Assets: Três Lagoas (MS)
Logistics Terminals: A. Taboado (MS), Pederneira (SP) and Santos (SP)
Paraná River
Novoeste Railway
Ferroban Railway
City
Multimodal terminal
Port
Source: ELDORADO presentation to the banks, December/2011
39
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 STATUS
According to management representative of ELDORADO, the construction
initiated in June 2010. The current status of the implementation is that around
70% of the civil infrastructure has been installed and 7,750 contractor’s
personnel are working on-site (estimated). It is expected that, in March 2012,
the number of contractors working on site reaches the maximum of 8,000
workers, 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 Central
West regions of Brazil. Around 60% of those workers are living in
accommodations provided by ELDORADO, while the other 40% are living in
accommodations provided by contractors.
Accommodations under ELDORADO responsibility are managed by a third
part company named Meta. This company is also responsible for monitoring
conditions of accommodations provided by contractors. The Engineering
Department 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;
40
 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 inland
water transportation; and
 Internal railway branch;
 Energy production in a small power station and distribution through a
transmission line.
Other auxiliary installations that will be part of the complex include:
 Water intake and treatment;
 Boiler water treatment system;
 Wastewater treatment system;
 Utilities;
41
 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 as
are being implemented. Emphasis is given, when appropriate, to the
environmental controls of each area, associated with effluents generation and
atmospheric emissions.
3.1.1
Wood Handling
Wood logs will be received from the forestry areas by trucks and debarked
through a dry debarking system (no effluents generation).
Debarked logs will be conveyed to a washing station. Water for wood
washing will be kept in closed circuit, thus not generating effluents. Industrial
water will be introduced into the system to compensate for losses.
After the washing station the wood logs will be chipped and chips stored in a
chip pile to be later fed to the digestion system. Prior to be fed to the digestion
system, chips will be classified and off-specification chips will be sent to the
biomass pile to be used as fuel in the power boiler.
3.1.2
Cooking
The adopted concept of the cooking plant is continuous digester, which is, as
reported, the current best available technology, not only associated with pulp
production itself, but also in what refers to environmental performance, given
that it allows better chemicals recovery, resulting in lower chemicals
consumption and efficient energy conservation.
Wood chips will be directed to the impregnation, where they are impregnated
with hot black liquor from the digester cooking zone. Impregnated chips will
then be fed to the top of the digester and flow downwards in controlled
temperature and pressure conditions, for a sufficient time to allow the
chemical reaction between the cooking liquor and the wood fibers bonding
components, mainly lignin.
After the chemical reactions in the digester, the cooking liquor is turned into
black liquor. The black liquor extracted from the digester is pumped through a
black liquor filter and heat exchanger (to recovery energy for the production
of hot water) before being sent to the weak black liquor tank in the
evaporation plant.
42
3.1.3
Pulp Washing and Screening
The brown stock (unbleached pulp) washing stage will accomplished using
recycled filtrates from subsequent stages, thus minimizing chemicals
consumption and effluent generation.
The main purpose is to remove impurities from the pulp prior to the
subsequent processing steps. Separation will mechanically accomplished by
screen plates. The accepted fraction will be conveyed to the washing stages
and the screening rejects will be sent back to the digester.
Washed pulp will be stored for subsequent delignification with oxygen.
3.1.4
Oxygen Delignification
The main goal of this stage is to remove residual lignin in the pulp, thus
reducing the chemicals consumption in the bleaching stages and the effluent
organic load.
In the delignification, the brown stock is mixed with oxidized white liquor
produced in the causticizing area or sodium hydroxide. Brown stock will be
conveyed to the delignification feeding tank and subsequently to the
delignification 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 stored
in the brown stock storage tank.
3.1.5
Pulp Bleaching
Pulp bleaching will be accomplished through an elementary chlorine-free
(ECF) bleaching system. The ECF process, with the use of chlorine dioxide as
the main bleaching agent, represents the current best available technology
regarding minimization of chlorinated organics (AOX) in the effluent.
In the future pulp mill, pulp washing will be accomplished by counter current
washing systems between the bleaching stages, thus minimizing the effluents
generation.
3.1.6
Pulp Drying and Baling
Bleached pulp will be stored in the bleached high-consistency pulp storage
tower 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 on
a stem-heated hot-air “mattress”.
At the end of the drying machine, the pulp sheet will be cooled, cut and piled
43
to form 250-kg pulp bales, which will be transferred to the baling unit to form
2.0-ton bale groups. The 2.0-ton pulp bales will then piled and stored in the
bleached pulp warehouse prior to transportation to the port facilities for
export.
3.1.7
Chemicals Production, Handling and Storage
The chemicals production and handling facilities will include:
 Oxygen production
Oxygen will be produced on site by a third company (White Martins) in a
cryogenic air separator unit and will include liquid oxygen storage and
vaporizers to be used in case of abnormal conditions in the oxygen
production process, so as to guarantee the oxygen supply to the pulp mill.
Oxygen will be used, for example, in the delignification process and in the
white liquor oxidation.
 Hydrogen Peroxide
Hydrogen peroxide will be transported to the pulp mill in tank trucks in
concentrated solution (50 to 60%) and stored in a storage tank. From the
storage tank it will be pumped to the bleaching lines.
 Sodium Hydroxide Storage and Handling
Sodium hydroxide 50% will be transported to the site in tank trucks and
transferred to storage tanks to be used in the liquor systems, oxygen
delignification, bleaching and other areas such as the boiler water
treatment and wastewater treatment.
 Methanol Handling and Storage
Methanol will be transported to the site by tank trucks and transferred to
the storage tank. From the storage tank, it will be pumped to the chlorine
dioxide plant.
 Sodium Chlorate Production and Storage
Originally, sodium chlorate was going be acquired in the market and
transported to the plant by tanker trucks.
Recently, after technical and economic feasibility studies, ELDORADO
decided 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 will
receive sodium chloride by trucks, thus minimizing environmental risks.
44
Sodium chlorate is the main raw material for the production of chlorine
dioxide that will be used in the bleaching line.
 Chlorine Dioxide Production
Chlorine dioxide will be produced on site through the methanol-based
method, by the reduction of sodium chlorate in acid media, using methanol
as reducing agent, to obtain a chlorine dioxide solution.
Chlorine dioxide will be used in the bleaching lines.
3.1.8
Energy Recovery
ELDORADO energy recovery system will include:
 Black Liquor Evaporation
The main goal of the evaporation is the concentration of the weak black
liquor form the cooking stage to be burned in the recovery boiler.
The evaporation system will concentrate the black liquor to a minimum
solids concentration of 80%. The evaporation system to be installed at
ELDORADO 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. Foul
condensate will be treated in a gas/liquid separation column (stripping)
also allowing its reuse.
 Recovery Boiler
The main objective of the recovery boiler is to recover chemicals used in the
pulp production process and the generation of steam used in the
production process and for the generation of energy.
The main fuel of the recovery boiler is the concentrated black liquor
generated in the evaporation system. The organic matter present in the
black liquor provides the required calorific power for combustion and the
inorganic content (mainly sodium carbonate and sodium sulfide) that
leaves the boiler as smelt is re-dissolved in the smelt dissolution tank
generating the green liquor that will be further processed in the
causticizing area.
The recovery boiler to be installed at ELDORADO pulp mill will be of the
low-odor emission type, with indirect contact, thus reducing the pollutant
emissions to the atmosphere. It will also be equipped with high-efficiency
electrostatic precipitator to retain particulates.
45
Additionally, the recovery boiler will also be used as the primary control of
concentrated and diluted non condensable gases, thus minimizing odor
emissions.
 Power Boiler (biomass-fueled)
The power boiler will burn eucalyptus bark and wood rejects as fuel and
will work as a backup system for the treatment of concentrated and diluted
non-condensable gases, in case of abnormal operational conditions of the
recovery 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 electrostatic
precipitator to retain particulates.
 Causticizing and Lime Kiln
The green liquor produced in the recovery boiler smelting dissolving tank
will be further processed in the causticizing area to produce the cooking
(white) liquor, through the reaction of sodium carbonate with sodium
oxide, producing sodium hydroxide and calcium carbonate, which will be
separated by filtration.
Green liquor will be fed to the causticizers to be converted into white
liquor, in one single line. Dregs and grits (inerts from the process) will be
dried and will constitute an industrial waste. In the original project,
ELDORADO would dispose of this waste in an industrial landfill to be
constructed in the complex. However, ELDORADO is currently
considering sending these wastes to a composting system to be later used
as fertilizer.
The calcium carbonate that is formed in the causticizing process will be
converted to calcium oxide to be used in the reaction with green liquor. The
operation will be achieved in a rotary lime kiln.
The lime kiln will be equipped with a high-efficiency electrostatic
precipitator to reduce the particulate emissions. The particulate removed
from the exhaust gases in the precipitator will return to the lime kiln, thus
reducing process losses and waste generation.
46
3.1.9
Pulp Transport and Associated Facilities
Finished bleached pulp will be transported to port facilities located in the city
of Santos, State of São Paulo, using preferably combined fluvial and rail
transportation.
An internal railway branch will be constructed providing a connection with
the existing railway system.
Similarly, a pier will be constructed at the site, allowing the transportation of
finished product by barges using the existing Paraná-Tietê hydro way until
the municipality of Pederneiras, located in the State of São Paulo
(approximately 350 km from the site) and from Pederneiras to the port
facilities via railway.
Alternatively, the finished product can be transported by trucks or integrated
highway-railway system, as described in Section 3.0.
3.1.10
Water Intake and Treatment
Water will be abstracted from Paraná River, downstream of the effluent
discharge outfall.
ELDORADO is authorized to abstract a total flow of 7, 500 m³/h from Paraná
River.
Water intake will include mechanically cleaned bar screens, water pumps and
a 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 be
added. 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-fighting
water reserve (3,000 m³).
Clarifier sludge will be conducted to the wastewater treatment system and the
filters backwash water to the beginning of the treatment process.
For the construction stage, ELDORADO installed a temporary water
treatment plant, with the same unitary operations and 120-m³ capacity.
 Boiler Water Treatment
Treated water will be further treated in a reverse osmosis system to
produce demineralized water used for steam production in the boilers.
47
3.1.11
Wastewater Treatment System
Industrial effluents will be segregated into two lines: solids-containing
effluents and solids-free (low solids) effluent.
High solids effluent will be submitted to screening and primary clarification
prior to joining the low solids effluent in the neutralization tank, where the
effluent will have its pH adjusted. Primary sludge will be dewatered in screw
press and reportedly sold to be used as raw material by low-grade paper
producers or destined to a recycling central.
The effluent will then be cooled in a cooling tower to lower the temperature to
a suitable level for biological treatment.
The biological treatment, which will also treat the sanitary effluents, will
consist of an activated sludge system composed of an aerated selective reactor
(to eliminate filamentous organisms), an aeration tank, a secondary clarifier
and biological sludge recycle. The excess biological sludge will be dewatered
in a centrifuge system. Dewatered sludge will reportedly be treated in a
composting system to be used as fertilizer. It can alternatively be disposed of
in the industrial landfill to be constructed at the site.
The effluent treatment system will include an emergency lagoon, which will
receive off-specification effluents from the process areas, to be gradually
pumped to the wastewater treatment, in the neutralization tank, so as to avoid
operational 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 wastewater
treatment system consisting of an aerated lagoon followed by a polishing
lagoon. Treated sanitary effluent is being discharged to Paraná River, via a
temporary effluent outfall.
3.1.12
Waste Management
ELDORADO will construct an industrial landfill, designed to receive nonhazardous wastes (Class IIA and IIB, according to Brazilian classification
established in the standard ABNT NBR 10004). This landfill is included in the
environmental licensing of the industrial project and the current Installation
License establishes parameters for groundwater monitoring at the industrial
site, including the land of the future landfill.
The landfill will be constructed with compacted soil and will be lined with
synthetic (HDPE) membrane. It will be equipped with leak detection system
connected to a monitoring sump.
48
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. This
waste is currently being crushed and will be used in the forest areas to cover
the access roads, so as to minimize waste disposal.
Hazardous wastes are being managed by a contractor, Podium, and are
currently being temporarily stored in specific areas near the construction
works, by each contractor prior to being removed, packed by Podium and sent
to their final disposal. Podium is currently constructing a central hazardous
waste temporary storage area.
3.2
OVERVIEW OF FORESTRY OPERATIONS AND CURRENT STATUS
Activities and exploitation of eucalyptus plantation are being carried out on
behalf of the company Florestal Brasil (Florestal). ELDORADO Industrial and
Florestal have recently merged into one company, ELDORADO.
The forest areas will support the operation of the pulp mill. Reportedly, in
order to operate the first production line, an area of 162 thousand hectares of
eucalyptus cultivation will be necessary. Therefore, the goal is to plant 26
thousand hectares per year. Until December 2011 the planted area was 80
thousand hectares.
Regarding wood production it is expected a productivity of 40-50m³/year per
hectare, according to soil and zoning studies performed by ELDORADO.
Currently, according information provided during the site visit, 23.6% of the
land is owned by the company and 76.4% are leased or are object of
partnership contracts.
The operation also involves a seedling nursery, working with six different
eucalyptus clones, in an area of 159,000 m² in the municipality of Andradina in
São Paulo state. ELDORADO directly employs 1,566 people in 6 different
municipalities (Três Lagoas, Selvíria, Inocência, Água Clara, Santa Rita do
Pardo at Mato Grosso do Sul State). 88% of these workers are rural workers
and 37% of them are migrant workers from the states of Bahia, Maranhão,
Piauí and the municipality of Aquidauana in Mato Grosso do Sul state. All
migrant workers are men employed in planting and growing activities, which
include pesticides application, among other activities.
Women are hired in the above mentioned cities and employed at the seedling
nursery, which has 260 workers employed.
49
Besides, there are 534 contractors workers from two different companies:
Plantar, JS Florestal and Ruah.
The planting and maintenance, including the application of pesticides and
herbicides, are held by ELDORADO and contractors, Ruah, JS Florestal and
Plantar.
3.2.1
Management System
Regarding management system, the Forestry Operation has software for
project management which includes environmental activities such as
procedures regarding assessment of planting or wood cutting areas. A
procedure 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 Social
Technical Project (“Projeto Técnico Econômico, Ambiental e Social”) and it is
developed by a multidisciplinary team.
The Forestry Operation intends to have by 2017 all the wood used in the
project certified by FSC- Forest Stewardship Council. All the process that the
Forestry Operation manages will be certified.
The certification process will be conducted in phases. The first phase involves
all the existing planted wood and the ones to be planted until July 2012. Preaudit is scheduled for March 2012 and final audit in July 2012. After that
ELDORADO will include the new plantings in the scope year by year. More
details about FSC certification can be obtained in Section 3.5.
3.2.2
Forestry Operations Description
ELDORADO (Forestry Operations) is currently working with 4 models of
land 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 means
planting, maintenance, harvesting and transportation of the wood, employing
ELDORADO’s employees or contractors workers. It is also responsible for
complying with environmental legislation.
50
Leased Land:
ELDORADO rents the land for 14 years, 2 eucalyptus cycles. ELDORADO is
responsible for the whole forest operation, which means planting,
maintenance, harvesting and transportation of the wood, employing
ELDORADO’s employees or contractors workers.
Partnership land:
For partnership contracts, ELDORADO is in charge of the operation and its
costs, for which it will receive a percentage of wood production (80%). The
partner, the land owner, can choose to sell his percentage of the wood to
ELDORADO or others.
ELDORADO is also responsible for the whole forestry operations, which
means planting, maintenance, harvesting and transportation of the wood,
employment and/or contractors workers.
There are currently 121 partnership and leased land contracts in 12
municipalities: Água Clara/MS, Selvíria/MS, Três Lagoas/MS, Santa Rita do
Pardo/MS, Pontal do Araguaia/MT, Corumbá/MS, Alto Araguaia/MS,
Inocência/MS, Dois Irmãos do Buriti/MS, Ribas do Rio Pardo/MS, Aparecida
do Taboado/MS and Anastácio/MS.
To sign a contract for leased land and partnership, ELDORADO request the
land owner provide several documents to verify that the land is in compliance
with environmental and social legislation.
ELDORADO is responsible to operate the land in compliance with Brazilian
environmental and social Legislation.
Wood Supplier:
ELDORADO will be in charge of harvesting and transport in the majority of
the suppliers, while the land owner was in charge of planting and growing.
Reportedly, wood supply will be used in the first years of operation, until
2016. The wood will arrive from the states of São Paulo, Minas Gerais, Mato
Grosso do Sul and Mato Grosso. Wood from São Paulo will be transported by
river and the others by truck. Table 3.1 shows the wood supply program for
the following years.
51
Table 3.1
Wood Supply Program
State
Municipality
Owner
Type of Harvesting
MS
Água Clara
Paulo Formigoni
MS
Ribas do Rio
Pardo
MS
Ribas do Rio
Pardo
MS
Harvesting Volume (Thousend m³sc)
2013
Eldorado
-
577
839
-
-
1.416
Grupo Mutum
Eldorado
316
-
86
-
-
402
N. BIASI
Eldorado
-
-
-
357
-
357
Três Lagoas
RODRIGO
ARRUY
Eldorado
-
-
18
-
-
18
MS
Água Clara
Paulo Bentivoglio Eldorado
-
-
82
-
-
82
MS
Brasilândia
Paulo Baldini
Eldorado
-
-
145
-
-
145
MS
Ribas do Rio
Pardo
Maria Aparecida
Eldorado
-
55
-
-
-
55
MS
Água Clara
José Arnaldo
Eldorado
-
-
55
-
-
55
MS
Ribas do Rio
Pardo
Rinaldo Rocha
Eldorado
24
76
-
52
-
152
MS
Campo Grande
Vitório Maronese Eldorado
91
-
-
-
-
91
SP
Paranapanema
PJB
Third Part
60
-
-
-
60
SP
Paranapanema
PJB
Third Part
90
-
-
-
90
MS
Água Clara
João Cancio
Eldorado
-
-
106
72
-
178
SP
Piedade
Prosperi
(Alberto)
Third Part
48
80
40
40
30
238
SP
Angatuba
DURATEX
Eldorado
210
1.178
636
-
-
2.024
MG
Nova Ponte
DURATEX
Third Part
65
111
-
-
-
176
SP
Lençois
Lwarcel
Eldorado
-
52
148
99
-
299
SP
Cafelandia
Bertin
Eldorado
203
-
118
-
-
321
SP
Paulistânia
International
Paper
Eldorado
143
125
-
-
-
268
SP
Agudos
Paulo Formigoni
Eldorado
-
296
-
-
-
296
Total SP
664
1.821
942
139
30
3.596
Total MS
431
708
1.331
481
-
2.951
Total MG
65
111
-
-
-
176
1.160
2.640
2.273
620
30
6.723
Total Geral
2014 2015
2016
Total
2012
ELDORADO has a procedure for the Development of Environmental, Social
and Technical Project (PTEAS) which should be applied to every farm 1 or 2
months before intervention (planting and harvesting) to support land
management. This PTEAS should be developed by a multidisciplinary group
composed of representatives of the following areas/departments: social,
cartography, environmental, certification, communication (community
relations), harvesting, agroforestry, health and safety and logistic. Each
representative is responsible to identify the technical features of the farm to
support the land management planning. This procedure is dated December
2011 and PTEAS was not carried out at farms in which planting was
performed before it.
52
3.3
OVERVIEW OF THE LOGISTICS PROJECT
Based on technical, economic and environmental feasibility factors,
ELDORADO will construct two multimodal terminals according to two
distinct models, as described below:
 Model 1: road transportation from the industrial plant to Aparecida do
Taboado (90km) multimodal terminal, to be built by the Company and,
then, railroad transportation to Santos Port (900 km), where the product
will be loaded into ships for exportation; and
 Model 2: transportation from the industrial plant to Pederneiras
multimodal terminal by barges through Tietê river (350 km) and, then,
using a third party railway (MRS) to Santos Port (520 km), where the
product will be loaded into ships for exportation. In the port of Santos,
ELDORADO will construct and improve two terminals. One of them
comprises existing Warehouses IX, X, XI and XII of the Organized Port of
Santos (Porto Organizado de Santos), hereinafter referred as Terminal
Eldorado and the other area comprises the warehouses III, VIII, XIII and
XVIII, hereinafter referred as Terminal Elmar, as identified by
ELDORADO.
Further information is provided in the sections ahead for each terminal.
3.3.1
Aparecida do Taboado Multimodal Terminal
In Aparecida do Taboado, ELDORADO acquired a parcel of land, with 61.7
hectares, which was part of a farm (Fazenda Boa Esperança). As informed, in
Pederneiras a warehouse will be constructed by ELDORADO, with
approximately 6,000-m² covered area. The finished product from the pulp mill
in 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 will
then be loaded to rail compositions and transported to the Santos port
terminal by existing railway operated by the concessionaire ALL (América
Latina Logística).
According to ELDORADO site contacts, the company will be responsible for
the construction of the terminal, but all the operation will be carried out by
ALL.
The terminal is still in project stage and the construction works have not yet
started. An internal railway branch will also be part of the project and will be
constructed by ELDORADO.
53
3.3.2
Pederneiras Multimodal Terminal
This model considers the transportation of bleached pulp bales by barges from
the pulp mill to the multimodal terminal located in the municipality of
Pederneiras, approximately 350 km from Três Lagoas, in the State of São
Paulo, using the existing Tietê - Paraná hydro way. In Pederneiras, one
warehouse and one internal railway branch will be constructed.
The pulp mill project comprises the construction of a pier at ELDORADO site
in Três Lagoas, which is already included in the pulp mill licensing process.
The Pederneiras terminal destined to ELDORADO’s support operations
consists of the expansion of an existing terminal operated by private
companies EPN/Torque. ELDORADO established a contract with the
navigation company EGTM Navegação (Torque), which will be responsible for
the expansion of the existing terminal and the construction of the required
warehousing space for pulp storage, as well as will be in charge of obtaining
all the required permits. The existing operations at the terminal are mostly
related to grains storage and transportation. No further details are available
regarding the expansion.
Similarly, a new railway branch will be constructed in the terminal. The
railway lines from Pederneiras to Santos Port are operated by the
concessionaire MRS Logística, which will reportedly be responsible for the
construction 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 of
the existing operator EGTM Navegação – Torque.
3.3.3
Santos Port Terminal
Background
Santos Port administration was granted, since 1888 through an imperial
decree, to an economical group (Gaffre, Guinle & Cia.) that won a public
tender process. The group constituted a company called Companhia Docas de
Santos, 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 government
constituted 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 public
tender processes.
54
ELDORADO intends to construct and operate two port terminals in Santos.
However, due to time constraints, two different situations will occur. A brief
timeline of the port operations by ELDORADO is presented herein.
First Two Years of Operation – Terminal Elmar
ERM visited the area of the Terminal Elmar on February 10, 2012 and was
accompanied in the visit by Mr. Alvaro Bunster, Eldorado’s Logistics
Executive Manager.
ELDORADO acquired part of the shares of a company that already operates a
port terminal in the port of Santos. The company operates with solid bulk
materials and is in conformance with the Santos Port Development and
Zoning Plan (PDZPS – Plano de Desenvolvimento e Zoneamento do Porto de Santos
– CODESP, 2006), which allows the handling and movement of solid bulk
materials of vegetal or mineral origin, liquids of vegetal origin, containers and
general loads at that area. ELDORADO operations will also be in compliance
with this zoning regulation, given that pulp is classified as general load.
The concession acquired by ELDORADO comprises two existing warehouses
currently operating (Warehouses III and VIII), one area corresponding to a
demolished warehouse (Warehouse XIII) and one warehouse in process of
demolition (Warehouse XVIII).
For the first two years of operation, ELDORADO has also established a
service provision contract to use an area out of the organized port of Santos,
which is operated by a company named Hipercon Terminais. According to
information provided by the company’s contacts, in this area two tarpaulin
sheds will be assembled and one internal railway branch will be constructed.
The tarpaulin sheds will constitute a buffer for the ships loading. One
additional railway branch will also be constructed by the railway
concessionaire at that area, parallel to existing railway lines, directly
connecting Hipercon’s area to the port terminal area. Reportedly, ELDORADO
will finance the construction of the required infrastructure in Hipercon’s area,
but the operations will remain in the name of that company, which will be
responsible for obtaining all the required permits for construction.
Two tarpaulin sheds will also be assembled in the Terminal Elmar, on the area
corresponding to the Warehouse XIII, already demolished and on the area
corresponding to Warehouse XVIII, in process of demolition.
In order to be allowed to demolish warehouse XVIII, ELDORADO is required
to develop a demolition plan and submit it to CODESP, which will issue an
authorization. ELDORADO has already developed the demolition plan and
submitted to CODESP and is currently waiting for the company’s
authorization. The tarpaulin sheds at Terminal Elmar will also work as a
buffer for the ships loading.
55
Initially, the pulp from the industrial complex in Três Lagoas will arrive to the
area operated by Hipercon and will be unloaded at the tarpaulin sheds to be
constructed. Pulp will then be loaded and transported by trucks to the area of
Terminal Elmar, where it will be either unloaded to the tarpaulin sheds in the
terminal area or directly to the ships. At the port terminal, the transport of
pulp from the tarpaulin sheds to the mooring berths will initially be
accomplished by trucks.
It is expected that the issuance of all the required authorizations, the process
of constructing the internal railway branches and assembly of the tarpaulin
sheds in Hipercon’s area, the demolition of Warehouse XVIII and the assembly
of the tarpaulin sheds in the Terminal Elmar’s area will take approximately six
months, coinciding with the pulp mill startup, thus allowing the initial
operation in the Port of Santos.
After this initial operation stage, ELDORADO will demolish Warehouses III
and VIII and construct new warehouses, which will be specifically designed
for the movement of pulp bales, using cranes (automated operation).
ELDORADO also foresees the installation of a conveyor, connecting the
warehouses to the mooring berths (approximately 300 m), thus reducing the
traffic of trucks in the region.
ELDORADO expects that the process of obtaining all required authorizations,
improving the existing warehouses, construction of the railway branch until
the Terminal Elmar area and installing the conveyor, will take approximately
two years. After this period, ELDORADO will leave Hipercon’s area and will
definitively operate only in Terminal Elmar’s area.
Future Operations – Terminal ELDORADO
Foreseeing the future expansions of the pulp production industrial complex in
Três 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, which
are currently operating. As the concession granted by CODESP for the
operation of these warehouses is about to expire, a new public tender is
ongoing. ELDORADO is participating of this public tender process.
ELDORADO has already submitted to CODESP the project of the new
terminal. Considering that the warehouses are in area of Federal management
(area belonging to the Federation), ELDORADO has also submitted the
project to the Federal Environmental Agency – IBAMA.
The Terminal Eldorado will consist of four warehouses, whose improvement
will be specifically designed for the movement of pulp bales using cranes
(automated operation).
56
Two internal railway branches will be constructed by the railway
concessionaire at the area, thus releasing the existing railway lines for the
traffic of other compositions and avoiding traffic congestion.
The timeline for completion of the second port terminal in Santos is not yet
defined.
3.4
As part of the scope, ERM assessed if the environmental licensing process,
which includes the Environmental Impact Assessment (EIA) study, public
hearings and the environmental basic programs, was performed in
compliance with Brazilian regulations. The Brazilian environmental
permitting legislation and detailed information of the licensing status process
is 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 Operations
The pulp mill has been granted, until the present moment, with Preliminary
and Installation Permits by the State Environment Agency IMASUL – Mato
Grosso do Sul Environmental Institute (Instituto de Meio Ambiente do Mato
Grosso do Sul). Installation License nº 17/2011 issued on February 24th, 2011,
valid until March 26th, 2013, refers to the second step of the environmental
licensing process, which includes the approval of the environmental and
social impact assessment (EIA) and also the proposed environmental
monitoring plans outlined in the Impact assessment study and then detailed
within an Environmental Basic Plan - PBA (Plano Básico Ambiental). The
requirements of both licenses are being implemented. The environmental
programs PBA (Plano Básico Ambiental) Basic Environmental Plans are
currently being implemented. Therefore, the company is in compliance
regarding the environmental licensing process.
In addition, ELDORADO has recently decided to include a sodium chlorate
manufacturing plant on site, instead of transporting the sodium chlorate by
tank trucks from market suppliers. As a result, it applied for an Installation
Permit for the plant expansion on August 31, 2011. Additionally, it developed
an environmental study (EAP – Estudo Ambiental Preliminar) and a risk
analysis, considering the presence of the Chlorate plant to subsidize the
licensing process. The Installation Permit for the Chlorate Plant has not been
issued 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 November
18th, 2011 in order to include in the Installation Permit the commissioning of:
57
pulp production, chemical recovery, utilities and manufacturing systems for
sodium 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 therefore
would require their own preliminary, installation and operating licenses.
The Forestry Operations are not subjected to environmental licensing
process, according to the Brazilian regulations. According to samples of
documents from eucalyptus cultivating areas, provided during site visit, the
Forestry Operations comply with licensing requirements and procedures
with the state environmental agency.
3.4.2
Logistics Project
The environmental licensing process differs for each area of the logistical
undertaking.
Regarding the intermodal terminal in Aparecida do Taboado-MS, it is
subjected to the Mato Grosso do Sul environmental agency (IMASUL). A
Simplified Environmental Report- RAS was developed and, reportedly, it has
been submitted to the environmental agency in order to be granted with the
preliminary license.
As for the Pederneiras site, licensed under São Paulo environmental agency
(Cetesb), the area will be operated by a third party company which through
contract must comply with environmental legislation, obtain and maintain all
permits and licenses required. ELDORADO declares that has no responsibility
regarding permits or licensing of the area, however, a co-responsibility
relating to environmental and social compliance exists and, therefore, the
Company should ensure that all third parties’ companies comply with the
applicable regulations.
Regarding the areas of the Port Terminal in Santos, currently three areas are
under the scope of the logistics undertaking: i)A temporary warehouse,
outside the so called organized port, licensed under São Paulo environmental
agency (Cetesb), which is owned by a third company that will also operate
and be responsible for all environmental permits and compliance with
legislation; ii)The warehouses III, VIII, XIII and XVIII, inside the “Elmar
Terminal”, also licensed under Cetesb, purchased by ELDORADO from
Rodrimar S/A Transportes Equipamentos Industriais e Armazéns Gerais.
Warehouses XIII are not currently housing any operations. Warehouse XVIII
has already been demolished and the area is released for the construction of a
new warehouse, as intended by Eldorado. Warehouse XVIII is currently in
process of demolition with the Santos Port Authority (CODESP), to allow the
future construction of a new warehouse. This area has operating permit (for
warehouses III and VIII according to Cetesb’s site) under the third company’s
name and no information has been provided regarding changes in the
58
corporate name of these permits; iii) The permanent area of the organized
port, of warehouses IX to XII, which are licensed under Federal
Environmental Agency (IBAMA), that ELDORADO has submitted a letter of
introduction of the project in order to start the permit process and require a
term of reference. However, the area is still waiting for bidding from CODESP
which is the institution that manages the Port of Santos. Again, a coresponsibility relationship relating to environmental and social compliance
exists 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 Council
The Forest Stewardship Council (FSC) is an international body which
accredits certification organizations in order to guarantee the authenticity
of their claims. In all cases the process of certification will be initiated
voluntarily by forest owners and managers who request the services of a
certification organization. The goal of FSC is to promote environmentally
responsible, socially beneficial and economically viable management of the
world's forests, by establishing a worldwide standard of recognized and
respected Principles of Forest Stewardship.
The FSC's Principles and Criteria (P&C) apply to all tropical, temperate and
boreal forests, as addressed in Principle #9 and the accompanying glossary.
Many of these P&C apply also to plantations and partially replanted
forests.
The FSC is based on internationally-acceptable principles and criteria for
sustainable forest management, and include the following principles:
 Principle #1: Compliance with laws and FSC Principles. Forest
management shall respect all applicable laws of the country in which they
occur, and international treaties and agreements to which the country is a
signatory, and comply with all FSC Principles and Criteria.
 Principle #2: Tenure and use rights and responsibilities. Long-term
tenure and use rights to the land and forest resources shall be clearly
defined, documented and legally established.
 Principle #3: Indigenous peoples' rights. The legal and customary rights
of indigenous peoples to own, use and manage their lands, territories, and
resources shall be recognized and respected.
 Principle #4: Community relations and worker's rights. Forest
management operations shall maintain or enhance the long-term social and
economic well-being of forest workers and local communities.
59
 Principle #5: Benefits from the forest. Forest management operations shall
encourage the efficient use of the forest's multiple products and services to
ensure economic viability and a wide range of environmental and social
benefits.
 Principle #6: Environmental impact. Forest 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.
 Principle #7: Management plan. A management plan -- appropriate to the
scale and intensity of the operations – shall be written, implemented, and
kept up to date. The long term objectives of management, and the means of
achieving them, shall be clearly stated.
 Principle #8: Monitoring and assessment. Monitoring shall be conducted - appropriate to the scale and intensity of forest management -- to assess
the 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 or
enhance the attributes which define such forests. Decisions regarding high
conservation value forests shall always be considered in the context of a
precautionary approach.
 Principle #10: Plantations. Plantations shall be planned and managed in
accordance with Principles and Criteria 1 - 9, and Principle 10 and its
Criteria. While plantations can provide an array of social and economic
benefits, and can contribute to satisfying the world's needs for forest
products, they should complement the management of, reduce pressures
on, 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 forest
management (owned and lease lands and partnership agreement) and the
wood custody chain.
To accomplish this goal, ELDORADO already started to prepare the forest
management certification; they undertook training, formed working groups,
elaborated and executed an action plan, hired the certification company (SCS
Flora) and received their technical visit. They also elaborated the Forest
Management Plan, which first version was verified by the Certification
Company. This plan does not include the regions of Anastácio and Dois
irmãos do Buruti municipalities.
The pre-certification audit to the wood process is planned to April/2012 and
the certification audit to August/2012. After that, the company will start the
60
process to certify the custody chain. This second certification process goes
from September/2012 to November/2012, when the custody chain
certification audit is planned to occur.
In relation to the actions to attend all FSC requirements, ELDORADO has
developed an action plan to FSC Principles and Criteria implementation. For
certification purposes, it is not necessary to accomplish 100% of all FSC
Principles and after the certification it is not necessary to maintain an action
plan, however, regular audits will be performed in order to guarantee that the
company has been improving its management system and attendance of the
principles. The updated status of certification, attendance of FSC principles
and actions that need to be implemented are described in the table below:
61
Table 3.2
ELDORADO’s FSC Certification Status
Principles & Criteria - FSC
ELDORADO selfassessment Necessary actions to fully accomplish the criteria of each
Status (% complete) principle
12/April/2012
Principle #1: Compliance with laws and FSC Principles
Forest management shall respect all applicable laws of the country in which they
occur, and international treaties and agreements to which the country is a
signatory, and comply with all FSC Principles and Criteria.
91
1.1 Forest management shall respect all national and local laws and administrative
requirements.
91
Increase the sampling of the IVC (Contracts Verification Items).
Obtain the collective bargaining agreement (July).
1.2 All applicable and legally prescribed fees, royalties, taxes and other charges
shall be paid.
86
Prove fees exemption. This item will become "Not Applicable"
until the next evaluation round.
1.3 In signatory countries, the provisions of all binding international agreements
such as CITES, ILO Conventions, ITTA, and Convention on Biological Diversity,
shall be respected.
100 -
1.4 Conflicts between laws, regulations and the FSC Principles and Criteria shall be
evaluated for the purposes of certification, on a case by case basis, by the certifiers
and the involved or affected parties.
75 Create a crisis committee.
1.5 Forest management areas should be protected from illegal harvesting,
settlement and other unauthorized activities.
93 Establish systematic of patrols, recycling, etc.
1.6 Forest managers shall demonstrate a long-term commitment to adhere to the
FSC Principles and Criteria.
100 -
1.7 The responsible for the Unit of Forest Management (UMF) under certification
must declare its long-term commitment to the maintenance of representative
samples of existing ecosystems as (P6.c4), from areas such as legally protected (PPA
and LR).
If there are PPA or LR areas, the company will have to register
then. But today no RPPN areas exist in the company's land, so
85
this item will become "Not Applicable" at the next evaluation
stage.
Principle #2: Tenure and use rights and responsibilities
Long-term tenure and use rights to the land and forest resources shall be clearly
defined, documented and legally established.
84
62
12/April/2012
Obtain consent from the owners to allow the inspection of
87 property register (leased lands). Only 80% of owners have given
this consent until this moment.
2.1 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 maintain
control, to the extent necessary to protect their rights or resources, over forest
operations unless they delegate control with free and informed consent to other
agencies.
100 -
2.3 Appropriate mechanisms shall be employed to resolve disputes over tenure
claims and use rights. The circumstances and status of any outstanding disputes
will be explicitly considered in the certification evaluation. Disputes of substantial
magnitude involving a significant number of interests will normally disqualify an
operation from being certified.
100 -
2.4 The responsible for the UMF (Unit of Forest Management) should respect
customary recognized rights of local communities who have no legal rights of land
possession or use, seeking uses mechanisms that help then to legalize their rights
and establishing agreements to ensure the presence of these communities in
harmony with the forest management operations, or to promote resettlement, and
in last case, fare compensation.
100 -
3 Principle #3: Indigenous peoples' rights
The legal and customary rights of indigenous peoples to own, use and manage
their lands, territories, and resources shall be recognized and respected.
100
3.1 Indigenous peoples shall control forest management on their lands and
territories unless they delegate control with free and informed consent to other
agencies.
100 -
3.2 Forest management shall not threaten or diminish, either directly or indirectly,
the resources or tenure rights of indigenous peoples.
100 -
3.3 Sites of special cultural, ecological, economic or religious significance to
indigenous peoples shall be clearly identified in cooperation with such peoples, and
recognized and protected by forest managers.
100 -
3.4 Indigenous peoples shall be compensated for the application of their traditional
knowledge regarding the use of forest species or management systems in forest
operations. This compensation shall be formally agreed upon with their free and
informed consent before forest operations commence.
This principle was considered in compliance during the
certification company technical visit.
100 (N/A) -
63
12/April/2012
3.5 Objective measures should be taken to avoid the negative social impacts of
forest management activities in order to contribute to the enhancement of the
diversity of indigenous and traditional communities.
100 -
3.6 The management responsible should provide information on identification,
location and population of all indigenous communities, traditional communities in
areas under forest management, bordering areas, and areas that have been claimed
in relation to customary rights over the area to be certified.
100 -
3.7 Indigenous communities and / or traditional communities that live in areas
under forest management or bordering areas, should directly control the use of
their natural resources, they can establishing contracts and partnerships for
planning and implementation of management plans in their territories.
100 -
Principle #4: Community relations and worker's rights
Forest management operations shall maintain or enhance the long-term social
and economic well-being of forest workers and local communities.
89
4.1 The communities within, or adjacent to, the forest management area should be
given opportunities for employment, training, and other services.
75
Do partnerships with the government. Make an agreement to
work with Universities.
4.2 Forest management should meet or exceed all applicable laws and/or
regulations covering health and safety of employees and their families.
90
Make the company's health campaigns together / in the same
period of the municipal government health campaigns.
4.2A All workers in the forest management unit should have access to health, in
obedience of the law.
77
4.2B There must be sanitary and environmental conditions appropriate to the
performance of activities.
89
4.3 The rights of workers to organize and voluntarily negotiate with their
employers shall be guaranteed as outlined in Conventions 87 and 98 of the
International Labor Organization (ILO).
The labor union will be institutionalized in July; the meeting to
approve the collective bargaining agreement will be at the same
92
month. After accomplish this task this criteria will be 100% in
compliance.
4.4 Management planning and operations shall incorporate the results of
evaluations of social impact. Consultations shall be maintained with people and
groups (both men and women) directly affected by management operations1.
97
64
Run two more PTEAS during harvest period to validate the
systematic to evaluate social impacts.
12/April/2012
4.5 Appropriate mechanisms shall be employed for resolving grievances and for
providing fair compensation in the case of loss or damage affecting the legal or
customary rights, property, resources, or livelihoods of local peoples. Measures
shall be taken to avoid such loss or damage.
97 Create a crisis committee.
4.6 The responsible for forest management should consider the social initiatives that
should be included in planning and operations of forest management activities.
Must be maintained and proven clear information and opportunity of participation
for local community directly affected for forest management operations and their
views on the aspects that directly affect their quality of life should be considered.
85
4.7 There should be a mechanism for dialogue and resolution of complaints
between the workers and the responsible for the UNIT of forest management,
including a person to represent formally the workers, recognized by then.
The company already has an initiative in which the HR team
goes to the field to collect the field staff claims, but they still lack
in give responses to then in relation to their claims.
68
Make minutes of the dialogues between the committee and the
community.
Create the crisis committee.
4.8 The workers must have remuneration at least compatible with the average of
the market in the region, in accordance with the productive activity performed.
100 -
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...
100 (N/A) -
4.10 The women working during pregnancy and breastfeeding period should be
accompanied of preventive dangers and risk measures inherent to the productive
activity performed.
100 As the company has a lack of local labor, they do not dismiss
employees when the activity ends in a certain region; they just
relocate the staff to other Operational Management Unit
93
(Unidade de Gerenciamento Operacional UGO). But they do not
have procedure for demonstrating this guideline, so it will be
demonstrated only during the audit.
4.11 In case of substantial changes in the workforce of the Unit of Forest
Management, preventive actions should be taken to minimize the impacts of layoffs
on workers and local community.
4.12 The adoption of programs or strategies to flexibilize work should not result in
damage to the rights legally acquired by the workers and the local community.
Increase the amount of PTEAS executed and solve the identified
problems.
100 -
65
12/April/2012
4.13 The community's access to management and non-predatory collection of forest
products, from wood or not, is allowed in the places where such access already
existed for legal or historical reasons, for that the user has to have formal
authorization from the responsible for the forest management unit ,respecting
property rights.
100 -
Principle #5: Benefits from the forest
Forest management operations shall encourage the efficient use of the forest's
multiple products and services to ensure economic viability and a wide range of
environmental and social benefits.
To achieve 100% of attendance in this principle, Eldorado
executed initiatives such as conducted a study with Sebrae to
100
make beekeeping activities at the company's farms to be
carried out with local beekeepers.
5.1 Forest management should strive toward economic viability, while taking into
account the full environmental, social, and operational costs of production, and
ensuring the investments necessary to maintain the ecological productivity of the
forest.
100 -
5.2 Forest management and marketing operations should encourage the optimal
use and local processing of the forest's diversity of products.
100 -
5.3 Forest management should minimize waste associated with harvesting and onsite processing operations and avoid damage to other forest resources.
100 -
5.4 Forest management should strive to strengthen and diversify the local economy,
avoiding dependence on a single forest product.
100 -
5.5 Forest management operations shall recognize, maintain, and, where
appropriate, enhance the value of forest services and resources such as watersheds
and fisheries.
100 -
5.6 The rate of harvest of forest products shall not exceed levels which can be
permanently sustained.
100 -
Principle #6: Environmental impact
Forest 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.
75
66
12/April/2012
6.1 Assessment of environmental impacts shall be completed -- appropriate to the
scale, intensity of forest management and the uniqueness of the affected resources - and adequately integrated into management systems. Assessments shall include
landscape level considerations as well as the impacts of on-site processing facilities.
Environmental impacts shall be assessed prior to commencement of site-disturbing
operations.
The environmental aspects and impacts have been identified,
88 but the company need to implement the necessary actions
related to them.
6.2 Safeguards shall exist which protect rare, threatened and endangered species
and their habitats (e.g., nesting and feeding areas). Conservation zones and
protection areas shall be established, appropriate to the scale and intensity of forest
management and the uniqueness of the affected resources. Inappropriate hunting,
fishing, trapping and collecting shall be controlled.
Eldorado needs to make an agreement with the university for
92 monitoring and tracking areas with high conservation value
(AAVC).
6.3 Ecological functions and values shall be maintained intact, enhanced, or
restored, including:
a) Forest regeneration and succession.
b) Genetic, species, and ecosystem diversity.
c) Natural cycles that affect the productivity of the forest ecosystem.
100 -
6.4 Representative samples of existing ecosystems within the landscape shall be
protected in their natural state and recorded on maps, appropriate to the scale and
intensity of operations and the uniqueness of the affected resources.
80
6.5 Written guidelines shall be prepared and implemented to: control erosion;
minimize forest damage during harvesting, road construction, and all other
mechanical disturbances; and protect water resources.
The environmental aspects and impacts have been identified,
92 but the company need to implement the necessary actions
related to them.
6.6 Management systems shall promote the development and adoption of
environmentally friendly non-chemical methods of pest management and strive to
avoid the use of chemical pesticides. World Health Organization Type 1A and 1B
and chlorinated hydrocarbon pesticides; pesticides that are persistent, toxic or
whose derivatives remain biologically active and accumulate in the food chain
beyond their intended use; as well as any pesticides banned by international
agreement, shall be prohibited. If chemicals are used, proper equipment and
training shall be provided to minimize health and environmental risks.
93 Improve monitoring of handling pesticides.
6.7 Chemicals, containers, liquid and solid non-organic wastes including fuel and
oil shall be disposed of in an environmentally appropriate manner at off-site
locations.
92 Finish the implementation of the waste management procedure.
67
The company needs to spread the emergency response plan
(PAE)
12/April/2012
6.8 Use of biological control agents shall be documented, minimized, monitored
and strictly controlled in accordance with national laws and internationally
accepted scientific protocols. Use of genetically modified organisms shall be
prohibited.
100 -
6.9 The use of exotic species shall be carefully controlled and actively monitored to
avoid adverse ecological impacts.
100 -
6.10 Forest conversion to plantations or non-forest land uses shall not occur, except
in circumstances where conversion:
a) entails a very limited portion of the forest management unit; and
b) does not occur on high conservation value forest areas; and
c) will enable clear, substantial, additional, secure, long term conservation benefits
across the forest management unit.
100 -
6.11 Information regarding pesticide substances shall be given to all potentially
affected, ir order to alert the possible negative impacts in people, hydric resources,
fauna, flora and native reserves.
100 -
68
12/April/2012
Principle #7: Management plan
A management plan -- appropriate to the scale and intensity of the operations -shall be written, implemented, and kept up to date. The long term objectives of
management, and the means of achieving them, shall be clearly stated.
67
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 adjacent
lands.
c) Description of silvicultural and/or other management system, based on the
ecology of the forest in question and information gathered through resource
inventories.
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 endangered
species.
h) Maps describing the forest resource base including protected areas, planned
management activities and land ownership.
i) Description and justification of harvesting techniques and equipment to be used.
The management plan is already prepared, but the company
70 need to do updates and corrections regarding data from farms
until August/2012
7.2 The management plan shall be periodically revised to incorporate the results of
monitoring or new scientific and technical information, as well as to respond to
changing environmental, social and economic circumstances.
100 -
7.3 Forest workers shall receive adequate training and supervision to ensure proper
implementation of the management plan.
100 -
7.4 While respecting the confidentiality of information, forest managers shall make
publicly available a summary of the primary elements of the management plan,
including those listed in Criterion 7.1.
67
69
The overview of the management plan will be made only in July
/ 2012.
12/April/2012
Principle #8: Monitoring and assessment
Monitoring shall be conducted -- appropriate to the scale and intensity of forest
management -- to assess the condition of the forest, yields of forest products,
chain of custody, management activities and their social and environmental
impacts.
79
8.1 The frequency and intensity of monitoring should be determined by the scale
and intensity of forest management operations as well as the relative complexity
and fragility of the affected environment. Monitoring procedures should be
consistent and replicable over time to allow comparison of results and assessment
of change.
100 -
8.2 Forest management should include the research and data collection needed to
monitor, 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.
The company needs to develop a plan for monitoring the rate of
the forest growth (IMA). For achieve this task, Eldorado has
51
hired specialized employees, but it is expected to take some time
in order to achieve compliance.
8.3 Documentation shall be provided by the forest manager to enable monitoring
and certifying organizations to trace each forest product from its origin, a process
known as the "chain of custody."
This step will be worked during the custody chain certification,
79 which will begin after the conclusion of the forest management
certification.
8.4 The results of monitoring shall be incorporated into the implementation and
revision of the management plan.
100 -
8.5 While respecting the confidentiality of information, forest managers shall make
publicly available a summary of the results of monitoring indicators, including
those
67
Principle #9: Maintenance of high conservation value forests
Management activities in high conservation value forests shall maintain or
enhance the attributes which define such forests. Decisions regarding high
conservation value forests shall always be considered in the context of a
precautionary approach.
80
9.1 Assessment to determine the presence of the attributes consistent with High
Conservation Value Forests will be completed, appropriate to scale and intensity of
forest management.
The overview of the management plan will be made only in July
/ 2012.
100 -
70
12/April/2012
9.2 The consultative portion of the certification process must place emphasis on the
identified conservation attributes, and options for the maintenance thereof.
67
9.3 The management plan shall include and implement specific measures that
ensure the maintenance and/or enhancement of the applicable conservation
attributes consistent with the precautionary approach. These measures shall be
specifically included in the publicly available management plan summary.
The company needs to validate the study of high conservation
value areas to meet this requirement.
100 -
9.4 Annual monitoring shall be conducted to assess the effectiveness of the
measures employed to maintain or enhance the applicable conservation attributes.
At the moment this criteria is not applicable. The company will
67 be able to perform this evaluation just after 1 year of
certification.
Principle #10: Plantations
Plantations shall be planned and managed in accordance with Principles and
Criteria 1 - 9, and Principle 10 and its Criteria. While plantations can provide an
array of social and economic benefits, and can contribute to satisfying the
world's needs for forest products, they should complement the management of,
reduce pressures on, and promote the restoration and conservation of natural
forests.
83
10.1 The management objectives of the plantation, including natural forest
conservation and restoration objectives, shall be explicitly stated in the
management plan, and clearly demonstrated in the implementation of the plan.
100 -
10.2 The design and layout of plantations should promote the protection,
restoration and conservation of natural forests, and not increase pressures on
natural forests. Wildlife corridors, streamside zones and a mosaic of stands of
different 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 blocks
shall be consistent with the patterns of forest stands found within the natural
landscape.
100 -
10.3 Diversity in the composition of plantations is preferred, so as to enhance
economic, ecological and social stability. Such diversity may include the size and
spatial distribution of management units within the landscape, number and genetic
composition of species, age classes and structures.
100 -
71
12/April/2012
10.4 The selection of species for planting shall be based on their overall suitability
for the site and their appropriateness to the management objectives. In order to
enhance the conservation of biological diversity, native species are preferred over
exotic species in the establishment of plantations and the restoration of degraded
ecosystems. Exotic species, which shall be used only when their performance is
greater than that of native species, shall be carefully monitored to detect unusual
mortality, disease, or insect outbreaks and adverse ecological impacts.
100 -
10.5 A proportion of the overall forest management area, appropriate to the scale of
the plantation and to be determined in regional standards, shall be managed so as
to restore the site to a natural forest cover.
100 -
10.6 Measures shall be taken to maintain or improve soil structure, fertility, and
biological activity. The techniques and rate of harvesting, road and trail
construction and maintenance, and the choice of species shall not result in long
term soil degradation or adverse impacts on water quality, quantity or substantial
deviation from stream course drainage patterns.
100 -
10.7 Measures shall be taken to prevent and minimize outbreaks of pests, diseases,
fire and invasive plant introductions. Integrated pest management shall form na
essential part of the management plan, with primary reliance on prevention and
biological control methods rather than chemical pesticides and fertilizers.
Plantation management should make every effort to move away from chemical
pesticides and fertilizers, including their use in nurseries. The use of chemicals is
also covered in Criteria 6.6 and 6.7.
100 -
10.8 Appropriate to the scale and diversity of the operation, monitoring of
plantations shall include regular assessment of potential on-site and off-site
ecological and social impacts, (e.g. natural regeneration, effects on water resources
and soil fertility, and impacts on local welfare and social well-being), in addition to
those elements addressed in principles 8, 6 and 4. No species should be planted on
a large scale until local trials and/or experience have shown that they are
ecologically well-adapted to the site, are not invasive, and do not have significant
negative ecological impacts on other ecosystems. Special attention will be paid to
social issues of land acquisition for plantations, especially the protection of local
rights of ownership, use or access.
To achieve these criteria, during the audit, the certification
90 company needs to verify if PTEAS is in compliance with FSC
principles and criteria.
72
12/April/2012
10.9 Plantations established in areas converted from natural forests after November
1994 normally shall not qualify for certification. Certification may be allowed in
circumstances where sufficient evidence is submitted to the certification body that
the manager/owner is not responsible directly or indirectly of such conversion.
100 -
Note: 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 FSC
standard 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. Removed
criteria 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.
73
 Social programs implemented by ELDORADO
As 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 social
projects 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 to
invest such amount in programs/projects related to the improvement of
the public infrastructure, and focusing in health and education, social and
environmental, at Tres Lagoas, Selvira, Inocência and Água Clara
municipalities, all located at Mato Grosso do Sul State.
As a result of the social studies, health service is the main vulnerability of
the region that lacks of physical infrastructure, hospitals, equipment and
medical experts. Although there are educational services available, the
region lacks of technical courses and a better distribution of the services
that are concentrated in the urban area.
At Social aspect, the treatment of children requires special attention
because of the increase demand for educational and refuge services. The
urban infrastructure also lacks of areas of environmental preservation and
leisure.
ELDORADO identified the followings projects to be supported between
2012 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 Senhora
Aparecida.
 Educational:
 Construction of the basic school.
74
 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 Family
Health 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 PERFORMANCE
STANDARDS
4.1
BACKGROUND TO CATEGORIZATION
As the Project is not located in a high-income OECD country, in order for the
Project to be aligned with the Equator Principles it must meet the
requirements of the relevant IFC Performance Standards (PSs). The recently
revised IFC PSs are applicable from 1st January 2012 and these have been
applied to this assignment. The Equator Principles require Project Financing
75
Due Diligence to categorize Projects on the basis of the potential magnitude
and impacts associated with the environmental and social aspects of the
Project. The categorization is not influenced by the robustness of mitigation
measures which may be implemented to reduce the environmental and social
risks of the Project.
As described above the Project is defined as the existing assets which are
owned, operated and/or managed by ELDORADO and located within Três
Lagoas, 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 the
inherent risks related to the project sector and the sensitivity of the local
context to be specifically considered in the categorization decision, in addition
to specific project impacts1.
4.2
BASIS FOR CATEGORIZATION
As part of this assessment ERM has assigned the Project a categorization of
Category A (‘business activities with potential significant adverse
environmental or social risks and/or impacts that are diverse, irreversible, or
unprecedented’2).
Project specific impacts are additionally described within Annex C, D and E of
this report.
4.3
APPLICABLE IFC PERFORMANCE STANDARDS
This report reflects ERM’s assessment of the overall alignment of the current
Project status with the Equator Principles and associated applicable Reference
Standards. The due diligence process has additionally provided
recommendations which should be implemented in order to mitigate, reduce
or manage the environmental and social gaps and risks to a level where they
are more acceptable to potential lenders.
Based upon the assessment conducted to date ERM understands that the
following PSs are applicable in terms of managing the current and anticipated
impacts of the Project:
 PS1. Assessment and Management of Environmental and Social Risks and
Impacts;
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 at
http://www1.ifc.org/wps/wcm/connect/fca42a0049800aaaaba2fb336b93d75f/Board-Paper-IFC_SustainabilityFramework2012.pdf?MOD=AJPERES
2 International Finance Corporation’s Policy on Environmental and Social Sustainability, January 1, 2012, Page 8. Also available at
http://www1.ifc.org/wps/wcm/connect/7540778049a792dcb87efaa8c6a8312a/SP_English_2012.pdf?MOD=AJPERES
1
76
 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 Living
Natural 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 Harvesting
Operations; and
 Environmental, Health, and Safety Guidelines Ports, Harbors and
Terminals.
All reporting is by exception; where topics are not referred to, no gaps have
been identified with reference to the IFC PSs or other relevant requirements
identified above. Please see Annex C, D and E for a detailed conformance
assessment for the requirements of each Performance Standard.
4.4
ALIGNMENT WITH EQUATOR PRINCIPLES
The Equator Principles (EPs) represent a financial industry benchmark for
determining, assessing and managing social and environmental risks in
project financing. They are a set of ten principles which have been adopted by
over seventy financial institutions (Equator Principles Financial Institutions EPFIs) in order to ensure the projects they finance are developed in a manner
that is socially responsible and reflect sound environmental management
practices.
In overall terms ERM understands that the Project exhibits a status of Partial
Alignment with the Equator Principles. It is clear that ELDORADO has
awareness of the standards required and, providing sufficient time and
resources are planned, supplied and successfully implemented, may reduce
many of these risks and/or close the majority of these gaps.
77
For the purposes of the Equator Principles assessment the following
definitions are proposed in Table 4.1 below:
Table 4.1
EP Compliance Definitions
Rating
Definition
Aligned

Information available indicates the Project fulfills the
requirement and/or is aligned with intended outcome
of the requirement.
Partially Aligned

Information available indicates the Project partially
fulfills the requirement and/or is partially aligned with
intended outcome of the requirement.
Not Aligned

Information available indicates the Project does not
fulfil the requirement.
Insufficient Information

There is insufficient information to make an
assessment of the level of alignment.
Not Applicable

The requirements do not apply to the Project at the
current time.
Details of alignment with each Equator Principle are provided in
Table 4.2 below:
Table 4.2
Overview of Equator Principles Alignment Assessment
Equator Principle (2006)
Project Alignment
with EP
Comment
1
Review and Categorization
The project has been
categorized under Category A,
B or C.
Aligned: No further
The Project is Categorized as
action required.
Category A.
Justification for this
Categorization is included within
Section 6.1 of this report.
2
Social and Environmental
Assessment
If Category A or B, an
assessment has been prepared
by borrower, consultant or
external expert, and includes
mitigation and management
measures.
The Project includes the
construction of an industrial site,
plantations areas and a logistics
project (which includes ports,
terminal, road, rail and hydro
ways). Logistics project is in
initial phase of development.
Environmental Impact
Assessments (EIAs) have been
conducted for the industrial site.
No Project wide, cumulative or
Project specific Social and
Environmental Assessment for
forest operations and logistics has
been produced.
78
Partially Aligned:
See Annex C, D and E
for details of the
Project alignment with
Specific PS’s.
3
4
5
6
Comment
Applicable Social and
Environmental Standards
Non-OECD countries and
OECD not High-Income: The
project complies with, or
establishes a justified deviation
from, applicable Performance
Standards and EHS Guidelines.
High-Income OECD:
Compliance of local or national
law in High-Income OECD
countries.
IFC Performance Standards have
been used to assess
environmental and social
compliance of the Project. In
addition related IFC EHS and IFC
Sector Guidance have been
referred to. No other assessments
undertaken for the Project (such
as EIAs undertaken for
permitting purposes) have
included reference to the
Performance Standards or EHS
Guidelines.
As part of the due diligence
exercise PS’s 1, 2, 3, 4, 5, 6, 7 and 8
have been determined to be
applicable to the Project.
Action Plan and Management
System
The borrower has prepared an
Action Plan (AP) to address
findings, prioritize mitigation
measures, and take corrective
actions and monitoring
measures.
The borrower has established a
Social and Environmental
Management System.
No Project specific Action Plan
(AP) or integrated social and
environmental management
system has been developed.
Preparation of a comprehensive
integrated Environmental, Social
and Health and Safety
Management System (ESHMS)
and an action plan is a
recommendation this report.
Project Alignment
with EP
Partially Aligned:
See Annex C, D and E
for details of the
Project alignment with
Specific PS’s.
Not Aligned:
A Project specific
integrated
Environmental and
Social Management
System (ESMS) and
Environmental and
Social Action Plan
(ESAP) is
recommended to be
implemented.
Consultation and Disclosure
A Project specific Stakeholder
The borrower, government or Engagement Plan is a
recommendation of this report.
third party expert has
consulted with project-affected
communities in a culturally
appropriate way.
The consultation process has
ensured free, prior and
informed consultation and
participation to include
community concerns.
Partially Aligned:
Grievance Mechanism
To ensure that consultation,
disclosure and community
engagement occurs throughout
construction and operation of
the project, the borrower has
established a grievance
mechanism, scaled to the risks
and adverse impacts of the
project, as part of the
management system.
The grievance mechanism
addresses concerns promptly
and transparently, in a
culturally appropriate manner
and is accessible to the
community.
Partially Aligned:
The expansion of the
existed Grievance
Mechanism to other
stakeholders groups is
a recommendation of
this report.
A Grievance Mechanism exists
for the industrial and forest
Projects. No grievance
mechanism for logistic operations
has been implemented yet.
A pro-active and appropriately
documented Grievance
Mechanism is a recommendation
of this report.
79
A Project specific
Stakeholder
Engagement Plan
(SEP) is recommended.
Comment
7
Independent Review
The Assessment, AP and
consultation process
documentation have been
reviewed by an independent
expert to assist the EPFI’s due
diligence and to assess
compliance with Equator
Principles.
8
Covenants
Required covenants will be
The borrower has covenant(s) developed by Lenders as part of
the Loan Agreement.
linked to the following:
a) Comply with social and
environmental host country
laws, regulations and permits;
b) Comply with the AP during
construction and operation;
c) Provide periodic reports (at
least annually);
d) Decommission facilities
according to plan.
Not applicable at this
time:
Lenders to develop
Project specific
covenants.
9
Independent Monitoring and
Reporting
The project has appointed an
independent or external
environmental and/or social
expert to ensure ongoing
monitoring and reporting.
time:
The Client may engage
an appropriate
independent expert(s)
to carry out periodic
monitoring of the
performance of the
Project and
implementation of the
Action Plan
recommended by this
ESDD.
This report has been prepared to
satisfy this requirement. There
are still assessments to be
performed and the action plan
needs to be detailed.
Independent monitors may be
appointed in accordance with
covenants and the Loan
Agreement. Annual reporting
will be required.
Reporting will be undertaken by
10 EPFI Reporting
Lenders in accordance with EP
The EPFI reports publicly at
least annually the EP processes requirements.
and experience, considering
confidentiality.
5
Project Alignment
with EP
Partially Aligned:
Further assessments
and a detailed action
plan are
recommendations of
this report
time:
Lenders to report in
accordance with EP
requirements.
BENCHMARK OF THE PROJECT - ALIGNMENT WITH BRAZILIAN
LEGAL REQUIREMENTS AND IFC PERFORMANCE STANDARDS
The 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. To
facilitate a focused summary of the gaps and proposed mitigation measures
relating to the Project ERM has adopted the qualitative ranking scheme
provided below. Where one or more aspects at risk correspond to the
definitions below a Risk Level of H (High), M (Moderate), or L (Low) is
provided.
80
Table 5.1
Project Risk Level Definitions
Risk
Level
Risk Group(s)
Definition
High
Immediate action
Immediate action required to address the key
environmental and social risks, which can include legal
compliance findings.
Moderate
Short term action
Actions related to IFC Standards or legal compliance
findings/ gaps, which represent moderate risk to the
project.
Low
Longer term
recommendations
for improvement
Actions that need to be addressed as part of the
management 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 requirements
and the IFC Performance Standards, including the assessment of risks posed
by gaps identified and recommended actions to take steps to mitigate and/or
address these gaps where possible. Further details of the IFC PS’s and ERM’s
assessment of the Project alignment are provided in Annexes C, D and E for the
pulp and paper industrial project, forest operations, and logistics project,
respectively. All reporting is by exception; where topics are not referred to no
gaps have been identified with reference to the IFC PSs or other relevant
requirements.
81
Table 5.2
Summary Gap Analysis and Risk Assessment
PS
Risk Group Description
Para
Ref.
No’s.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Gap
Ref
No.
Recommended Actions
Environmental and Social Assessment and Management System
1.1
5
Moderate
Industrial Operation
According to EIA, the project did evaluate environmental
and social impacts of the project, and mitigation measures
were defined for all impacts identified. The Environmental
Basic Plan -PBA and PBA reports presented detailed these
programs and demonstrate the implementation of the
construction programs until the end of 2011. Programs
associated with the operation will start, reportedly, on
November 2012. According to information given on site
visit the management of the programs is held by two thirdparty companies currently in charge of the site operation,
Meta and DuPont. Reportedly, ELDORADO will take over
the management of the PBA’s implementation and the site
management when the operational license is issued.
Guidance for third party companies is provided by a
document called Health and Safety and Environment of
contracted and subcontracted companies Book.
ELDORADO does not conduct due diligence to monitor
third party companies in charge of the site management.
Logistics
For the logistics project, at this phase of the project, no
environmental or social management system has been
developed.
82
For the industrial operations:
ELDORADO should implement a system to monitor third
party companies in charge of the site management.
ELDORADO should integrate the existing practices in a
management system, that shall include: Training program
for employees and contractors with direct responsibility
for activities relevant to social and environmental
performance of the project
For the Logistics:
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 to social 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 Stakeholder
Engagement;
(iv)
Dissemination of information on the Action
Plan through internal reports for
management of the organization and
external stakeholders, including affected
communities.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
1.2
7 to 10
Moderate
Identification of Risks and Impacts:
For the industrial operations, as part of the permitting
process, ELDORADO developed an Environmental Impact
Assessment (EIA) study, which considers the impacts
related to the planning, implementation and operation of
the project. However, the EIA did not identify the
cumulative impacts from other existing, planned or
reasonably defined developments and also did not identify
potential vulnerable groups that may be differentially or
disproportionately affected by the project because of their
disadvantaged or vulnerable status nor impacts on
biodiversity and ecosystems services.
Integrate and complete, if necessary, the existing studies
(EIA, RAS, social diagnosis, Inventory of High
Conservation Areas, and others), in order to:

Asses cumulative impacts of the project; and

Identify specific vulnerable groups;

Identify direct and indirect project-related
impacts on biodiversity and ecosystem services;

Identify risks and impacts in all parts of the
logistics project (railroad, waterway
transportations, warehouses modifications, etc.)
Complement management programs with the mitigating
action proposed by risks and impacts assessment
recommended above.
Identify areas likely to be affected by the operation at São
Paulo and Minas Gerais state and Dois Irmãos dos Buruti
and Anastacio municipalities.
The Forest Management Plan defined the area affected by
the project. It does not include the lands at São Paulo and
Minas Gerais state (that will supply wood for the first years
of operation) and Dois Irmãos dos Buruti and Anastacio
municipalities, where ELDORADO owns 4 lands and lease
2 lands.
For the logistics project, as part of the permitting process,
ELDORADO has developed a Simplified Environmental
Report – RAS for the multimodal terminal at Aparecida do
Taboado/MS. No environmental and social assessment
was performed for the other parts of the logistics project,
such as, railroad, waterway transportation, warehouse
modifications, among others.
1.3
17
Moderate
Organizational capacity and competency:
For industrial, forest and logistics projects, ELDORADO
has already assigned specific personnel for managing
Environmental and Social (E&S) programs, however, no
training program to support the designated personnel to
carry out their part of the ESMS.
83
Develop training program to support the designated
personnel to carry out their part of the ESMS. The training
program shall ensure consistence with ELDORADO
policies and procedures. The training can be formal,
informal (on-the-job), one-time, periodic, etc. The program
must include third parties with direct responsibility with
activities relevant to the environmental and social
performance of the project, for example, wood suppliers,
rural workers supplier, etc.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
1.4
20 to 21
Moderate
Emergency preparedness and response:
During the assessment, ERM verified that the construction
phase of the industrial plant has an emergency
preparedness and response (EPR) plan in place. This plan
will be completed and adapted for the operation stage.
Emergency Plan should be communicated to affected
community and relevant governmental authorities with
responsibility on emergency situations, e.g, local police,
hospitals, fire department, etc.
It was also verified that forest operations have an EPR.
No EPR has been developed for the logistics project.
1.5
25 to 31
Moderate
Industrial, Forest and Logistics Project:
Stakeholder engagement:
For stakeholder identification, ELDORADO mapped and
identified local stakeholders. Neighbors of the lands where
ELDORADO operates (owned lands, leased lands and
partnerships agreements) are identified through PTEAS.
ELDORADO has the following consultation initiatives:
 For the purpose of social economic diagnosis, a sample
of citizens and local governmental authorities were
interviewed to identify vulnerability of the region;
 For the Inventory of Areas of High Biodiversity,
stakeholders were consulted to identify the areas of
high biodiversity important to the community and the
use of it;
 As a result of the local vulnerabilities identified at the
social economic diagnosis, local governmental
representatives were consulted by ELDORADO to
identify projects that could be supported by
ELDORADO;
 During PTEAS process, neighbors of the lands were
ELDORADO’s operate receive information about
ELDORADO and orientation on how to contact the
company;
 Forums and public hearings were held for the purpose
84
An emergency plan should be prepared for the logistics
projects and communicated to affected community and
relevant governmental authorities with responsibility on
emergency situations, e.g, local police, hospitals, fire
department, etc. in all multimodal terminal ports
(Aparecida do Taboado, Pederneiras and Santos).
For fully comply with the performance standard,
ELDORADO should systematize the stakeholders
identification and contact information, to enable
evaluation of stakeholder and classification according the
following:
 Stakeholders affected by ELDORADO, positively and
negatively, directly and indirectly, particularly those
directly and adversely affected by project activities,
including those that are disadvantaged or vulnerable;
 Stakeholders who may be able to influence the
outcome of the project because of their knowledge
about the affected communities or political influence
over them;
 Legitimate stakeholders representatives, including
elected officials, non-elected community leaders,
leader of informal or traditional community
institutions, and elders within the affected community;
 Stakeholders not directly affected by the project but
may have the ability to influence or alter the
relationship of the client with the affected community.
Develop a Stakeholder Engagement Plan, including:
 engagement principles,
 objective and criteria,
Gap
Ref
No.
1.6
PS
Para
Ref.
No’s.
22 to 24
Risk Group
Low
Description
Recommended Actions
of the industry license process and disclosure
information about the EIA and PBA and identified
community concerns about the project;
 A public hearing for the forestry project will be hold for
certification purpose and the Forest Management Plan
will be disclosured.
ELDORADO does not have a systematic approach to
consult and/or to engage stakeholders.
Besides, none of the above mentioned initiatives were
undertaken to Dois Irmãos do Buruti and Anastacio
municipalities, where ELDORADO owns 6 lands and
leases 2 other lands. According to a social diagnosis
undertaken at these areas, there are around 7 indigenous
lands in the region. According to ELDORADO, none of
them located inside the lands operated by ELDORADO.
Thus, indigenous people, is not currently being engaged or
consulted. These municipalities are located at 350 km away
from Tres Lagoas municipality, where ELDORADO’s pulp
plant is located.


Monitoring and review:
Documents provided do not contain the procedures to
monitor and measure on a regular basis the key
characteristics and performance of the social management
program, including the use of external experts if required.
Develop a systematic to evaluate efficiency of the
mitigation measures.
risks and impacts,
identification, characterization and priority of
stakeholders, focusing on those 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
information about risk and impact.
 the engagement process shall also support the update
of risks and impacts of the operation to affected
community.
Information about risks and impacts identified, mitigation
measures shall be periodically disclosure to affected
community, at least annually, as long the specific items in
the management programs. ELDORADO may consider
using sustainability report on the financial, environmental
and social aspects to report so.
External Communication and Grievance Mechanism
1.7
34 and
35
Low
ELDORADO has the followings communication channel:
 Internal newspaper to workers
There are four mechanisms in place for grievance and to
register communication received from stakeholders:
 There is an ombudsman for industrial workers
85
The grievance mechanism must be part of the Stakeholder
Engagement Plan.
It is recommended to expand the disclosure on how
community and external stakeholders can complain to
ELDORADO.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
grievance (employees and contractor’s worker).
Information about the ombudsman is disclosure disclosed
in at the Manual for Induction and banners at the site.
”Human Resources in the Field”. A representative from
Human Resources visits workers in the field twice a month
to register their demands. ERM reviewed a spreadsheet
containing the name of the worker, complaint, feedback
provided, and time of response. Complains from
contractor’s workers are registered and directed to the
Contract company. None of the complaints registered on
the spreadsheet were related to contractor’s workers.

There is a form to register external communication
from the public. Community and neighbor might
contact ELDORADO’s office in each municipality,
a telephone number, the supervisor of the 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 contact and action
taken. Once complete, the form is delivered to one
person in charge to receive it. The complaint is
registered in a spreadsheet that contains the name
of the person, data, who received the complaint, a
description of the complaint, action taken,
feedback and data. ERM reviewed the spreadsheet
and it contained 13 complains.
Conduct the public hearing for the forest operations and
to disclosure information about the Forest management
Plan.
It is recommended to expand the grievance mechanism
currently in place for industrial and forest operations 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 by ELDORADO;
 it shall be culturally appropriate, readily accessible to
all workers;
 it must be defined roles and responsibilities for
receiving the grievance and communication flow;
 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 to security personnel
abuses and others.

The ELDORADO site’s has a channel to receive
communication through e-mail or telephone number.
Forums and public hearings were held for the purpose
of the industry license process and disclosure
information about the EIA and PBA and identified
community concerns about the project.A public hearing
for the forestry project will be hold for certification
purpose and the Forest Management Plan will be
disclosure.
No grievance mechanism for logistic operations has been
developed yet.
For more information on Grievance Mechanism refer to Section 2.0
of this report.
86
PS
Para
Ref.
No’s.
Ongoing Reporting to Affected Communities
Gap
Ref
No.
1.8
36
Moderate
Recommended Actions
For the ELDORADO industrial project a public hearing
was held for license 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 disclosure twice a year with ongoing information about
the management programs.
It is not clear if stakeholders are communicated about how
to access this information.
Include on communication channels information about
how to access PBA of the industrial site and other relevant
public available information.
Conduct the public hearing for the forest operations and
to disclosure information about the Forest management
Plan.
Include on the stakeholder engagement plan the
disclosure of information related to the logistic project.
Reportedly a public hearing for the forest operations will
be held for certification purpose and the Forest
Management Plan will be public disclosure.
For the logistics project, no ongoing reporting to
stakeholders is planned.
PS 2 - Labor and Working Conditions
Working Conditions and Management of Worker Relationship
2.1
7
Moderate
Industrial, Forest and Logistics Operation:
There is no human resource police that set out its approach
to managing workers as required by this Performance
Standard.
There is current a Policy for Remuneration that states the
salaries and benefits by professional category. This Policy is
not available to the employees and general public.
There is also Policy for Training developed to be applied
for industrial and rural workers, however, the policy has
not being validated by the managers in charge of the forest
activity.
ELDORADO reported to be developing an ethical code.
2.2
8
Low
Forest Operations:
During the Induction process, staffs are reportedly
provided with information associated with legal rights and
other information about working conditions, but it lacks of
87
Develop a Human Resource Policy, procedures or ethical
code, to be applied for workers, contracted workers and
supply chain workers, that cover all issues treated by this
performance standard, as exemplified bellow: working
conditions, terms of employment; collective bargain and
freedom of association; nondiscrimination and equal
opportunity; grievance mechanism; child and forced
Labor; right to privacy about surveillance methods.
Communicate the policy, procedure or ethical code to all
the workers. It is recommended to public disclosure it.
Include on rural workers induction information about
freedom of association and the union representation.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
information about freedom of association and union
representation. Some workers reported not being informed
about union representation and how to join it.
2.3
10
High
(legal noncompliance)
Forest Operations:
ELDORADO has currently 1556 workers, 88% of them are
rural workers, around 1370. 37% of those are migrant
workers.
ELDORADO reported that workers are recruited by a third
part contracted by 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 to Multipla, which will not be
charged from the worker. The contract does not detail the
procedure to contract migrant workers. ELDORADO’s
procedure to Employees Selection and Contraction
(Procedure PCH RH 001 (00) states companies hired to
recruit workers are forbidden to subcontract others to the
recruitment process.
Develop a procedure to the recruitment of migrant
workers, including:

Criteria for third part recruitment;

Travel conditions to workers and to return to their
home;

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 issued to all migrant workers travelling to Tres
Lagoas or back to their origin.
ERM interviewed 9 migrant workers. One of them reported
that he was not recruited by Multipla but by a local man,
who charged him a fee of R$150.00 for the recruitment
process. The charge of a fee from migrant workers does
not complying with the ILO Convention 110, and the
Federal Decree 58.826/66, that promulgates it, and Law
9777/98 and the Union Convention issued by the
Federation of Rural Workers of Mato Grosso do Sul State,
clause 15.
ELDORADO informed that it did not issue the Declaration
of the transport of Workers (CDTT), which does not
comply with the Federal Standard SIT 76/09. This law
states that the transport of workers recruited to work in an
area other than their origin shall be communicated to
Labour regional authority (Superintendências Regionais do
Trabalho- SRTE), SRTE through the Declaration of the
transport of Workers (CDTT)..
88
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
2.4
11
High
Industrial operations:
ELDORADO is directly in charge of 3 accommodations for
migrant workers hired by contractors.
Develop a mechanism to disqualify contractors that are
not monitoring their accommodations or timely solving
the findings identified by Meta.
Contractors are in charge of 135 houses and hotel were
workers are accommodated. Those houses are monitored
by a third part company hired by ELDORADO. Although
the management and monitoring of the contractor’s
accommodation is well structured, no compliance with
Brazilian Legislation are currently identified and not timely
solved by contractors.
2.5
13
Moderate
There have been 3 work stoppages of activities in the site
by workers hired by contractors: On January (1 day of
stop), April (2 days of stop) and August 2011 (8 days of
stop). The work stoppages are considered unofficial
because it lacked the organization aspects defined by
Brazilian regulation (it’s is different of strike, which is
organized and follows the legal terms).
On August, the demand was associated with salaries and
commuting to work. Companies have increased salaries
2,5% and 8% and provided feed benefits. The negotiation
was between the union and contractors, monitored by the
Labour Regional Tribunal and supported by ELDORADO.
ELDORADO reported that, 300 workers were dismissed
after the work stoppage in August 2011.
Monitor dismissal of contractor’s workers who were
engaged on work stoppages /strikes to avoid
discrimination and guarantee freedom of discrimination
and collective bargain.
2.6
14
Low
Industrial and Forest Operations:
Currently, ELDORADO has not taken measures to prevent
and address discrimination in employment relationship,
including harassment, intimidation and/or exploitation.
However, ERM did not identify that any nondiscrimination practices are in place to govern employment
relationships.
Define measures and orient contractors on prevention of
discrimination in employment relationship.
89
Take measures to prevent any harassment, including
sexual harassment or psychological mistreatment within
the workplace, including a module about harassment for
leaders, managers, for example.
Monitor and treat cases of harassment identified through
ombudsman.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
2.7
15
Moderate
Industrial and Forest Operations:
ELDORADO has recently hired a doctor to identify among
workers those that have disability and if the company is in
compliance with the Law 7.853 that states a quota of 5% of
workers with disability for companies with more than
1,0000 workers.
Identify total number of employees with disability and, if
not sufficient to comply with law 3298/99, define
measures to do so at operation phase.
Define a measure to comply with Apprentice Law.
ELDORADO has not developed a plan or measure to
achieve the quota defined by law at operation phase.
ELDORADO informed that there is no apprentice at the
site, which is a not compliance with the Apprentice Law
5.598/05 apprentices, state a quota for apprentices.
However, the company sponsors the Program “My First
Job” that aims to provide technical training to almost 200
students of the local high schools. Fifty percent (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 measure undertaken seems to be sufficient to
guarantee compliance with this requirement.
Brazilian companies face difficulty in complying with both
laws.
Occupational Health and Safety
2.8
23
Moderate
Industry Operation
A deficiency was observed regarding the Regulatory Norm
NR-6, associated with PPE delivery records. The delivery
records do not fully match the list of PPEs that must be
provided to each employee, according to their
Occupational Risk Prevention Plan (PPRA).
Additionally, some PPE deliveries were not properly
registered.
ELDORADO must guarantee the delivery of all PPEs to
the employees. The deliveries must be properly registered
and all PPEs must be adequate to the risks identified and
listed in the PPRA.
Workers Engaged by Third Parties
2.9
24, 25
and 26
Low
Forest Operations:
There are 534 contractors workers hired by Plantar, J&S
and Ruah to perform rural activities. ELDORADO
developed a procedure (Contracts Verification Items - IVC)
90
Guarantee that contractor’s workers are provided with
induction, including information about freedom of
association and collective bargain.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
to verify contractors in relation to labor 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 are verified on a monthly
basis and a report is issues for each verification. In case the
contractor is not complying with the items, a part of the
contractor payment is retained until achieving compliance.
Reportedly, ELDORADO’s practice is to verify contractor’s
workers documentation and health and safety conditions in
place and to revise documentation quarterly. The person in
charge of the contractor monitors contractor’s operational
performance and legal fiscal requirements. Clearance
certificate for fiscal workers payment are provided
monthly.
There is no policy or procedure to monitor the contractor
performance associated with the other aspects of this
performance standard, e.g no discrimination, equal of
opportunity, treatment of workers, etc.
ELDORADO does not monitor or orient contractors (J&S,
Plantar and Ruah) on implementing a grievance
mechanism.
Define measures and orient contractors on prevention of
discrimination in employment relationship, and
harassment.
Guarantee that contractor’s workers are provided with a
grievance mechanism. Take measures to guarantee that
terminal expansion and railway branch are complying
with labor rights and other issues addressed by these
performance standards (freedom of association and
collective bargain, non-discrimination in employment
relationship, harassment, child and forced labor). This
could be done through regular visits to the site, audit
process, etc.
Take measures to orient logistics contractors on
compliance with labor rights
Logistics Project
Most of the logistics operations shall be conducted by third
party contractors. Reportedly, all contracts signed between
ELDORADO and contractors have a clause stating that no
part shall employ slavery like and/or child labor.
Supply Chain
2.10
27
Moderate
Forest Operations and Logistics Project:
Wood Supply: For contract purpose, ELDORADO requests
the suppliers several documents and clearance certification
to identify legal risks associated with the farm and the
wood transaction. Those documents and certificates could,
in thesis, demonstrate any judicial action against the farm
due to child labor or forced labor.
ERM reviewed one contract, which has a clause stating that
91
Establish a systematic to monitor child and forced labour
in primary supply chain. This systematic may include:


Identify categories of significant suppliers in the
primary supply chain in high risk of child labor
and forced labor.
Define measures to monitor significant suppliers
on employment of child labor and forced labor.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
both parts are responsible to avoid employment of child or
forced labor.
The contract is signed 2 to 4 years before the harvesting
operations begin and ELDORADO does not monitor
suppliers during this period. Not monitoring wood
suppliers not FSC certified poses a risk to the company.
Land Supply: ELDORADO’s contract with land supply has
a clause that states that both parts are responsible to avoid
the employment of child or forced labor. The farms Vô
Fiorindo and Buba were leased by the company MMX and
then transferred to ELDORADO. The contract signed by
MMX and the farmers does not contain specific clause
about child and forced labor. No other measure has been
taken to identify and avoid the employment of child and
forced labor by these land suppliers.



For wood suppliers, monitoring measure to be
conducted in between the contract signature and
the harvesting of the wood, especially for those
that are not FSC certified.
For Vô Fiorino Farm and Buba, include the
contractual clause that both parts will not employ
child or forced labour.
For the logistic project, inclusion on suppliers’
contract a clause stating that both parts are
responsible to avoid the employment of child
and forced labor.
PS 3 - Resource Efficiency and Pollution Prevention
General
3.1
4 and 5
Moderate
 Forest Operation
The analysis of environmental impacts related to the forest
management 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). The
issues of the EMS guidelines and procedures are related to:
 The elaboration and application of the PTEAS is still
restricted to few farms.
 It was not observed a systematic and comprehensive
monitoring documentation system.
b) Efficiency of the EMS procedures:
 Waste management: ERM observed issues related to the
implementation of the waste management program –
see PS 3 Paragraph 12.
 Hazardous material management: ERM observed issues
related to the implementation of the waste management
program – see PS 3 Paragraph 13.
92
ELDORADO should apply the PTEAS procedure to all
lands prior to the intervention (planting and harvesting).
For the lands where intervention (plantation) has already
occurred and no PTEAS undertaken, ELDORADO should
conduct the PTEAS considering impacts already caused
by the activity described by this performance standard
(PS3).
ELDORADO should also improve the EMS efficiency
regarding the following programs:
1 – Waste Management Program
2 – Hazardous Material Program
3 – Monitoring and Documentation Program
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
 Water management: ERM did not observed issues
related to the water management program – see PS 3
Paragraph 9.
3.2
7 and 8
Low
Industrial Operations:
The ELDORADO Pulp mill of Três Lagoas/MS does not
have an estimate of carbon dioxide emission equivalents
for the Project. Production has not yet started. Some
measures adopted in the project are aligned with the
reduction of greenhouse gas emissions, such as the use of
renewable energy sources associated with biomass
burning, co-generation of heat and power and chemicals
recovery, among others.
Forestry Operations:
The company did not provide documents relating to
inventory of Greenhouse Gas (GHG) as an energy balance
of the project. The project considers the use of fossil fuel
sources and will result in emission of greenhouse gases.
The site should develop an estimate of greenhouse gas
(GHG) emissions at the project stage, according to
internationally recognized methodology, such as the
Guidelines of the Intergovernmental Panel on Climate
Change (IPCC) or equivalent.
The GHG emissions estimate should be annually
reviewed.
The company should quantify GHG emissions, not only
carbon sequestration, but also emissions, as the first step
in managing and ultimately reducing emissions in a costeffective manner, as required by Performance Standard 3.
Logistics Project:
ELDORADO’s logistics operation is still in the detailing
study stage. ELDORADO has not yet estimated the carbon
dioxide emission equivalents for the project. As informed,
this estimate is currently being developed, in spite of not
being required by the Brazilian regulations.
3.3
9
Low
Logistics Project:
The logistics operations are not associated with high water
consumption. The main water use will be associated with
human consumption. According to information provided
by ELDORADO, no maintenance 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 complying with the drinking water
93
Guarantee that no water contamination occurs inside its
installations in Santos.
Guarantee that third party companies distribute water for
human consumption in Aparecida do Taboado and
Pederneiras are in compliance with the drinking water
standards.
Apply for a water abstraction permit for the well
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
standards established by Brazilian regulations. However,
ELDORADO is responsible 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 were available.
Water quality in Pederneiras will be responsibility of
EGTM – Torque and in Aparecida do Taboado of ALL.
installation in Aparecida do Taboado.
Pollution Prevention
3.4
10
Low
The air quality monitoring campaigns conducted to date
has not included the monitoring of Particulate Matter
PM2.5.
Include Particulate Matter PM2.5 in the next monitoring
campaigns, to assure compliance with international
standards and IFC Guidelines.
3.5
10 and
11
Low
According to the pulp mill project and information
provided to ERM during the site visit, effluents will be
treated in an on-site wastewater treatment system and
discharged into Paraná River via an effluent outfall,
installed upstream of the pulp water intake point.
comprising primary clarification for solids-containing
effluents, neutralization of
The effluent treatment system will consist primary
treatment (solids-containing effluent) and a biological
treatment for effluents joint treatment (activated sludge).
ERM reviewed the process guarantees provided by the
effluent treatment system supplier.
Taking into account the process guarantees, ERM
compared the effluent estimated quality with the IFC EHS
guidelines and the applicable wastewater discharge
standards.
ERM evidenced compliance with the standards.
Similarly, the process guarantees result in the following
specific flow and loads:
ELDORADO to confirm whether they can meet the IFC
standard for phosphorous.
94
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Parameter
Recommended Actions
Specific value
Flow (m³/ADt)

Average

Design
BOD (kg/ADt)
28.9
36.8
TSS (kg/ADt)
1.11
AOX (kg/ADt)
0.14
Total Nitrogen (kg/ADt)
0.18
0.04
Total Phosphorus (kg/Adt)
IFC G
0.59
Although the estimated total phosphorus content is
roughly higher than the IFC specific standard, ERM
understands that ELDORADO can adjust the treatment
process to lower the treated effluent phosphorus
concentration.
3.6
10 and
11
Moderate
Logistics Project:
The São Paulo State Environmental Agency (CETESB)
issued a statewide Contaminated Areas Report that
includes the contaminated Sites in the State of Sao Paulo
that are registered with the Agency. CETESB began
developing this report in May 2002 and it includes only
those sites where companies have voluntarily disclosed
information regarding soil/groundwater contamination. In
general, this report is updated once a year and was last
updated in November, 2010. The report does 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
gives information on the main contaminants and status of
the Sites in terms of investigation/remediation efforts.
The area located out of the organized port of Santos,
operated by Hipercon Terminais, with which ELDORADO
will sign a service provision contract, is not listed in
CETESB’s website as a contaminated area. However, it is
surrounded by bulk liquid terminals, which are listed as
contaminated areas (Stolthaven Santos, Ultragaz,
95
Request Hipercon Terminais to assess soil and groundwater
contamination in its area to establish the baseline
conditions, given that migration of contaminants from
surrounding areas cannot be totally ruled out.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
Tequimar, among others). ERM understands that the
operations with ELDORADO’s finished product (bleached
kraft pulp) at that area will not represent an additional
potential for soil/groundwater contamination in the area.
Additionally, according to information provided by
ELDORADO, Hipercon Terminais operations at the area
are mostly related to receipt and shipment of sugar.
However, regardless of the product handled on behalf of
ELDORADO being a non-contaminating material,
ELDORADO could be deemed co-responsible if a
contamination at the area is detected.
3.7
12
High
(legal non
compliance)
Industrial operations:
As 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 wastes generated
by each contractor working in the construction site,
centralize the temporary storage and give proper
destination.
Each contractor, in its turn, temporarily store generated
hazardous waste in a temporary storage area, until it is
removed by Podium to the central waste management
facility.
During the site visit, ERM sample checked the contractor’s
installations and some deficiencies were noted. At the
installations of Serpal (power boiler civil construction
contractor), the hazardous waste storage area is small
(approximately 4.0 m²), apparently insufficient to
accommodate the wastes generated (oily wastes, spent
solvent, etc.) until the transfer to the central waste facility
by Podium. As a result, reportedly because Podium had
not yet removed the wastes from the generation point, six
drums were observed outside the storage area, directly on
unpaved soil, covered with a plastic sheet (no evidence of
leakage was observed). Additionally, the wastes were not
adequately labeled.
ERM observed a pile (approximately 50 m²) of fiber-cement
96
Inspect the contractors’ installations and make sure that
hazardous wastes are being stored in covered, secondarily
contained and paved areas.
ELDORADO should require the following actions from
Podium:
 Expedite the construction of the hazardous waste
temporary storage area;
 Develop a procedure for handling, storage and
disposal of asbestos-containing wastes that assure not
only environmental compliance with applicable
regulations, but also health and safety regulations;
 Segregate asbestos-containing wastes and give them
appropriate final disposal as hazardous waste;
 Develop a procedure for asbestos-containing wastes
management, including handling, storage and
disposal. The procedure should contain the guidance
for asbestos-waste handling, the required PPE to be
provided to employees and employees training
requirements;
 Appropriately train the employees responsible for
asbestos-containing wastes handling.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
roof tiles on an unpaved area and evidenced that part of
the tiles are asbestos-containing and part asbestos-free
(with synthetic fibers). It is not possible to visually
determine the percentage of each type. Asbestos-containing
construction waste is classified under Brazilian regulations
as hazardous waste and must be disposed of as such.
Podium has not developed a procedure for handling and
disposal of asbestos-containing wastes, that are being
disposed of as non-hazardous waste.
Forest Operations:
 Waste handling: during the site visits, it was observed
that some types of waste were not adequately handled
in the farms. The major issue is related to the aluminum
disposable dishes provided to the workers as part of
their daily meal, which sometimes were disposed in an
improper manner.
 Waste collection: it was reported that, in some cases, the
general waste of the farms was transported to the final
waste disposal site by contractor’s stuff, and therefore,
not following the Waste Management guidelines.
ELDORADO has not provided information on whether
licensed disposal sites are being operated to acceptable
standards or a possible program to reduce waste sent to
such sites or alternative disposal options.
3.7
13
Moderate
Forest Operations:
During the site visits at the farms, it was verified the
following issues related to the handling, storage and final
destination of hazardous materials:
a) Storage of Chemical and Hazard Materials:
The chemical storage facilities (central warehouses) were
implemented in strategic farms in order to facilitate the
distribution 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 chemical
97
Improve the Waste Management Program in order to
accomplish the following goals:
 Verify if the licensed disposal sites are being operated
to acceptable standards.
 Develop a program to reduce waste sent to disposal
sites or alternative disposal options, including the
possibility of developing their own recovery or
disposal facilities at the project site.
 Improve the efficiency of the waste management
procedures in order to avoid the problems identified in
the site visits regarding the waste handling and
collection.
Improve the efficiency of the Hazardous Material
Management in order to:

Provide detailed information on hazardous
materials to be used throughout the different
project stages, such as: volumes; characteristics/
MSDS; handling and storage; and chemicals
storage locations.

Define the amount of asbestos containing
materials, PCBs and ozone depleting substances
used by the operation and establish measures to
reduce the use.

Guarantee that Maintenance area have adequate
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
materials, used products, hazardous and non hazardous
waste. At the same location was observed a wet floor,
probably derived from rain water entering through the
ventilation openings.
 The chemical inventory control system is not efficient.
There are no documents at these places informing the
amount or type of stored products. The inventory
control is basically done by the contractor’s stuff when
the product is being used at the forest plantation sites
 The warehouse has no access restricted to qualified
personnel. Anyone can access and manipulate the
products.
 Even though there is a central warehouse, it was
observed chemical and hazard products stored at
inadequate places in other farms.
 According to evidence on site visit, hazardous products
(paint thinner and oil for example) from maintenance on
cultivation of eucalyptus fields are stored inadequately.
The floor is not paved, there is no secondary
containment or drainage to avoid leakage directly on
soil
b) Transport of Chemical and Hazard Materials from
central warehouses to the forest plantation sites
 The transport of hazardous and chemicals materials is
performed by contractor’s personnel. It was reported
that the contractor’s personnel does not hold the
Emergency Preparedness and Response Plan during the
transportation of these products.
 ERM did not verify the transport operation of these
products
c) Temporarily hazard waste disposal facilities
 The use of adequate storage facilities to store
temporarily used herbicides containers was not
observed. There is no clear definition on how or where
to store these containers. In one farm, misinformation
was provided regarding the location of this facility.
d) Final hazard waste destination
98
hazardous material storage, with secondary
containment or drainage to avoid leakages on
soil and water bodies.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
 Reportedly all hazardous waste are not stored and
immediately collected by the respective contracted
company for final disposal. In one farm, it was verified
that the hazard waste collection never happened, where
it was possible to count more than 200 used containers at
the same place
PS 4 - Community Health, Safety and Security
Community Health and Safety
4.1
5
Low
Industry Project
ELDORADO has identified the main risks to community
health and as defined by law, ELDORADO promotes
awareness programs to workers about alcoholism,
smoking, besides monitoring workers occupational health
through medical examinations.
Forest Project
The increase of transport flow on the inhabited areas was
assessed by ELDORADO and as a mitigate measure the
community is informed about the transportation schedule.
The PTEAS also support the identification of traffic
increase on public roads.
Awareness programs should be applied to employees,
contractors, their families and affected communities.
Develop the transportation plan considering avoiding
impacts on community health and safety, as identified by
PTEAS.
The plan to wood transport is not developed and it shall be
supported by the PTEAS carried out before harvesting.
Logistics Project:
Considering the size of the logistics projects , that no inflow
of workers is planned and that most of the activities will be
performed by contractors that already operate in the area
(waterway, rail way and port), ELDORADO should be in
charge to identify risks and impacts to community health
for the road transportation, the railway branch
(construction and operation at Aparecida do Taboado,
Pederneiras and Santos) and terminal expansion (at
Pederneiras and Santos).
99
Perform a health impact assessment to identify
impact on community and workers health, including
contractors (e.g identification of existing diseases or
new diseases that can be spread because of the inflow
of workers) and, as a result, to define the appropriate
mitigation measure to avoid and minimize the
impacts on health. This include:

Sanitation (Public Health) measures (e.g. once
diseases are identified, asses if the public health
service has the capability to prevent and treat it;
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions


Reportedly, communities impacted by the road
transportation are included on the EIA and the area
impacted by industrial operation.
Prevention of communicable disease;
Program to monitor workers health (contractors
and employees) to prevent STIs, water-borne
disease or other identified through the health
impact assessment.
Verify the process to identify health and safety risk
and impact undertaken by ALL, MRS and CODESP,
checking upon measures that are applicable to
ELDORADO or that could be undertaken jointly, if
applicable
Identify risks and impacts to community health and
safety due to the road construction and operation (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 transmitted
illness STIs and prevention of fatalities and injuries.
Provide workers performing activities at the port of
Santos educational programs related to STIs.
Security Personnel
4.2
12
Low
ELDORADO reported not to monitor security
arrangements, neither provide training to security
personnel, nor there is a systemic procedure to verify if
those providing security are not involved in past abuses.
Ensure the grievance procedure and Stakeholder
Engagement Plan (PS1 Paragraph 25) are designed to
identify any concerns from local government,
communities and workers regarding security activities.
Industry Operations:
Company Meta is in charge to manage the site support
facilities, which include the security personnel
arrangements, provided by Security. Reportedly, Meta is in
charge to verify the documents of those providing security.
Security personnel arrangements is provided at the site and
the 3 accommodations managed by ELDORADO. Those
providing security are in charge to supervise the access to
the site and accommodation.
Define procedures on the correct code of conduct and use
of the force by security personnel. This shall include
measures to investigate and address any complaints
regarding potential human right abuses committed by
those providing security.
Monitor those providing security arrangement to identify
compliance with the above mentioned procedures.

100
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
At most of the farms, there are no security personnel but
workers who perform round to identify fire and plague.
Security personnel are provided at the accommodation by a
third part company named Apolo Segurança Privada, hired
by Foco. Foco provided evidence of Apolo certificate to
operate, issued by the federal police, and the certificate that
authorizes one worker to provide security issued by a
certificated school. At the farm Correntes there are security
personnel hired by the previous owner of the land (the
company MMX). ERM interviewed the security working
and documentation was according to Brazilian legislation.
Logistics Project:
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 in charge of
the area inside the organized Port called Terminal Elmar
and 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 provide
training to security personnel, neither there is a systemic
procedure to verify if those providing security are not
involved in past abuses.
PS 5 - Land Acquisition and Involuntary Resettlement
Displacement
Economic Displacement
5.1
25 to 29
Moderate
Forest Operations:
The PTEAS – Economic, Environmental and Social
Technical Project (Projeto Técnico Econômico, Ambiental e
Social) includes the identification of use of roads by
neighbors, access to water resources, closeness to
neighbors, schools, churches, households, etc., which could
identify economic displacement. As reported above, this
procedure is dated December 2011 and it was not
101
Carry out the PTEAS in all farms before intervention is
made. For areas in which intervention was made before
and PTEAS was not carried on, ELDORADO must define
measures to identify economic displacement.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
performed in farms in which planting was carried out
before this date.
ELDORADO has performed PTEAS for only 2 farms (Barra
Mansa and Laranjal).
Reportedly, no economic displacement has been carried out
by ELDORADO.
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resource
General
6.2
6 and 7
Moderate
Industry Operation
According to the EIA, the studies conducted during the
previous license showed only the initial situation of the
area of influence and allow only a general prediction of the
impacts on biodiversity (related to the change in the land
use, increase in the nuisance to native species and
restrictions to resources usage). The reports of the
monitoring programs (PBA) allow comparisons of data, yet
still are not related to ecosystems services.
Licensing process does not require and does not include
identification and analysis of impacts on eco-system
services. Therefore there is no information regarding this
issue in the documentation presented.
ELDORADO has performed several studies that addresses
impacts on biodiversity, such as:
 General environmental aspects and impacts assessment
- Environmental Impacts (Impactos Ambientais).
 Forest Management Plan that includes monitoring
activities in order to check if the impacts are being
mitigated and minimized.
 Two studies performed by “Casa da Floresta” to identify
the areas with high conservation value inside its
properties. These studies are: “Selection of areas of high
102
Evaluate potentially impacts on ecosystem services
through the existing studies (Industrial and Forest
operations) and the data obtained in the implementation
of the environmental programs.
ELDORADO should guarantee that the studies to be
developed in High Conservation Value Areas include
quantitative and representative sampling of animal and
vegetation communities, and make integrated assessment
of all components of the biota (analyzing the
communities) to then integrate the physical and biotic
aspects. This study should also evaluate impacts due to
change of use and isolation of the remaining naturals
inside the cultivation of eucalyptus; and the restriction of
movement of animals from the Cerrado biome to the
forest plantation.
The risks and impacts identification studies should
include the scoping for ecosystems services, at least in a
qualitative way.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
conservation value and planning of environmental
monitoring”, which identifies and classifies areas of
High Conservation 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 sociocultural importance and / or essential social functions in
the regions of work development of the Eldorado Brazil,
Mato Grosso do Sul”.
 A third study is being carried out aiming to perform a
biodiversity inventory in the areas identified as high
conservation value and perform fauna and flora
monitoring.
 PTEAS – Economic, Environmental and Social Technical
Project (Projeto Técnico Econômico, Ambiental e Social)
is an internal procedure that evaluates the economic,
environmental and social aspects of the land before
major interferences (cultivation or harvesting).
The available environmental studies do not include
quantitative and representative sampling of animal and
vegetation communities, neither make integrated
assessment of all components of the biota (analyzing the
communities) to then integrate the physical and biotic
aspects. Also, it was not reported impacts due to change of
use and isolation of the remaining naturals inside the
cultivation of eucalyptus; and the restriction of movement
of animals from the Cerrado biome to the forest plantation.
The existing studies do not use concepts of ecosystems
services.
Logistics Project:
The Simplified Environmental Report – RAS for the
multimodal terminal in Aparecida do Taboado-MS
contains an environmental and social impact assessment.
However, it did not assessed impacts and risks to
biodiversity and ecosystems.
103
With regards to Aparecida do Taboado, ELDORADO
should:

Identify direct and indirect project-related impacts on
biodiversity and ecosystem services and identify any
significant residual impacts.
PS
Para
Ref.
No’s.
Protection and Conservation of Biodiversity
Gap
Ref
No.
Recommended Actions
6.4
11 and
12
Low
Industry Operation
The EIA presents quantitative data on fauna and flora.
The EIA evaluated the impacts on flora and fauna
(vegetation removal), as minor, and did not evaluate
impacts on biodiversity, considering that the project is
located in an area previously modified. It also presents
mitigation and management actions.
PBA presents monitoring programs in order to minimize
the impacts and risks identified.
6.5
13, 14
and 15
Low
Forest Operation
According to site visit and information provided by
ELDORADO, legally protected areas (Permanent
preservation areas and Legal Reserves) as well as endemic
or endangered species are maintained and preserved inside
the visited properties.
The land use management guidelines (PS6 paragraphs 6
and 7) are being also applied to leased lands, partnership
agreements and wood suppliers to guarantee that natural
habits are not being converted to forest plantation in thirdparty farms. This requirement is imposed by contract.
Evaluate potentially impacts on biodiversity through the
existing studies (Industrial and Forest operations) and the
data obtained in the implementation of the environmental
programs.
There are three main actions that ELDORADO could take
in order to improve the management of natural resources:
1 – Try, when possible, to connect the Legal Reserves with
Protected Permanent Areas (PPAs) in order to enhance the
ecological function of these areas, provide habitat
corridors and promote the conservation of rare,
threatened or endangered species.
2 – Implement a Native Forest Management System in
isolated Legal Reserves in order to enhance their
ecological function when other alternatives are not
possible (e.g. connection with PPAs)
ERM observed that some of the legal reserve areas are
isolated and surrounded by forest plantation or are not
connected with permanent protected areas (PPA) around
the riparian zones. This isolation may interfere with the
ecological function of these areas. However, this land
configuration was mostly inherited from previous
ownership.
104
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
6.6
16 to 19
Moderate
Forest Operation
ELDORADO presented two studies performed by “Casa da
Floresta” on January of 2012 to identify the areas with high
conservation value inside its properties. These studies are:
 “Selection of areas of high conservation value and
planning of environmental monitoring”. This study
identifies and classifies areas of High 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-cultural importance and / or essential social
functions in the regions of work development of the
Eldorado Brazil, Mato Grosso do Sul”.
A third study is being carried out aiming to perform a
biodiversity inventory in the areas identified as high
conservation value and perform fauna and flora
monitoring.
After the conclusion of the third study ELDORADO
should consolidate the improvement actions to be
performed in these areas in a Biodiversity Action Plan, in
order to guarantee net gains of biodiversity values.
6.7
20
Low
Forest Operation
A 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 done by the Environmental
Agency. It means that there is not yet any instruction or
regulation on what type of use is allowed inside the EPA.
Therefore, due to the small overlay between these areas
and the lack of proper zoning, it does not configure a land
use conflict.
ELDORADO is not actively managing the lands to bring
the PPA and the Legal reserve back into their natural state,
based on a report that concludes that in Cerrado biome is
better to leave them for natural reforestation.
105
ELDORADO must follow the development of zoning
regulation related to the Piraputanga Park Road, which
may affect how the land is used in two of their properties
Natural regeneration of the bioma Cerrado can occur once
there is a near sources of propagules (other Cerrado areas
surrounding) and since the operator favors the natural
regeneration. It should ensure disturbing factors (eg fire,
opening trails, movement of domesticated animals like
cattle and horses) are minimized or eliminated.
ELDORADO should monitor if natural regeneration
occurs, and prepare a recovery plan, if necessary.
PS
Risk Group
Para
Ref.
No’s.
PS 7 - Indigenous Peoples
Gap
Ref
No.
7.1
8
Low
Description
Recommended Actions
Industrial and Forest Forest Operation
An archeological survey has been conducted in December
2011, and identified that there was no indigenous groups or
traditional people affected by ELDORADO’s industrial
operation. The study was undertaken on 7 municipalities
were ELDORADO operates: Tres Lagoas, Selvíria,
Aparecida do Taboado, Inocencia, Agua Clara, Santa Rita
do Pardo, Ribas do Rio Pardo. As a result, no indigenous
groups were identified on ELDORADO land and the
closest one is 96 km from the pulp plant.
A social territory study was undertaken for the two
municipalities, Anastacio and Dois Irmaos do Buruti, were
ELDORADO possess lands. The study was undertaken by
the previous land owner and identified 7 indigenous
communities in the region. .
According to ELDORADO, there are no indigenous or
traditional people at ELDORADO’s land and the closest
indigenous land is 22 km from Jatiúca Farm.
ELDORADO reported that impact on indigenous and
traditional people will be identified through PTEAS that
will be carried out before harvesting (between June to
December 2012).
ERM visited farms in Anastacio and Dois Irmãos de Buriti
and interviewed workers. None were identified as
indigenous workers.
Identify the influence of the operation at Dois Irmãos do
Buruti and Anastacio municipalities over indigenous or
traditional peoples through the PTEAS.
In case impact on indigenous or traditional people is
identified, ELDORADO must develop an Action Plan to
minimize, restore, and/or compensate for these impacts in
a culturally appropriate manner commensurate with the
nature and scale of such impacts and the vulnerability of
the Affected Communities of Indigenous Peoples, in
compliance with this performance standard and the
Include impacted indigenous people’s representatives, if
applicable, on the Stakeholder Development Plan
described in PS1, paragraph 27, 28.
PS 8 - Cultural Heritage
Protection of Cultural Heritage in Project Design and Execution
8.1
6 and 7
Moderate
Industry Operations:
Archeological survey has been conducted in December
2011. The study has revealed a set of 10 archaeological sites
and related chipped lithic remains. This study has been
submitted to the Institute for National Historical and
Artistic Heritage (IPHAN – Instituto do Patrimônio Histórico
106
Recommendations provided in the archaeological study
should be implemented by ELDORADO.
Guarantee that the Stakeholder Engagement Plan includes
consultation in relation to cultural heritage.
Gap
Ref
No.
PS
Para
Ref.
No’s.
Risk Group
Description
Recommended Actions
e Artístico Nacional) and waits for the issuance of technical
opinion, however it does not involve consultations with
affected communities and therefore does not incorporate in
its decision-making process the considerations of these
affected communities.
The Inventory of Areas of High Conservation Value
consulted the community nearby the farms to identify
common use of the biodiversity areas. This inventory
identified that there are no areas of common use or
essential to the community on ELDORADO’s farms.
However, this study did not include the areas at Dois
Irmãos do Buruti and Anastácio municipalities.
For the disclosure, it was reported that a public hearing
will be carried out for the purpose of forest certification.
Logistics Project:
No evidence has been provided regarding protection of
cultural heritage.
107
Identify important areas of common use or essential to the
community on ELDORADO’s farms located at Dois
Irmãos do Buruti and Anastácio municipalities.
Conduct the public hearing as planned.
If archaeological and cultural remains are found during
construction, the works must be stopped and an expert in
the field should be called for inspection. It requires
training of workers so they can identify these remains
during construction. This is valid for Aparecida do
Taboado and Pederneiras Terminal.
ELDORADO should identify and protect cultural heritage
by ensuring that internationally recognized practices 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 of importance, and to incorporate into
the client’s decision-making process the views of the
Affected Communities on such cultural heritage. This is
valid for Aparecida do Taboado and Pederneiras
Terminal.
As for the Port Terminal in Santos, studies should have
already been performed by IPHAN since the areas is
already occupied for a long period of time. It is
recommended to check this information with the institute.
6
FINAL OBSERVATIONS AND RECOMMENDATION
ERM Brazil Ltda. (ERM) was commissioned by ELDORADO BRASIL
(ELDORADO) to act as Independent Environmental Consultant and to
conduct an independent Social and Environmental Assessment of its pulp and
paper plant project which is currently under construction. The project is being
developed in Três Lagoas State of Mato Grosso do Sul/Brazil and includes
logistics operations for the transportation of pulp produced in the industrial
complex, to the port of Santos in the State of São Paulo. The objective of the
Assessment was to provide technical information for the financing process
with FINNVERA, EKN and OeKB.
The Area of Influence of the Project represents the geographical area
considered to be affected or potentially affected by the Project’s activities. This
includes facilities that are directly owned, operated or managed (including by
sub-contractors), and including those areas of unplanned but predictable and
indirect impacts on biodiversity or on ecosystem services (the benefits people
obtain from ecosystems) upon which affected communities’ livelihoods are
dependent. In addition facilities associated with or influenced by
ELDORADO’s existing facilities, which would not have been constructed or
expanded without these facilities, and any third party activities (including
supply chains) where ELDORADO has significant control and influence over
the third party are also contained within the Area of Influence of the Project.
This report presents the findings of the independent analysis which has been
carried out with reference to the Equator Principles; the financial industry
benchmark for identifying, assessing and managing social and environmental
risk in project financing.
Besides the gaps and findings identified and shown in Annex C, D and E for
the industrial plant, forest operations and logistics project, respectively, ERM
has identified some issues as part of the external factor review and during the
visits that also poses risk to ELDORADO and potential lenders. These issues
are described below:
 According to secondary data review, one of the ELDORADO’S partners,
Mário Celso Lopes (from MJ Empreendimentos) has a rubber tree
plantation in which the Ministry of Labor identified 23 workers in slave
like conditions in June 2010. This farm (Fazenda Santa Izabel) is located at
Mato 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 was
analyzed by the Federal Justice. According to a report provided by the law
company in charge of his defense, document named Detailed Report of
Process (Relatório Detalhado de Processo, dated September 22nd 2011 and
November 30th, 2011), payments to the workers were made according to
the agreement with the Labor Ministry and the case has been considered
concluded. As a result, Mário Lopes and the farm will not be added to the
108
Labor Ministry’s Black List. Companies listed are not allowed to participate
on bidding and to receive public funds;
 During ERM visit, it was observed a settlement of the Landless Movement
had invaded the right side of way of the federal road, neighboring the
farms Correntes I and II. There are around 10 houses in the area and,
according to the farm security personnel, they never invaded the farms. To
avoid conflict with the Landless movement, it is recommended to include
the families in the engagement process and provide adequate training for
the security personnel; and
 The secondary data review indicated that ALL has been accused by the
Public Ministry for employing 51 migrant workers in slave-like conditions
at São Paulo State, for which is being charged R$100 million. The workers
were recruited by a third party company for the expansion of the railway,
but the Public Ministry understands that ALL was responsible for the poor
working conditions because of their deficient contractors management
practices and because the degrading work was performed on the ALL’s
site, which was directly supervised by the company’s representative.
(source: http://www.reporterbrasil.org.br/exibe.php?id=2012). This poses
a reputational risk to ELDORADO in case the same practices are repeated
at the construction of the internal railway branch. Reportedly, the contract
signed between ELDORADO and ALL includes a clause that both parts
shall not employ slave or child labor.
In addition and as explained previously, ERM did not perform site visits to all
farms where ELDORADO has or will have plantations activities, due to
schedule and budget reasons. ERM considers that the sampling performed
was adequate for an overall assessment of the Environmental and Social
Management System, however, recognizes that with this strategy it was not
possible to identify specific conditions in the areas not visited. In order to
mitigate this matter, ERM recommends ELDORADO to prioritize an
environmental and social assessment of the areas not visit and include the
specific 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 the
E&S impact of the existing and future activities and facilities to ensure
ongoing compliance with national and IFC requirements during construction
and operation. The ESMP shall provide associated mitigation measures and
monitoring measures for both construction and operation phases.
As part of the ESMP the following measures described on Table 5.2 should be
taken as priority. A preliminary Environmental and Social (E&S) Action Plan
with the priority measures will be prepared by ELDORADO and submitted to
the Financial Institutions.
109
Moreover, ELDORADO must prepare and provide an annual report on the
implementation progression of the E&S Action Plan and establish a third
party review process during remaining construction phase.
110
Annex A
List of Documents Reviewed
and Persons Interviewed
Material Disponibilizado pela Eldorado à ERM
TIPO
TÍTULO
AUTOR
Mapa - PDF
Pöyry Tecnologia Ltda.
19/07/2011
PDF
Word - PDF
ART - PDF
Tratamento de Efluentes - Estação de Tratamento de Efluentes - Lay Out geral
ETE
Cais de Atracação - Alteração de localização e metodologia construtiva
Cais de Atracação - LP nº135 - Processo 23/108.071/2009
ART - Anotação de Responsabilidade Técnica - Marcos Aparecido Franco Portela
08/11/2011
22/11/2011
08/08/2011
Formulário - PDF
Sistema de Reserva Legal - SISREL MS. Formulário de Requerimento
PDF
Caderno de SSMA (Contratadas e Subcontratadas)
Word - PDF
Alterações (Comissionamento e descrição das atividades)- Condicionante 07- LI
17/2011 - Processo 23/101741/2010
Acompanhamento de atividades
Planilha de monitoramento e medição de fumaça preta e vazamentos
Estudo de dispersão atmosférica
Planilha de controle operacional
Planilha de controle operacional
Relatório do Monitoramento da Estação de Tratamento de Água Provisória
Certificação de Qualificação de Supervisor de Radioproteção
Eldorado Celulose e Papel S.A. - José Antonio Chiareli Caveanha
Conselho Regional de Engenharia, Arquitetura e Agronomia do Estado de
São Paulo
Secretaria de Estado de Meio Ambiente, Cidades, Planejamento, Ciências e
Tecnologia
Diretoria Técnica e Industrial / Gerência Administrativa - Eldorado
Celulose e Papel S.A.
Mayza Carla da Silva Devens - Eldorado Celulose e Papel S.A.
Word
Excel
PDF
PDF
PDF
Word - PDF
Word - PDF
Certificado - PDF
Word - PDF
Mapa - PDF
Autorização ambiental
- PDF
Licença de Instalação PDF
Licença Prévia - PDF
Não possui
Montcalm
Storm & Smoke
Sanágua, Meta, Eldorado Brasil
Sanágua, Meta, Eldorado Brasil
Comissão Nacional de Energia Nuclear - Maria Helena Da Hora Marechal
DATA
26/02/2010
30/11/2010
17/10/2011
SEMAC e IMASUL - Carlos Alberto N. Said Menezes
26/03/2010
22/07/2010
27/10/2010
04/04/2011
04/04/2011
04/11/2010
22/07/2010
1
2
n
04/11/2010
04/11/2010
13/04/2011
n
n
Márcia Moura, prefeita de Três Lagoas e José Antonio Chiareli Caveanha,
procurador da Eldorado Celulose
01/05/2010
Eldorado Celulose e Papel S.A. - Edna Martha Martins Pereira
Marinha do Brasil - Luis Fernando Baptistella
07/10/2011
18/08/2011
19/09/2011
13/07/2011
12/08/2011
Marinha do Brasil - Luis Fernando Baptistella
12/08/2011
Marinha do Brasil - 3º SG MR Edson Cesar
08/12/2011
Auditor fiscal do trabalho -Péricles Brandão Filho
Paranasa
Ministério do trabalho e emprego. Delegacia Regional do Trabalho DRT/MS - Vanderci Braga Gonçalves
Diretoria Técnica / Gerência Administrativa & SSMA
07/07/2011
01/03/2011
22/03/2011
01/09/2011
19/09/2011
07/07/2010
04/08/2011
29/08/2011
Word - PDF
ART - Anotação de Responsabilidade Técnica - Wagner Alexandre Folli
DMP -Imagem de
mapa
JPEG - Imagem de
mapa
DWG -Imagem de
mapa
BAK -Imagem de
mapa
DWG -Imagem de
mapa
BAK -Imagem de
mapa
JPEG - Imagem de
mapa
JPEG - Imagem de
mapa
BAK -Imagens
Acadstk (Imagem de mapa de Três Lagoas)
Três Lagoas (Imagem de mapa de Três Lagoas)
Não possui
Não possui
Empreendimento (Imagem de mapa de Três Lagoas)
Não possui
2011
Empreendimento (Imagem de mapa de Três Lagoas)
Não possui
2011
Área de influência indireta (Imagem de mapa de Três Lagoas)
Não possui
Não possui
Área de influência indireta (Imagem de mapa de Três Lagoas)
Não possui
Não possui
3L (Imagem de mapa de Três Lagoas)
Não possui
Não possui
3 Lagoas
Não possui
Não possui
Empreendimento 2011 ventos (Imagem de mapa de Três Lagoas e Predominância Não possui
do ventos)
Ventos
Não possui
Empreendimento_2011_Uso_do_Solo_agricola
Não possui
2011
Laudo de constatação e Auto de infração
Auto de infração 2º 02119
Licença de operação - Fertibom Industrias Ltda.
Ofício nº 1046/2011 - Outorga de direito de uso dos recursos hídricos.
ART - Anotação de Responsabilidade Técnica - Eduardo de Moura Nogueira
2011
29/08/2011
2011
29/08/2011
Não possui
Não possui
2011
Empreendimento_2011_Uso_do_Solo_agricola
Não possui
2011
Mapa solos 2
Não possui
Não possui
EAP - Estudo ambiental preliminar (etapa) e estudo de análise de risco (era) ampliação da ilha química com instalação da planta de clorato de sódio
W F Ambiental
ago/11
Word
Programa de Proteção ao Meio Ambiente - Plano de Auto Monitoramento
ago/11
Word - PDF
Word - PDF
Requerimento Padrão -LI - Protocolo ampliação p c
Eldorado Brasil Alojamento Am 8943 8944 8945 8946 - Boletim De Análises
Laboratoriais
Eldorado Brasil Site 11419 11420 11421 11422 - Boletim De Análises Laboratoriais
Eldorado Celulose S.A.
Planta de Clorato de Sódio
SEMAC e IMASUL
Sanágua - Fabiano Viana Storti
31/08/2011
18/11/2011
28/12/2011
31/10/2011
18/11/2011
29/11/2011
Edna Martha Martins Pereira - Eldorado Celulose
Guará Ambiental - Alessandra Dourado Caliente Quinto
Não possui
Eldorado Celulose e Papel S.A. - José Antonio C. Caveanha
28/09/2011
29/09/2011
Não possui
jan/11
jul/11
30/11/2011
19/12/2011
18/02/2011
Word - PDF
Eldorado Brasil Site De Obras Am 9417 9418 9419 9420 - Boletim De Análises
Laboratoriais
Laboratoriais
Laboratoriais
Requerimento Padrão - Recuperação de áreas degradadas
Projeto Técnico para a Recuperação de área Degradada
405_PRADE_-_Projeto_Para_Recuperacao_Area_Degradada -mapa
Projeto Eldorado - 1º Relatório PBA
Projeto Eldorado - 2º Relatório PBA
Condicionante 06- LI 17/2011 - Processo 23/101741/2010- Relatório do
Monitoramento da Qualidade do ar
Condicionante 06- LI 17/2011 - Processo 23/101741/2010- Relatório do
Monitoramento das águas superficiais
1º Relatório do PBA - processo IMASUL 23/101741/2010 - Licença de Instalação
nº 54/2010 - fabricação de celulose branqueada de eucalipto - Projeto Eldorado
2º Relatório do PBA - processo IMASUL 23/101741/2010 - Licença de Instalação
nº 17/2011 - fabricação de celulose branqueada de eucalipto - Projeto Eldorado
n
n
1
2
n
n
n
ART - Anotação de Responsabilidade Técnica - Thiago Ranier Gomes
Word - PDF
n
Licença de Instalação - Fabricação de celulose branqueada de eucalipto
Word - PDF
Word - PDF
n
n
n
ART - Anotação de Responsabilidade Técnica - Larissa Nantes Pereira
Word - Imagem
PDF
Mapa - PDF
PDF
PDF
Word - PDF
n
jul/11
Não possui
16/06/2011
Word - PDF
Word - PDF
n
Não possui
IMASUL
Eldorado Brasil - Dr. Ricardo Ferreiro da Silva
CETESB
Agência Nacional de Águas - Vicente Andreu.
São Paulo
São Paulo
São Paulo
São Paulo
Não possui
Word - PDF
n
n
n
n
1
2
1
2
Paralisações -Projeto Eldorado - 2011
Word - PDF
n
n
Não possui
ago-nov /2011
ago/11
out/11
out/11
02/01/2012
03/01/2012
05/08/2009
Apresentação em
Power Point - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
n
Inventário das fontes radioativas
Fábrica de celulose - área do processo - arranjo geral
Autorização ambiental para exploração vegetal
Licença de Instalação - Linha de transmissão de energia elétrica acima de 7,94 KV
até 230 KV
Licença de Instalação - Linha de transmissão de energia elétrica acima de 7,94 KV
até 230 KV
Licença Prévia - Canteiro de Obras
Licença Prévia - Canteiro de Obras
Licença Prévia - Cais de atração
Licença Prévia - Linha de transmissão de energia elétrica acima de 7,94 KV até
230 KV
Licença Prévia - PDF Licença Prévia - Posto de abastecimento - PA
Licença Prévia - PDF Licença Prévia -Ferrovias
Licença de Operação - Licença Operação -Canteiro de Obras
PDF
Word - PDF
Contrato de Cessão onerosa de direito real de uso de imóvel municipal que entre
si celebram o município de Três Lagoas e a empresa Eldorado Celulose e Papel
Ltda.
Word - PDF
Requerimento padrão - LO - Canteiro de Obras
Word - PDF
Requerimento padrão - LO - Canteiro de Obras
Word - PDF
Requerimento de autorização para perfuração de poço tubular profundo
Word - PDF
Formulário técnico para registro de poço tubular profundo
Autorização Marinha - Requerimento de obras - Sistema de abastecimento de água
PDF
Autorização Marinha - Requerimento de obras - Sistema de lançamento de efluente industrial tratado
PDF
Recibo - GRU
Autorização para regularização de um terminal hidroviário na margem direita do
Cobrança - PDF
córrego bebedouro
PDF
Termo de Registro de inspeção
PDF
Livro da inspeção do trabalho
PDF
Notificação para apresentação de documentos
JPEG - Imagem
BAK -Imagem de
mapa
DWG -Imagem de
mapa
JPEG - Imagem de
mapa
Word
VS
1
2
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
n
1
2
3
4
1
2
n
n
n
n
1
2
n
n
n
n
1
2
3
4
5
n
n
n
n
n
n
n
n
Eldorado Celulose e Papel S.A. -Edna Martha Martins Pereira
18/08/2011
n
TIPO
TÍTULO
AUTOR
DATA
PDF
Relatório Técnico da 2ª Campanha de Monitoramento Ambiental de Solo e Águas
Subterrâneas Projeto Eldorado - Três Lagoas/MS
Monitoramento da Qualidade das Águas Superficiais. Relatório
086000054MAS2011-06
Análise da Qualidade do Ar na Região de Três Lagoas em Três Pontos Pré
Definidos 21.09.2011 a 24.09.2011
Processo Executivo do Sistema de Controle Ambiental
Projeto Eldorado - Tpe-051 - Transformadores de Potência Imersos em Óleo
SE138 KV ELDORADO- Transformador de potencia 138 kV (+12x1%-16X1%) 34,5 kV - 90/110 MVA (ONAN/ONAF)SE138 KV ELDORADO- Transformador
de potencia 13,8 - 36,2±2x2,5 kV - 115/140 MVA (ONAN/ONAF)
W F Ambiental
set/11
Word
PDF
Internet - E-mail
Word - PDF
Word - PDF
Word - PDF
Excel - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Word - PDF
Projeto Eldorado – Três Lagoas Ata De Reunião
Características do óleo mineral isolante tipo A
Proposta Técnica Eldorado
Licença sanitária 2º 2669/11
Licença sanitária 2º 2668/11
Solicitação visita alojamento serviria
Dados Estatísticos de Acidentes do Trabalho e Meio Ambiente
1ª Reunião de SSMA 2012
Eldorado Celulose e Papel S.A.
WEG Transmissão & Distribuição
Fernando Hebling - WEG Transmissão & Distribuição
Departamento de vigilância sanitária
Departamento de vigilância sanitária
Meta central de serviços -Mariana Deroide Marcolino
DuPont e Eldorado Celulose e Papel
2ª Reunião de SSMA 2012
Caderno de SSMA (Contratadas e Subcontratadas)
Apresentação em
Power Point - PDF
Excel - PDF
Excel - PDF
Excel - PDF
Excel - PDF
Vídeo - Windows
Media
Word - PDF
Word - JPEG
COMSECON
19/01/2012
IPA - Índice De Práticas Ambientais
IPS - Índice De Práticas Seguras
Quadro informativo Dezembro NOV - (Planilha de incidentes e acidentes)
Quadro informativo Janeiro NOV - (Planilha de incidentes e acidentes)
Teste.Velocidade
Prof. Ian Johston - University Accident Researche Centre
Não possui
Não possui
Não possui
Não possui
Não possui
n
n
n
n
Acordo Coletivo de Trabalho 2011/2013
Tribunal Regional do Trabalho da 24ª Região
Antonio Luiz de Oliveira
Desembargador Federal do Trabalho, Francisco das Chagas Lima Filho
01/04/2011
Não possui
n
Word - JPEG
Não possui
Word - JPEG
Não possui
Word - 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 Dantas
01/05/2011
Sindicato dos Trabalhadores nas Indústrias de Papel, Celulose e Eldorado
Celulose e Papel S.A. - Almir Morgão e Rogério D’Alcantara Queiroz Peres
01/08/2011
PDF
PDF
WinZip
Word - PDF
Excel
Word - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Banner - PDF
Word - PDF
Word - PDF
Word - PDF
Anantecn - Análise Tecnológica Ltda - Edgar Sandim de Macedo
Storm & Smoke – Consultoria Ambiental e Prestadora de Serviços
Pöyry Tecnologia Ltda
WEG Transmissão & Distribuição
Não possui
Outubro de 2011
set/11
18.01.2010
15/02/2011
Não possui
14/07/21010
Não possui
09/06/2011
04/08/2011
19/09/2011
03/01/2012
2011
04/01/2012
11/01/2012
2011
1
2
3
Florestal Brasil e Carvoaria Ananmoma
Não possui
02/12/2010
30/06/2011
01/07/2010
Não possui
19/01/2012
28/02/2011
n
n
n
n
Sem título - (transporte dos colaboradores da sua cidade de origem para Três
Lagoas)
Gestão de Competências Essenciais dez11
Gestão de Competências Essenciais_meses_anteriores
Floresta Plantada BRACELPA
23/01/2012
Não possui
Não possui
Associação Brasileira de Celulose e Papel
dez/11
nov/11
Não possui
Projeto Eldorado Fábrica de celulose
17/01/2012
P. C. M. S. O. – Programa de Controle Médico de Saúde Ocupacional - Água
Clara
P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Pontal do
Araguaia
P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Santa Rita
do Pardo
P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Selviria
Médico do Trabalho - Dr. Ronaldo Bacci
21/10/2010
21/10/2010
21/10/2010
21/10/2010
P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional - Três
Lagoas
P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Água Clara
21/10/2010
Florestal Brasil
20/10/2010
P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional
Araguaia
Pardo
- Pontal do
Florestal Brasil
20/10/2010
- Santa Rita do
Florestal Brasil
20/10/2010
- Selviria
- Três Lagoas
Florestal Brasil
Florestal Brasil
20/10/2010
20/10/2010
Florestal Brasil
04/10/2010
Florestal Brasil
Secretaria Municipal de Saúde de Andradina - Grupo técnico de vigilância
sanitária municipal
Florestal Brasil
Florestal - Fornecedor de Madeira
Florestal - Fornecedor de Madeira
Eldorado
Florestal Brasil
Florestal Brasil
Florestal Brasil
01/10/2010
23/03/2011
Excel
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Word
Word
Word
Word
Word
Word
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
n
Ouvidoria - Projeto Eldorado
Contrato Particular de compromisso de compra e venda de madeira em pé e
outras avenças, que entre si celebram a Carvoaria Ananmoma e Florestal
Contrato de Arrendamento Agrícola
Convenção Coletiva De Trabalho 2010/2012
Outlook - Mensagem
de e-mail
Excel - PDF
Excel - PDF
Vídeo - Windows
Media
Apresentação em
Power Point - PDF
Word
Word
Word - PDF
n
Não possui
Não possui
Word
n
Word
Word
n
Treinamento de Integração
Procedimento de Controle de Acessos (Portarias)
Word
n
Não possui
out/11
Não possui
Não possui
27/05/2011
19/01/2012
Não possui
28/02/2011
Word
n
n
n
n
n
n
n
Sindicato dos Trabalhadores nas Indústrias Const. Est. Pav. o Ter.
Florestal Brasil e Eldorado Celulose e Papel S.A.
Registradora Substituta - Comarca de Água Clara
Não possui
Word
n
n
Integração de Novos Colaboradores - Florestal
Lista de presença - Treinamento para os representantes da CIPATR
Matriz De Treinamentos Legais - Operações Florestais
Matriz De Treinamentos Legais - D. industrial e Administrativa
Certidão - Registro de imóveis
Nº de empregados
Procedimento Operacional - Treinamento e Capacitação
Políticas de Remuneração e Benefícios
Word
n
n
Matriz De Treinamentos Legais - Operações Florestais
Empregados Próprios - Florestal
Políticas de Remuneração e Benefícios
Word
n
n
Excel - PDF
Excel - PDF
Apresentação em
Power Point - PDF
Word - PDF
Excel - PDF
Excel - PDF
Word - PDF
Excel - PDF
Word - PDF
Apresentação em
Power Point - PDF
Word - PDF
Word
n
n
Florestal Brasil e Tipto e Indústria e Comércio de Calçados Ltda
Federacao dos Trabalhadores na Agricultura do Est MS e Federação da
Agricultura e Pecuaria do Estado de Mato Grosso do Sul-Famasul
Não possui
Word
VS
P. C. M. S. O. - Programa de Controle Médico de Saúde Ocupacional Andradina
P.P.R.A.- Programa de Controle Médico de Saúde Ocupacional - Andradina
Licença de funcionamento
Ficha de Registro de Demandas Sociais
Livro de Inspeção do Ministério do Trabalho
Livro de Inspeção do Ministério do Trabalho. Fazenda Boa Água
Livro de Inspeção do Ministério do Trabalho. Fazenda Mutum
Procedimento para Utilização do Alojamento
PC-MAC-003(00) - Projeto Técnico Ambiental e Social (PTEAS)
Lista de partes interessadas: Mailing Três Lagoas
Lista de partes interessadas: Lista de Contato Três Lagoas
Lista de partes interessadas: Fazendas Vizinhas
Lista de partes interessadas: Indústrias locais
Lista de partes interessadas: Lista de autoridades
Lista de partes interessadas: Lista de autoridades do MS
Contrato de compra de madeira em pé para entrega futura nº 000004
Contrato de Arrendamento Agrícola (modelo)
Contrato de Fornecimento de Madeira para entrega futura (modelo)
Cópia dos documento de 2 trabalhadores da empresa Plantar
Cópia dos documento de 2 trabalhadores da empresa JS Florestal, certificados de
saúde e segurança ocupacional, registro de entrega de EPIs e treinamentos.
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
Não possui
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TIPO
TÍTULO
Documentos Físicos
Florestal Brasil
Documentação de 2 trabalhadores rurais da Eldorado: Ficha de registro do
empregado; Contrato de Trabalho; recibo de entrega e devolução de Carteira de
Trabalho e Previdência Social para anotações; Autorização de 20% de desconto
para alimentação; Autorização para desconto em holerite da contribuição sindical
assistencial; Acordo para compensação de horas de trabalho; Acordo para
prorrogação de horas trabalho; Acordo de prorrogação de horas extras; ASO.
Não possui
Jornal da Obra
Mapa ilustrando terras operadas pela Eldorado e terras indígenas
Florestal Brasil
jul/11
Não possui
n
Bem-Vindo ao Treinamento de Integração
Estudo de Análise de Riscos Junho 2011
Alvará nº 1.438, de 26 de março 2008. Emitido pela Polícia Federal para a Apolo
Segurança privada LTDA
Alvará provisório emitido pela Prefeitura Municipal de Água Clara, MS para
Foco Hotelaria e Assessoria
Relatório Mensal- Repúblicas Novembro 2011.
Apolo Segurança privada LTDA
Não possui
jun/11
26/03/2008
n
n
Foco Hotelaria e Assessoria
20/01/2012
Meta
nov/11
Relatório Mensal- Repúblicas Dezembro 2011.
Meta
dez/11
Relatório de Vistoria de Retorno nº 1. Empresa Imetame
Meta
10/01/2012
Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua Silveira Silva.
Meta
15/12/2011
Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua 13 de Junho.
Meta
26/10/2011
Relatório de Vistoria de retorno nº 1. Empresa Paranasa. Rua Silveira Silva.
Meta
18/11/2011
Relatório de Vistoria de retorno nº 2. Empresa Paranasa. Rua Silveira Silva.
Meta
12/12/2011
Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua Rayldo de
Oliveira Gomes.
Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Rayldo de Oliveira
Gomes.
Relatório de Vistoria em República nº 1. Empresa Paranasa. Rua Maria
Guilhermina Esteves.
Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Maria Guilhermina
Esteves.
Relatório de Vistoria em Alojamento nº 1. Empresa Paranasa. Rua Filinto Muller
Meta
15/12/2011
Meta
04/01/2012
Meta
26/01/2011
Meta
04/01/2012
Meta
08/08/2011
Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Filinto Muller
Meta
25/08/2011
Relatório de Vistoria de República nº 2. Empresa Paranasa. Rua Filinto Muller
Meta
12/12/2011
Relatório de Vistoria de Retorno nº 2. Empresa Paranasa. Rua Filinto Muller
Meta
20/01/2012
Relatório de Vistoria em Alojamento nº 1. Empresa Paranasa. Rua Viela Senai
Meta
21/09/2011
Relatório de Vistoria de Retorno nº 1. Empresa Paranasa. Rua Viela Senai
Meta
12/01/2011
Relatório de Vistoria de Retorno nº 2. Empresa Paranasa. Rua Viela Senai
Meta
20/01/2012
Relatório de Vistoria de Retorno nº 1. Empresa Mutual Construções LTDA, Rua
Alfredo Justino, 75
Meta
20/01/2011
Relatório de ocorrência nº 06. Empresa Paranasa Engenharia e Comércio S.A. Rua
Silveira Silva, 30 (Amarelinha)
Análise Laboratorial - Sedimentos
Mapa_ComunidadeAquatica_A3
Mapa A3 Fauna, Flora Terrestre
Monitoramento da Qualidade das Águas Superficiais - Relatório Técnico 02
Monitoramento da Fauna Silvestre, Flora e Comunidades Aquáticas - Relatório
Técnico Semestral 01
Relatório Técnico de Amostragem Águas Superficiais
ART - Anotação de Responsabilidade Técnica
Meta
Documento Físico
Mapa - documento
físico
Documento Físico
Word-PDF
PDF
PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Apresentação em
Power Point - PDF
Word - PDF
Imagem - PDF
Imagem - PDF
Word - PDF
Word - PDF
Word - PDF
Word - JPEG
Excel - PDF
Certificado - JPEG
Certificado - JPEG
Certificado - JPEG
Certificado - JPEG
Word - JPEG
Word - PDF
Excel - PDF
Certificado - JPEG
Certificado - JPEG
Certificado - JPEG
Certificado - JPEG
Word - JPEG
Word - JPEG
Word - PDF
Word - PDF
Foto - WinZip
Word - PDF
Apresentação em
Power Point
Word - PDF
Planilha de Calibração/Amostragem – PTS
Certificado de Controle de Qualidade
Certificado de Calibração
Análise da Qualidade do Ar na Região de Três Lagoas em Três Pontos Pré
Definidos
Planilha de Calibração/Amostragem – PTS
Certificado de Calibração
Analise da Qualidade do Ar Na Região de Três Lagoas em Três Pontos PréDefinidos
1º Relatório PBA – Projeto Eldorado
Anexo 7 - Projeto primeira profissão
Ofício - Lançamento de Cartilha de Conscientização Ambiental
Programa: Minha Primeira Profissão - Projeto Eldorado Brasil
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - JPEG
Caderno de SMS (Contratadas e Subcontratadas) - Segurança do Trabalho, Meio
Ambiente e Saúde Contratadas e Subcontratadas
Projeto de Levantamento do Patrimônio Arqueológico e Cultural da Área
Diretamente Afetada Pela Implantação Projeto Eldorado da Eldorado Celulose E
Papel Ltda. - Município de Três Lagoas – Mato Grosso Do Sul.
Anexo 2a -Planilha de Amostragem - PTS
Anexo 2b- Planilha de Amostragem - PTS
Anexo 2c -Planilha de Amostragem - PTS
Anexo 2d -Planilha de Amostragem - PTS
Anexo 2e - Planilha de Amostragem - PTS
Anexo 2f - Planilha de Amostragem - PTS
Anexo 2g- Planilha de Amostragem - PTS
ADR - 1200s Certificado de Calibração
Média Horária do MP10
Material particulado PM10
Word - PDF
ART - Anotação de Responsabilidade Técnica - Alfrink Haruo Kikushi Porfirio
Word - PDF
PDF - WinZip
Relatório da Qualidade do Ar na Região de Três Lagoas-MS
Monitoramento da Fauna Silvestre, Flora e Comunidades Aquáticas - Relatório
Consolidado 056000054RMA2011-05
Relatório de Visita Técnica
2º Relatório PBA – Projeto Eldorado
2º Relatório do Programa Básico Ambiental PBA – Processo IMASUL
23/101.741/2010 - Licença de Instalação - Fabricação de celulose branqueada de
eucalipto - Projeto Eldorado
Atendimento de Licença Ambiental
Word - PDF
PDF - WinZip
PDF - WinZip
PDF - WinZip
Apresentação em
Power Point
Word - PDF
Word - PDF
PDF - WinZip
PDF - WinZip
Plano de Trabalho - Descrição do Projeto - Anexo I
Termo de compromisso de compensação ambiental nº 002/2010 que celebra a
Eldorado Celulose e Papel Ltda. com o Instituto de Meio Ambiente de Mato
Grosso do Sul
Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto
Ambiental (RIMA) e Análise de Risco (AR) - Capítulo 1 - Introdução
Ambiental (RIMA) e Análise de Risco (AR) - CAPÍTULO 2 – INFORMAÇÕES
GERAIS
AUTOR
DATA
VS
n
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n
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n
n
n
n
n
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n
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n
n
Analítica - Análises químicas e controle de qualidade
Anantecn - Análise Tecnológica Ltda
02/01/2012
n
20/12/2010
set/10
set/10
dez/10
set e dez /2010
n
n
n
n
Conselho Regional de Engenharia, Arquitetura e Agronomia de Mato
Grosso do Sul
Storm and Smoke - Eng. Amb. Alfrink Haruo Kikuchi Porfirio
Environnement S.A. - M. Paulze
Instrutemp - Instrumentos de Medição Ltda.
Storm and Smoke -Consultoria Ambiental e Prestadora de Serviços
dez/10
18/01/2011
n
29/09/2010
17/09/2010
17/09/2010
17/09/2010
17/09/2010
30/10/2009
out/10
n
1
2
3
4
1
Instrutemp - Instrumentos de Medição Ltda.
Conselho Regional de Engenharia, Arquitetura e Agronomia de Mato
Grosso do Sul
22/12/2010
17/09/2010
17/09/2010
17/09/2010
17/09/2010
30/10/2009
18/01/2011
n
5
6
7
8
2
Não Possui
Secretário Municipal de Meio Ambiente - Cristovam Lages Canela
jan/11
jun-dez/2010
Não Possui
16/12/2010
29/09/2010
20/09/2010
Griphus Consultoria em Recursos Culturais Ltda - Márcio Antônio Telles,
MS Jonas Israel de Sousa Melo
nov/10
Thermo Fisher Scientific
São Paulo
São Paulo
Anantecn - Análise Tecnológica Ltda.
29/03/2011
30/03/2011
01/04/2011
11/07/2011
12/07/2011
13/07/2011
14/07/2011
15/10/2007
mar-abr/?
11-12/7/2011
07/04/2011
Anantecn - Análise Tecnológica Ltda.
n
n
n
2
n
n
n
n
n
n
n
19/07/2011
n
n
n
n
n
n
n
n
n
n
n
n
15.07.2011
jun/11
n
30/04/2011
jun/11
18/08/2011
n
n
n
n
Eldorado Celulose e Papel S.A. - Jose Antonio Caveanha
28 de setembro de 2011
IMASUL -Carlos Alberto Negreiros Said Menezes. Eldorado Celulose e
Papel S.A. - Jose Antonio Caveanha
26/07/2010
26/07/2010
DMB Engenharia e Florestal Investimentos Florestais S⁄A
Não Possui
Não Possui
n
n
n
n
n
TIPO
TÍTULO
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) -CAPÍTULO 3 – CARACTERIZAÇÃO
DO EMPREENDIMENTO
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 GERENCIAMENTO DE PRODUTOS PERIGOSOS
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 - PROGRAMA DE
GERENCIAMENTO AMBIENTAL FABRIL
BAK e DWG Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto
WinZip
Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 CAD_PROCESSOS_PRODUTIVOS
Imagens - JPEG, BAK Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto
Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -Layot
e DWG - WinZip
Imagens de mapas Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto
JPEG - WinZip
Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 CARTOGRAFIA_ELDORADO1011
Imagens- JPEG Projeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto
WinZip
Ambiental (RIMA) e Análise de Risco (AR) - ANEXOS CAP. 3 -Localização
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) -CAPÍTULO 4 – ÀREAS DE
INFLUÊNCIA
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) -5.1 – MEIO FÍSICO
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) -5.2 – MEIO BIÓTICO
Imagem de MapaProjeto Eldorado - Estudo de Impacto Ambiental (EIA), Relatório de Impacto
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR) -5.2 – MEIO BIÓTICO - ANEXO:
Mapa de cobertura do solo A3
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR-) 5.3 – MEIO ANTRÓPICO
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR-) CAPÍTULO 6 – ANÁLISE DIS
IMPACTOS AMBIENTAIS E MEDIDAS
MITIGADORAS
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR-) - CAPÍTULO 7 – PROGRAMAS
AMBIENTAIS
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR-) -CAPÍTULO 8 – ESTUDO DE
DISPERSÃO ATMOSFÉRICA
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR-) CAPÍTULO 9 – ESTUDO DE
ANÁLISE DE RISCO
PDF - WinZip
Ambiental (RIMA) e Análise de Risco (AR-) CAPÍTULO 10 − CONSIDERAÇÕES
FINAIS
Excel - PDF
Cronograma Projeto Básico Ambiental - PBA - Projeto Eldorado
Word - PDF
Licença de Instalação - Fabricação de Celulose Branqueada de Eucalipto
Word - PDF
Projeto Eldorado: Programa Básico Ambiental - PBA
Apresentação em
Atendimento de Licença Ambiental
Power Point
Word - PDF
Notas de reuniões - Fóruns para apresentação do PBA à comunidade de Três
Lagoas e região
Word - PDF
Monitoramento da Estação de Tratamento de Efluentes Provisória
Word - PDF
Word - PDF
Licença Prévia - Eldorado Celuloses e Papel -Canteiro de Obras de Três Lagoas
AUTOR
Florestal Investimentos Florestais S⁄A
DATA
VS
Não Possui
n
Florestal Investimentos Florestais S⁄A
Não Possui
n
Não Possui
n
Não Possui
Não Possui
Não Possui
n
n
Não Possui
Não Possui
n
n
Não Possui
Não Possui
Não Possui
n
n
n
Não Possui
Não Possui
n
n
Não Possui
n
Não Possui
n
Não Possui
Não Possui
n
Não Possui
IMASUL -Carlos Alberto Negreiros Said Menezes
DMB Engenharia e Eldorado Celulose e Papel S.A.
Não Possui
26/03/2010
Não Possui
28/09/2011
18/03/2010
Eldorado Celulose e Papel S.A. - Mayza Carla da Silva Devens
Eldorado Celulose e Papel S.A. - Mayza Carla da Silva Devens
05/01/2012
01/09/2011
04/04/2011
n
n
n
n
n
n
n
n
n
Word - PDF
Word - PDF
Licença Prévia - Eldorado Celuloses e Papel -Canteiro de Obras de Selviria
Licença Prévia - Eldorado Celuloses e Papel - Cais de atracação de Três Lagoas
04/04/2011
04/04/2011
Word - PDF
Licença Prévia - Florestal Investimentos Florestais - Fabricação de celulose
branqueada de eucalipto
Licença de Operação - Tratamento e disposição final de resíduos sólidos
Licença de Operação - Eldorado Celulose e Papel - Linha de transmissão de
energia elétrica acima de 7,94 KV até 230 KV
Autorização ambiental para exploração vegetal
Outorga de direito de uso dos recursos hídricos
Autorização para regularização de um terminal hidroviário na margem direita do
córrego bebedouro
Autorização para captação de água e emissário
Relatório de Conclusão de Obra - Manutenção do Viveiro de Três Lagoas;
Certificado de Entrega e Garantia; Atestado de conclusão de obra.
16/12/2009
24/09/2009
24/02/2011
n
Agência Nacional de Águas - Vicente Andreu
Marinha do Brasil - 3º Sargento Mr Edson Cesar
16/06/2010
04/08/2011
08/12/2011
n
n
Marinha do Brasil - 3º Sargento Mr Edson Cesar
Eldorado Celulose e Papel S.A. - Mayza Carla da Silva Devens ; Van Der
Hoeven-Antonio Carlos Luz; Secretaria Municipal de Meio AmbienteMateus Arantes.
Janaína Monti Silveira
12/08/2011
07/11/2011
Word - JPEG
Word - PDF
Word - JPEG
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Word - PDF
Projeto Técnico Ambiental para a Atividade de Supressão de Vegetação Nativa
no imóvel rural
denominado Fazenda Eldorado conforme Resolução SEMAC n° 08.
26/10/2011
01/01/2012
Audiência Pública - Projeto Eldorado. Convite. (capa)
03/12/2009
Folder - PDF
Audiência Pública. Folder parte 1 (interno)
Folder - PDF
Audiência Pública. Folder parte 2 (final)
Documento Físico
Documento Físico
Documento Físico
Plano de Manejo submetido à IMASUL em 28 de Abril de 2010.
Plano de Manejo submetido à IMASUL em 20 de Dezembro de 2011 para
reflorestamento de 3.885,7641 ha no município de Inocência
Controle online da legislação ambiental, fornecida pela Âmbito.
Relatório de Aprovação Ambiental de Arrendamento de Terra (Modelo)
Relatório Legal para contrato de arrendamento/parceria agrícola Fazenda
Nevada
Relatório de Avaliação da Fazenda Barra Mansa, 02/09/2010
PTEAS – (Projeto Técnico Econômico, Ambiental e Social) da Fazenda Laranja
Quinhão I e II- UGO 01. Município de Três Lagoas. Visitada em 27 de Outubro
2011. Revisado em 17 de Jan 2012.
PTEAS – (Projeto Técnico Econômico, Ambiental e Social) da Fazenda Barra
Mansa- UGO 01. Município de Três Lagoas. Visitada em 27 de dezembro de 2011.
Revisado em 18 Jan 2012.
Levantamento arqueológico na área de plantio de eucalipto da Florestal Brasil,
municípios de Três Lagoas, Selvíria, Aparecida do Taboado, Inocência, Água
Clara, Ribas do Rio Pardo e Santa Rita do Rio Pardo/MS. Dez/2011 (Protocolo
IPHAN/MS nº 0141.000544/2011-82
Planilha de controle de permissão de resíduos
Procedimento de gestão de resíduos
Alsco Toalheiro Brasil Ltda. - Licença de Operação válida até 05 de Novembro de
2013.
Lwart Lubrificantes Ltda. – Licença de Operação nº 453/2009 valida por 4 anos
IMASUL -Carlos Alberto Negreiros Said Menezes; Florestal Invesimentos
Florestais S/A- Projeto Eldorado
Florestal Brasil
Florestal Brasil
Documento Físico
Lwart Lubrificantes Ltda. - Licença de Operação válida até 1º de Maio de 2013
Documento Físico
Podium Serviços Ambientais Ltda. - Licença de Operação nº 367/2010 validos por Lwart Lubrificantes Ltda
4 anos
Estre Emp. de Saneamento e Tratamento de Resíduos S.A. – C.G.R. Guatapará – Estre Emp. de Saneamento e Tratamento de Resíduos S.A
Licença Parcial de Operação válida até 21 de Dezembro de 2012.
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Maxima Ambiental – Serviços Gerais e Participações Ltda. Licença de Operação
nº 301156/2010 valida até 28 de Novembro de 2013.
Essencis Soluções Ambientais S/A – Licença Operacional Parcial válida até 6 de
Julho de 2012.
Essencis Soluções Ambientais S/A – Licença Operacional Parcial válida até 6 de
Junho de 2013.
Essencis Soluções Ambientais S/A – Licença Operacional nº 041 válida até 29 de
Março de 2014.
PPRA (Programa de Prevenção de Riscos Ambientais) 2012, PSSTSEF (Programa
de Saúde no Trabalho na Silvicultura e Exploração Florestal) 2011-2012, Registro
de Treinamento - Integração, Primeiros Socorros, Manuseio de Pesticida - da
empresa JS Florestal
n
n
n
Eldorado Celulose e Papel S.A. -Edna Martha Martins Pereira
Documento Físico
n
25/10/2011
Requerimento Padrão - Supressão Vegetal
Visão Geral da Companhia
Documento Físico
Documento Físico
n
n
Word - PDF
Apresentação em
Power Point
Folder - PDF
Documento Físico
Documento Físico
Documento Físico
n
03/12/2009
40150
n
n
n
n
n
28/04/2010.
40897
n
Florestal Brasil
Florestal Brasil
Florestal Brasil
Não Possui
n
n
Florestal Brasil
Florestal Brasil
40788
40925
n
n
n
n
Florestal Brasil
40926
n
Florestal Brasil
Dez. 2011
n
Florestal Brasil
Florestal Brasil
Alsco Toalheiro Brasil Ltda
Lwart Lubrificantes Ltda
Não Possui
Não Possui
41583
2009
Lwart Lubrificantes Ltda
n
n
n
2010
n
n
Maxima Ambiental
n
Essencis Soluções Ambientais
n
n
JS Florestal
n
n
n
2011-2012
n
TIPO
TÍTULO
Documento Físico
Procedimento para Comunicação e Investigação para Acidentes e incidentes de
Florestal Brasil
Trabalho – PC- SSO- 002
Registro de Diálogo de Saúde e Segurança
Florestal Brasil
Registro de Treinamento para Aplicação e Manuseio de Pesticida em 30 a 31 de Florestal Brasil
Agosto de 2011. Duração 20horas para Unidade de Operação 1 - Três Lagoas-MS.
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
AUTOR
Florestal Brasil
Registro de Treinamento para Combate de Fogo em Floresta. 31 de Agosto de
2011. Duração: 8 horas para Unidade de Operação 1- Três Lagoas-MS.
CIPATRs (Comissão Interna de Prevenção de Acidentes do Trabalho Rural) para Florestal Brasil
as Unidades Operacionais de Três Lagoas, Selvíria, Andradina, Santa Rita do
Pardo e Água Clara. Informe da eleição e protocolada no Ministério do Trabalho.
Registro de encontros da CIPATR de 11 de Novembro, 2011 e Treinamento da
CIPATR de 20 horas em 28 a 30 de Setembro,2011.
PPRA (Programa de Prevenção de Riscos Ambientais) e LTCAT (Laudo Técnico
das Condições do Ambiente de Trabalho) da empresa Plantar 2011/2012
Florestal Brasil
Florestal Brasil
Excel
Programa de Prevenção de Riscos Ocupacionais como requerido pela NR-09 para
Três Lagoas-MS;
Selvíria-MS;
Pontal do Araguaia-MT;
Santa Rita do Pardo-MS;
Água Clara-MS;
Andradina-SP;
Três Lagoas-MS;
Selvíria-MS;
Pontal do Araguaia-MT;
Santa Rita do Pardo-MS;
Água Clara-MS;
Programa de Prevenção de Riscos Ocupacionais para Andradina - SP, como
requerido pela NR-09;
PROCESSOS - Atividade - Operação (Planilha
Poyry_Aspecto_Impacto_Avaliação_Final)
PROJETO FSC (Cronog_FSC_CoC)
PDF - Word
Diagnóstico Socioterritorial
MMX; Integração Serviços e Assessoria Empresarial Ltda.
Excel
PDF - Word
CERTIFICAÇÃO FLORESTAL - FSC
Plano de Manejo Florestal
Florestal Brasil
Eldorado Brasil
PDF - Word
PDF - Word
Portfólio Serviços Múltipla
Relatório de Autuação (Relatório Autos de Infração - Super. Reg. Trabalho e
Emprego Mato Grosso)
Comunicação e Social (Relatório Grupo Comunicação e Social)
Múltipla Gestão de Pessoas
Departamento jurídico - Thales Alessi de Oliveira Silva e Ana Malvina
Ribeiro dos Santos
Não Possui
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Documento Físico
Excel
Word
PDF - Word
Word
Plantar
DATA
n
n
40786
n
40786
11/11/2011 e 30/11/2011
n
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Florestal Brasil
n
Não Possui
Não Possui
Não Possui
fev/12
jun/08
n
Não Possui
jan/12
n
n
Não Possui
2
Inventário de Áreas de Alto Valor de Conservação com importãncia sociocultural Casa da Floresta Assessoria Ambiental (Klaus Duarte Barretto, Mônica
Cabello de Brito) e Eldorado Brasil
crítica e/ou funções sociais essenciais na região de atuação da
Eldorado Brasil, Mato Grosso do Sul
27/04/2011
15/02/2012
jan/12
Word
Advocacia Gustavo Barbaroto Paro
PDF - Word
Boletim de Análises Laboratoriais (Eldorado Brasil Site AM 4069)
Sanágua
25/05/2011
17/05/2011
PDF - Word
Boletim de Análises Laboratoriais (Eldorado Brasil Site 7642 7643 7644 7645)
Sanágua
PDF - Word
Boletim de Análises Laboratoriais (Eldorado AM 5458)
Sanágua
PDF - Word
Boletim de Análises Laboratoriais (Eldorado AM 5457)
Sanágua
PDF - Word
Sanágua
PDF
Relatório de Ensaio Nº11454/11 (Eldorado Brasil Site de Obras AM 11453
_retroativo_ _1_)
Planilha de Controle Operacional - ETE - Site de Obras (RDOs)
Sanágua, Eldorado Brasil e Meta
PDF
Planilha de Controle Operacional - ETA - Site de Obras (RDOs)
Sanágua, Eldorado Brasil e Meta
PDF
Boletim de Análises Laboratoriais (Água site jul 11)
Sanágua
PDF
WinZip - PDF
Boletim de Análises Laboratoriais (ELDORADO BRASIL ALOJAMENTO AM
8943 8944 8945 8946)
Boletim de Análises Laboratoriais (ELDORADO BRASIL SITE DE OBRAS AM
10494 10495 10496 10497)
9417 9418 9419 9420)
Boletim de Análises Laboratoriais (ELDORADO BRASIL SITE 11419 11420 11421
11422)
10199 10200 10201 10202)
Relatório Analítico MI Dengue
Word
Notificados e Positivos de Dengue
PDF
Manual de Armazenamento de Produtos Fitossanitários
PDF
Monitoramento da Qualidade da Água
Secretaria Municipal de Saúde de Três Lagoas; Departamento de
Vigilância e Saneamento; Vigilância Epidemiológica / SINANNET
ANDEF - Associação Nacional de Defesa Vegetal; COGAP - Comitê de
Boas Práticas Agrícolas
Eldorado Celulose e Papel
PDF
Solicitação visita sitio de obras
Word
Sistema de Documentação - Aquisição e Liberação de Terras
Word
Sistema de Documentação - Atendimento à Emergência
Florestal Brasil
Documento Físico
Sistema de Documentação - Vigilância Patrimonial
PDF
Eldorado Brasil
Consultoria Ambiental Guará
Não Possui
PDF
PGRS – Plano de Gerenciamento de Resíduos Sólidos da ELDORADO BRASILBase Florestal
Considerações técnicas e legais do Projeto de Regularização da Reserva Legal do
imóvel rural Faz. Eldorado.
Proposta Multipla para Recrutamento, Seleção e Gestão de Pessoas
01/07/2011
20/07/2011
02/01/2012
12/08/2011
22/12/2011
01/02/2012
Multipla Gestão de Pessoas
PDF
Procedimento Corporativo para Seleção e Contratação de Pessoal
Eldorado Brasil
14/09/2011
24/02/2012
PDF
Instrução de Trabalho para Índice de Fumaça Preta
Florestal Brasil
13/06/2011
PDF
Manutenção Preventiva e Corretiva de Equipamentos, Veículos e Máquinas
Florestal Brasil
14/06/2011
PDF
Instrução de Trabalho para Abastecimento de Equipamentos Florestais
Florestal Brasil
18/01/2011
PDF
Procedimento Corporativo para Gerenciamento de Resíduos
Eldorado Brasil
12/12/2011
Word
Projetos Socioambientais PBA - BNDES
Eldorado Brasil
30/01/2012
PDF
PDF
n
n
2
n
2
19/06/2009
PDF
n
2011/2012
Advocacia Gustavo Barbaroto Paro
PDF
n
n
Relatório Detalhado de Processo -Ação Civil Pública -Ministério Público do
Trabalho ( tr-rela-acp-mptXmcl-barra)
Relatório Detalhado de Processo -Ação Inibitória
PDF
VS
n
n
n
n
27/06/2011
27/06/2011
14/12/2011
n
n
Sanágua
01/07/2011
01/07/2011
01/07/2011
18/11/2011
Sanágua
29/11/2011
n
Sanágua
31/10/2011
n
Sanágua
28/12/2011
n
Sanágua
18/11/2011
n
Ecovec S.A. , MI Dengue (Maria Rita Antunes Col)
03/07/1905
30/01/2012
02/07/1905
n
2
n
n
n
4
2
n
n
n
n
n
n
0
n
n
PC-RH001(00)
IT-MEF001(00)
PO-MEF001(00)
IT-MEF002(00)
PC-MAC007(00)
n
Name
Function
Site
Daniel Mathias
Financial Manager
Corporate
Ricardo Ferreira da Silva
Legal Affairs Manager
Corporate
José Antonio Caveanha
Sustainability Manager
Industrial
Maysa Carla da Silva Devens
Sustainability Analyst
Industrial
Germano Vieira
Forest Director
Forest
José Sobrinho Vieira
Silviculture Manager
Forest
Simone Filipo
Social Responsibility
Forest
Priscila Quevedo Monteiro Garcez
Forest Licensing
Forest
Nátia Santos
Environmental Management
Forest
Osvaldo Costa
Health and Safety
Forest
Alessandra Schreiner
Facilities
Forest
3 rural workers
Worker
Forest
1 supervisor of rural workers
Worker
Forest
Paulo Leme
HR
Industry and Forest
Ana Terra
HR
Industry and Forest
Fátima Garcia
HR
Industry
Gislaine Maino
Administrative Analyst
Industry
Marcone Santos Araújo
Environment Certification
Forest
Antônio José Sodré
Industry
Employment Relatioship
Coordinator
Sales Bueno
Administration Manager
Industrial
Vinicius Garcia
Administration Analyst
Industrial
Carlos Borromeu Brunetto
Process Consultant
Industry
José Carlos Kling
Process and Technology Manager
Industry
Daniel Rubega
Project Manager
Industry
2 contractor’s workers
Worker
Industry
Waldyr Bisco
Manager
CBC (power boiler supplier
Leonardo Maia Rocha
Manager
Serpal (power boiler
construction works
Gleison Laranjeira Rodrigues
Safety Technician
Serpal
Larissa Rafaela de Oliveira
Environmental Analyst
Serpal
Cassio Keller
Safety Technician
CBC
Vinicius Borges S.L. Garcia
Administration analyst
Industry
Zampierry Issler
Operational supervisor
Podium (waste management
contractor
Artur Monteiro
Environmental engineer
Podium
Floriswaldo Ferreira da Silva
Supervisor
Meta (employee relationship
contractor)
Douglas Henrique Queiroz
Supervisor
Meta (employee relationship
contractor)
Mário Roberto Scoss
Safety Engineer
DuPont (safety management
contractor)
Mário Kajita
EHS Coordinator
DuPont
Issam Fares Jr.
Occupational Physician
IF Saúde (contractor)
Gerson de Souza
Leader of the cultivation team at the
time of the site visit on Fazenda Barra Forest
Mansa
Mateus Reis and Moacir Reis
Wood Supplier and Land Leaser to
ELDORADO
Mutum Group
Daniel Mathias
Financial Manager
Industrial
Alvaro Bunster
Logistics Executive Manager
Port and multimodal
terminals
Otávio Grottone
Logistics Coordinator
Port and multimodal
terminals
José Antonio Caveanha
Sustainability Manager
Industrial
Agnaldo Silva Souza Jr.
Environmental coordinator
Santos Port – Terminal Elmar
Claudinei Gonçalves
Warehouse Foreman
Santos Port – Terminal Elmar
Annex B
Brazilian Environmental
Licensing Process Description
1
As part of the scope, ERM assessed if the environmental licensing process,
which includes the Environmental Impact Assessment (EIA) study, public
hearings and the environmental basic programs, was performed in
compliance with Brazilian regulations.
Environmental Licensing Regulations
Federal 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 the
environmental permitting obligation for construction, installation,
enlargement and operation of establishments and activities that use
environmental resources, considered effective or potential polluters or that
can cause environmental degradation.
Article 10 of Federal Law 6.938/81, amended by Law 7.804/1989, establishes
that States are responsible for environmental licensing in their territories,
except for projects with regional or national influence concerning
environmental impacts, where 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 sources
of pollution or present potential environmental impacts is regulated at the
Federal level by Federal Law 6938/81; Federal Decrees 99274/90 and 3942/01;
CONAMA Resolution 001/86 and CONAMA Resolution 237/97. These
regulations establish three general levels of licensing for new projects. They
also indicate that the environmental authorities shall make licensing
procedures compatible with the planning and implementation steps of new
projects, having the following as minimum requirements:
 Preliminary License (Licença Prévia - LP): issued after the project and
design of each facility has been approved;
 Installation License (Licença de Instalação - LI): issued before the
construction of each development; and
 Operating License (Licença de Operação - LO): issued after the phase of
construction and before operations commence.
Existing plants/facilities/developments must obtain new environmental
permits whenever any processes are changed, any facilities are expanded or
new facilities are constructed which include any new equipment or building.
With regards to State licensing regulations for forest activities, according to
SEMAC 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 planting
activities and conduct of forest species mentioned within are exempt from
licensing.
1.1
INDUSTRIAL SITE ENVIRONMENTAL LICENSING PROCEDURES
1.1.1
Federal Level
Federal CONAMA Resolution 01/86 requires that Environmental and Social
Impact Assessment (EIA) must be prepared by developers for new projects or
expansions of projects listed in its Article 2, which includes pulp and paper
production facilities, railways, ports, pipelines, high-voltage transmission
lines above 230 kV and energy power plants above 10 MW, among others.
However, this list is only indicative, allowing State or Municipal agencies to
require an EIA for other planned industries or enlargement of existing ones.
An EIA and its report RIMA - Environmental Impact Statement (Relatório de
Impacto Ambiental) must be developed, submitted to the environmental
protection agency and to a public hearing, reviewed and approved before the
issuance of a Preliminary Permit.
The authorities responsible for the EIA review at Federal Level are IBAMA
(Brazilian Environmental Institute) and CONAMA (National Environmental
Council), and at State Level is the Environment Office/Environmental Council
of the respective State.
CONAMA Resolution 01/86 also indicates that the EIA must be conducted by
a qualified multidisciplinary team, independent of the project entrepreneur.
All the 3 stages of permit previously described, besides having an expiration
term, are also subject of alterations, suspensions and annulments. These
actions can happen in the following cases:
 Violation or unsatisfactory fulfillment of any legal rule or circumstance;
 Omission or misdirection of relevant information during the permitting
process; and
 Occurrence of severe environmental and/or health risks.
According to the Federal Regulations, the permits must be publicly
announced. This measure was created in order to allow the society to take part
on the licensing procedure. As stated by the CONAMA Resolution 006/86,
“all the permit requests, renewing and issuing must be published at the
official press, as well as in large-circulation regional or local periodicals”.
Failure in doing so causes the cancellation of the permit by the government or
the judicial power, by means of a class action.
1.1.2
Licensing under Mato Grosso do Sul State Scope
The Mato Grosso do Sul State Environmental Licensing process follows the
Federal regulations and establishes complementation to the State and local
responsibilities.
The laws and resolutions bellow summarize the legislation on the subject.
Mato Grosso do Sul State Law nº 2257/01 establishes the guidelines for state
environmental licensing and the timeframe for the issuance of Permits and
Environmental authorizations.
According to its article 4 the procedure, for environmental licensing must
obey the following steps:
I. Environmental Permit application by the entrepreneur, accompanied by
the documents appropriately filled out and following the legal and material
requirements, projects and environmental studies requested and its
publicity;
II. Documents, projects and environmental studies analysis presented and
technical inspections, when necessary;
III.Public Hearings, when necessary, according to the regulations;
IV. Explanations and clarifications may be requested due to the analysis of the
public hearings; and
V. Issuance of the permit and publication of the permit concession.
In its article 6 the specific procedures for environmental permit authorization
are defined, as well as the unique characteristics of a project or activity, for
instance, simplified procedures for low potential environmental impact which
will 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 environmental
licensing of enterprises and activities considered to have local impact, as well
as those delegated by IMASUL – Environmental Institute of Mato Grosso do
Sul State (Instituto de Meio Ambiente do Mato Grosso do Sul) by legal
instrument or agreement.
SEMA (State Environmental Secretariat) Resolution nº 1 from January 26, 1989
establishes 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 to
it.
State Decree nº 10.600 from December 19, 2001 establishes the technical and
administrative cooperation between state and municipal environmental
agencies aiming at the licensing and inspection of activities with local
environmental impacts.
State Decree nº 11.204 from May 7, 2003 establishes the State jurisdiction for
environmental licensing in Mato Grosso do Sul State.
SEMA/IMAP Resolution nº 01, from April 30th, 2003 establishes the
procedures 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 through
use and soil occupation control among others.
1.1.3
ELDORADO Licensing Status
As previously explained, the entrepreneurship of ELDORADO in the city of
Três Lagoas, State of Mato Grosso do Sul -MS consists in the installation of a
bleached kraft eucalyptus pulp mill, eucalyptus homogeneous reforestation
and 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 the
municipality of Três Lagoas in the center western region of Brazil.
The pulp mill has been granted, until the present moment, with Preliminary
and Installation Permits by the State Environment Agency IMASUL – Mato
Grosso do Sul Environmental Institute (Instituto de Meio Ambiente do Mato
Grosso do Sul). The Installation Permit – LI refers to the second step of the
environmental licensing process, which includes the approval of the
environmental and social impact assessment (EIA) and also the proposed
environmental monitoring plans outlined in the Impact assessment study and
then detailed within an Environmental Basic Plan - PBA (Plano Básico
Ambiental).). The requirements of both licenses are being implemented.
Therefore, the company is in compliance regarding the environmental
licensing process.
The process began in 2009 with the elaboration of the EIA for a pulp mill
developed by the former owner of the entrepreneurship Florestal
Investimentos Florestais S⁄A (Florestal). Florestal has developed a strategic
eucalyptus cultivation and also partnership and leasing contracts of wood in
Três Lagoas, Selvíria, Água Clara, Inocência, Aparecida do Taboado in Mato
Grosso do Sul state and also other cities in the state of São Paulo.
During the EIA analysis process the Environmental Agency IMASUL
conducted a Public Hearing held on December 3rd, 2009, at 7pm in Três
Lagoas city, in Centro de Eventos Leiloado at Road BR 262, km 11.
ELDORADO Brasil received the Preliminary License LP nº 314/2009. After
this, a complementary study called Basic Environmental Project (Projeto
Básico Ambiental - PBA) was held in order to detail the environmental
programs proposed in the EIA and to comply with the technical requirements
imposed 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 and
therefore would require their own preliminary, installation and operating
licenses. The forest is not subject to environmental licensing process.
The environmental programs - PBA (Plano Básico Ambiental) are currently
being implemented.
The table 1.1 lists the environmental programs (PBA).
Table 1.1
Environmental Programs of the Pulp and Paper Mill
Environmental Programs
1. Project for Social Communication and Relationship with Communities close to the
Enterprise – PCS
2. Environmental Quality Control Project – PCQA
2.a Monitoring of Surface Water Quality
2.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 Monitoring
2.g Monitoring of the Wastewater Treatment System during installation phase.
2.h Monitoring of wastewater Treatment System during operation.
3. Social Development Projects – PDS
3.a Project for Development Entrepreneurial
3.b Adequacy of Project Infrastructure
3.c Public Health Project
3.d Security Project – Proseg
3.e Project for education, leisure and culture to the employees
4. Environmental Education and Training Project– PTEA
5. Environmental Projects for Construction – PAC
After the elaboration of the PBA, public meetings were held with stakeholders
representing all the society sectors in order to create a transparent process and
take in account different opinions.
Therefore, after analysis of documents from the environmental agency,
ELDORADO has been issued the Installation License nº 17/2011 on February
24th, 2011. The Installation License is valid until March 26th, 2013.
ELDORADO has recently decided to include a sodium chlorate
manufacturing plant on site, instead of transporting the sodium chlorate by
tank trucks from market suppliers. As a result, it applied for an Installation
Permit for the plant expansion on August 31, 2011. Additionally, it developed
an simplified environmental study (EAP – Estudo Ambiental Preliminar) and
a risk analysis, considering the presence of the Chlorate plant to subsidize the
licensing process. The Installation Permit for the Chlorate Plant has not been
issued 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 November
18th, 2011 in order to include in the Installation Permit the commissioning of:
pulp production, chemical recovery, utilities and manufacturing systems for
sodium 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 electrical
substation – 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 the
pier which were informed in the EIA;
 Preliminary License nº 137/2010 from November 4th, 2010 for the fuel
station – The concessionaire of the fuel station is Petrobras and, reportedly,
this company is responsible to issue the documentation for Installation and
Operation License, since they will be operating the station and
 Preliminary License nº 136/2010 from November 4th, 2010 for rail
extension inside the enterprise.
All the licenses listed above are currently valid.
2
FORESTRY OPERATIONS LICENSING
For the forestry activities no Environmental Impact Assessment (EIA) and
Environmental Basic Plan (PBA) were developed, according to the exemption
granted by State regulations.
The previously mentioned legislation requires Florestal to issues to IMASUL state environmental agency - "Planting Informative" of the concerning areas
for such activity as well as the appropriate "environmental clearance for
cutting of planted forests."
These documents demand proof of preservation of legally protected areas.
The legally protected areas, such as legal reserve and permanent preservation
areas are defined by Brazilian legislation. Reportedly, it is expected an average
use of 65% of the properties. According to information provided on site visit
from the total of 32.295 m² of legally protected areas, 24.044 m² are legal
reserves and 8,251m² are permanent preservation areas. Relating to the legal
reserves, reportedly 13% of all legal reserves are submitted and recognized by
the environmental agency, 53% has been submitted to the environmental
agency for approval and 34% has signed term of commitment for proof of
legal reserve within two years.
According to documents samples of eucalyptus cultivating areas, provided
during site visit, ELDORADO complies with licensing requirements and
procedures with the state environmental agency.
3
LOGISTICS PROJECT ENVIRONMENTAL LICENSING PROCESS
As part of the scope, ERM assessed if the environmental licensing process was
performed in compliance with Brazilian regulations for the following areas:
Fazenda Boa Esperança in Aparecida do Taboado –MS, Terminal in
Pederneiras – SP, Temporary and future warehouses in Santos Port TerminalSP.
3.1
LICENSING UNDER FEDERAL SCOPE
Federal 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 the
environmental permitting obligation for construction, installation,
enlargement and operation of establishments and activities that use
environmental resources, considered effective or potential polluters or that
can cause environmental degradation.
Article 10 of Federal Law 6.938/81, amended by Law 7.804/1989, establishes
that States are responsible for environmental licensing in their territories,
except for projects with regional or national influence concerning
environmental 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 sources
of pollution or present potential environmental impacts is regulated at the
Federal level by Federal Law 6938/81; Federal Decrees 99274/90 and 3942/01;
CONAMA Resolution 001/86 and CONAMA Resolution 237/97. These
regulations establish three general levels of licensing for new projects. They
also indicate that the environmental authorities shall make licensing
procedures compatible with the planning and implementation steps of new
projects, having the following as minimum requirements:
 Preliminary License (Licença Prévia - LP): issued after the project and
design of each facility has been approved;
 Installation License (Licença de Instalação - LI): issued before the
construction of each development; and
 Operating License (Licença de Operação - LO): issued after the phase of
construction and before operations commence.
Existing plants/facilities/developments must obtain new environmental
permits whenever any processes are changed, any facilities are expanded or
new facilities are constructed which include any new equipment or building.
The Federal Law 8630/93 deals with the legal operation of organized ports
and port facilities and other measures.
ANTAQ Resolution 830/07 approves the leasing program of areas and port
facilities in port of Santos.
MMA Ordinance 424/11, provides for specific procedures to be applied by
IBAMA in environmental regulation of ports and port terminals, as well as
those granted to Companhia Docas.
The area of the Organized Port of Santos is composed in accordance with
Ordinance 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 by
the islands of Sao Vicente and Santo Amaro, from Ponta da Praia to
Alemoa and on the left bank, from the island of Barnabé to the confluence
of the Rio Santo Amaro, including all piers, docks, bridges, piers and
mooring berths, warehouses, yards, buildings in general, internal
circulation roads and rail roads, and also the land along these marginal
bands and their surroundings, belonging to the Union, incorporated or not
the property of the Port of Santos, or under its custody and responsibility,
including also the Itatinga Hydroelectric Power Plant and the range of
domain of its transmission lines, and
b) for infrastructure protection and waterway access, such as anchorage areas,
evolution basin , the access channel until the parallel 23 º 52 '15 "south and
adjacent to the banks of the ground facilities of the organized Port as
defined in letter "a" above, which is or will be constructed and maintained
by the Port or other agency of government.
3.2
LICENSING UNDER MATO GROSSO DO SUL STATE SCOPE
The Mato Grosso do Sul State Environmental Licensing process follows the
Federal regulations and establishes complementation to the State and local
responsibilities.
The laws and resolutions bellow summarize the legislation on the subject.
Mato Grosso do Sul State Law 2257/01 establishes the guidelines for state
environmental licensing and the timeframe for the issuance of Permits and
Environmental authorizations.
According to its article 4 the procedure, for environmental licensing must
obey the following steps:
I. Environmental Permit application by the entrepreneur, accompanied by
the documents appropriately filled out and following the legal and material
requirements, projects and environmental studies requested and its
publicity;
II. Documents, projects and environmental studies analysis presented and
technical inspections, when necessary;
III.Public Hearings, when necessary, according to the regulations;
IV.
Explanations and clarifications may be requested due to the analysis of
the public hearings; and
V. Issuance of the permit and publication of the permit concession.
In its article 6 the specific procedures for environmental permit authorization
are defined, as well as the unique characteristics of a project or activity, for
instance, simplified procedures for low potential environmental impact which
will 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 environmental
licensing of enterprises and activities considered to have local impact, as well
as those delegated by IMASUL – Environmental Institute of Mato Grosso do
Sul State (Instituto de Meio Ambiente do Mato Grosso do Sul) by legal
instrument or agreement.
SEMA (State Environmental Secretariat) Resolution 01/89 establishes 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 to it.
State Decree 10.600/01 establishes the technical and administrative
cooperation between state and municipal environmental agencies aiming at
the licensing and inspection of activities with local environmental impacts.
State Decree 11.204/03 establishes the State jurisdiction for environmental
licensing in Mato Grosso do Sul State.
SEMA/IMAP Resolution 01/03 establishes the procedures for environmental
licensing process analysis.
According to SEMAC Resolution 008/2011, it was established the
documentation required for environmental licensing of an infrastructure
project, 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 to
submit the following studies to the state environmental agency (IMASUL):
RAS - Simplified Environmental Report, PBA - Basic Environmental Plan and
Form of linear works. In addition, to obtain the operating permit it is required
the RTC-Technical Report of Completion. In this case, the installation license is
not required.
3.3
LICENSING UNDER SÃO PAULO STATE SCOPE
The São Paulo State Environmental Licensing process follows the Federal
regulations and establishes complementation to the State and local
responsibilities.
In the State of São Paulo, CETESB is the agency assigned with the authority to
issue permits for potential pollution sources, including industrial activities.
SMA (State Secretary of Environment) reviews licensing procedures for other
potential pollution sources in the event a Environmental Impact Assessment
exists, in accordance with Federal regulations.
According with the State Law 997, issued on May 31st, 1976, modified by Law
9477/96, every installation, construction or enlargement and operation of
pollutant sources listed in this law are subject to prior authorization by the
Environmental Authority via permits.
Permits issued by the Environmental State Authority include:

Preliminary Environmental Permit – LP (Licença Prévia): issued during
the planning of a pollution source. LP contains the basic requirements
that must be complied with during the location, installation and operation
of the project;

Installation Environmental Permit – LI (Licença de Instalação): this permit
authorizes the installation / construction of the project; and

Operating Environmental Permit - LO (Licença de Operação): authorizes
the operation of the site and any environmental control equipment, in
accordance with LP and LI requirements.
The expiration date of the permits will be defined by the Environmental
Agency, depending on the projects potential for polluting. An Operating
Environmental 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 the
permitting requirements for São Paulo State. Pollution sources subject to an
Environmental Permit are listed in Article 57 of State Decree 8468/76. Annex
10 of State Decree 8468/76 defines the projects subjected to LP. Article 58-A of
State Decree 8468/76, presents the activities subjected to an Installation Permit
and Article 62 establishes the activities subjected to an Operating Permit.
According to Article 58-A of State Decree 8468/76, the Installation Permit
should be obtained for:

The construction, reconstruction, enlargement or renovation of any
building where a potential pollution source is installed;

The installation of a new potential pollution source in an existing
building; and

The installation, enlargement or alteration of a pollution source.
According to Article 62 of State Decree 8468/76, the LO should be obtained
for:

Use of a new building or modification to an existing building where a
new pollution source will be installed;

The operation of a pollution source within an existing building;

The operation pollution source already installed, enlarged or modified;
and

Land subdivision, detachment condominium and housing development,
prior to occupation, and cemeteries.
Article 59 of State Decree 8468/76 states that a Municipal Certificate is
required when a facility applies for the installation permit, in order to verify if
the location and type of the installation are in accordance with municipal
legislation.
Article 71 of the State Decree 8468/76 states that the pollution sources already
covered by an Operating Permit obtained prior to December 04, 2002 will be
contacted by CETESB during the next five years, in order to update the
permit.
State Decree 47397, issued on December 04, 2002 modify State Decree 8468/76
and establishes deadlines for installation and operating permits applications,
expiration dates of operating permits and the fees charged for issuing a
permit.
State Decree 47400/02 issued on December 04, 2002 regulates State Law
9505/97 and establishes expiration dates for each type of environmental
permit and the conditions for the permit renewal. The Operating Permit will
be valid for a period ranging from 2 to a maximum of 10 years.
Article 5 of State Decree 47400/02 establishes that facilities subjected to
environmental permits must communicate with the environmental agency the
suspension and closure of their activities, through a Deactivation Plan. The
Deactivation Plan must contain the environmental situation of the site and the
measures implemented to recover or remediate the site. A final report must be
submitted to the environmental agency after the completion of the
remediation activities. The decree also establishes the schedule and prices for
review of the deactivation process.
SMA Resolution 22/07 establishes the unification and integration of
environmental permitting in the State of São Paulo, and also modifies
permitting procedures for those activities listed in its attachments. The
intermodal Terminal in Pederneiras will be managed and operated by a third
party company which will be responsible for all environmental licensing
procedures as detailed below.
3.4
PORT LICENSING
There are different agencies with responsibilities related to environmental
controls 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 the
environment and perform the licensing of activities that modify the
environment; and the Federal Environmental Agency, IBAMA which is also
responsible for environmental licensing.
The Board of IBAMA Environmental Licensing, along with some state
environmental agencies (OEMA), are adopting the criteria of location in the
territorial sea or internal waters for the definition of competence of jurisdiction
of environmental agencies to conduct the environmental permits for ports. To
do so, they are using the demarcation of straight baselines established by
Federal Decree 4.983/2004.
It is clear that, in accordance with Article 1 of Federal Law nº 8.617/1993, the
Brazilian territorial sea is a belt of twelve nautical miles wide, measured from
the low tide line of the coastal mainland and islands, as indicated in largescale charts officially recognized in Brazil. In locations where the coastline is
indented and cut deep or where there is a fringe of islands along the coast in
its immediate vicinity, it is adopted the method of straight baselines
connecting the appropriate points for drawing the baseline, from which to
measure the extent of territorial sea.
According to the Federal Decree 4.983/2004, in all other parts of the mainland
and island coasts of Brazil, where there were delimited straight baselines, are
adopted Baseline Standard, as indicated in the large scale charts published by
the Board Hydrography and Navigation of the Navy of Brazil. Also according
to its Article 4, the Straight and Normal Baselines should be used only as a
source for the trace of the outer limits of the territorial sea, the contiguous
zone, exclusive economic zone and continental shelf, whose concepts are
specified in the Act No 8.617/1993.
Regarding the definition of internal waters, it can be found in the Federal Law
9.966/2000 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 sea
is measured;

waters of the ports;

of the bays;

the rivers and their estuaries;

of lakes, ponds and canals;

of the islands; and

the waters from the shallows and the discovery coast.
Thus, in the case of the Port of Santos, both the port itself and the disposal
area where oceanic sediments are disposed of dredging are located under the
legal point of view, in internal waters. Therefore, it is possible to conclude that
the licensing outside the organized port (which will be the temporary
warehouse managed and owned by a third party company and also
warehouses III, VIII, XIII and XVIII purchased by ELDORADO) is the state
environmental agency (Cetesb) responsibility under the management of
Management Port Authority (Codesp).
In accordance with the provisions of federal and state environmental
legislation (mainly the CONAMA Resolution 237/1997 and the State Decree
47.400/2002) Cetesb sets out the developments and port activities to be
licensed.
The permanent areas of the organized port, warehouses IX to XII, are licensed
under Federal Environmental Agency (IBAMA).
3.5
ENVIRONMENTAL LICENSING STATUS
Aparecida do Taboado - MS
As previously explained, ELDORADO acquired a parcel of land, with 61.7
hectares, which was part of a farm (Fazenda Boa Esperança) to build the
multimodal terminal in Aparecida do Taboado, in Mato Grosso do Sul state.
Reportedly, the area in which the warehouses will be built is approximately
from 7,000 to 8,000m². Therefore, ELDORADO has hired Poyry Silviconsult in
order to develop the Simplified Environmental Report-RAS required for
issuance of Preliminary License. The study was developed and reportedly
submitted to the state environmental agency IMASUL. The study is being
analyzed by IMASUL, in order to provide the preliminary license or request
further clarifications/complements before issuing such license.
Reportedly, the adjustments of the railway extension access and all licensing
procedures in Aparecida do Taboado, will be performed by ELDORADO. This
includes eventual vegetation suppression with its compensations. ALL
(América Latina Logística) will be responsible to transport the pulp and paper
from Aparecida do Taboado to the Port of Santos according contract
agreement already signed with ELDORADO.
Pederneiras - SP
Reportedly, a warehouse will be constructed by ELDORADO, with
approximately 6,000-m² covered area, in Pederneiras. ELDORADO has hired
EGTM Navegação (Torque) which already owns a multimodal terminal and
will expand its boundaries in other to meet the demand.
Regarding this company hired to work in logistics waterways of cellulose, it
was reported that the Service Agreement signed by the parties on December
22, 2011 has an item referring that EGTM Navegação (Torque) agrees to
observe and comply with environmental legislation, being responsible for
fines and notices of violation of activities directly related to the transportation
of cellulose, and is responsible for obtaining and maintaining any permits or
licenses required by public agencies, due to the object of the contract.
Therefore, ELDORADO declares that has no responsibility regarding permits
or licensing of the area.
Reportedly, the adjustments of the railway extension access in Pederneiras,
will be performed MRS LOGÍSTICA S.A. As reported, the licensing
procedures and eventual vegetation suppression with its compensations will
be managed by this company.
Santos-SP
The port of Santos is a logistic complex, with countless facilities, with a share
of 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 the
organized area of the port. These private companies have the useful domain of
the area where they are.
The port is equipped with rail to rail transit and railroads that serve it, and has
places 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 currently
going through a regularization process and has been granted with the
Installation License nº 852/2011 on December 23, 2011.
Reportedly, the railway to be used by the leased land is property of MRS
LOGÍSTICA S.A. According information provided during interview with
ELDORADO staff, in order to build the rail extension needed for wagons
maneuver, approximately 1.5km, the state agency would require an expansion
plan from MRS. The area is close to mangrove vegetation considered as
preservation area by the Brazilian Environmental Legislation (Forest Code).
Therefore, it is possible that MRS be subjected to compensation plans for the
suppression areas.
The temporary warehouse, in which was established a service provision
contract out of the organized port of Santos, is owned by Hipercon Terminais
de Cargas Ltda which currently has installation license according information
provided on Cetesb’s website. ELDORADO has informed that the area will be
operated by this company which will be responsible for obtaining and
maintaining environmental permits and licenses, as well as for complying
with the environmental legislation. Reportedly, the area of warehouses III,
VIII, XIII and XVIII, inside the previously mentioned Elmar Terminal, has
been purchased by ELDORADO from Rodrimar S/A Transportes
Equipamentos Industriais e Armazéns Gerais. Evidence has not been
provided. Operating permits for warehouses III and VIII are currently under
Rodrimar’s name, according information on Cetesb’s website. Operating
permit for warehouse III nº18001394 has been issued on 28/12/2009 and is
valid until 28/12/2013; operating permit for warehouse VIII nº 18001731 has
been issued on 03/10/2011 and is valid until 13/07/2014. No information has
been provided regarding changes in the corporate name of these permits.
Regarding the permanent warehouses IX to XII, ELDORADO has provided
the Letter of introduction of the project of Port Terminal Eldorado Brazil /
Santos-SP Portway submitted to IBAMA on 22/03/2011 showing that the
following 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; and

Plant of the future passenger terminal in Santos/ SP.
According to IBAMA’s website, Terminal Eldorado Brasil (regarding
warehouses IX to XII) is in the initial phase of licensing and has requested
term of reference; however the area is still waiting for bidding from CODESP.
Annex C
Gap Analysis Table – Pulp
and Paper Industrial Project
Review against IFC Performance Standard 1 (Environmental and Social Management and Evaluation Systems)
No:
Requirements of IFC PS 1
Related PS
Requirements, EHS
Guidelines (General,
Pulp and Paper) and
Legal Standards
Compliance Status/ Findings
Recommended further actions
The client, in coordination with other responsible government agencies
and third parties as appropriate, will conduct a process of
environmental and social assessment, and establish and maintain an
ESMS (Environmental and Social Management System) appropriate to
the nature and scale of the project and commensurate with the level of
its environmental and social risks and impacts. 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 preparedness and response; (vi)
stakeholder engagement; and (vii) monitoring and review.
PARTIALLY COMPLIANT
According to EIA, the project did evaluate environmental and social
impacts of the project, and mitigation measures were defined for all impacts
identified. The Environmental Basic Plan -PBA and PBA reports presented
detailed these programs and demonstrate the implementation of the
construction programs until the end of 2011. Programs associated with the
operation will start, reportedly, on November 2012. According to
information given on site visit the management of the programs is held by
two third-party companies currently in charge of the site operation, Meta
and DuPont. Reportedly, ELDORADO will take over the management of
the PBA’s implementation and the site management when the operational
license is issued. Guidance for third party companies is provided by a
document called Health and Safety and Environment of contracted and
subcontracted companies Book.
ELDORADO does not conduct due diligence to monitor third party
companies in charge of the site management.
For third companies in charge of the site infrastructure project, a report is
developed in monthly basis by DuPont and Meta and presented to
ELDORADO and the companies. Report includes indicators associated with
people management, health and safety, environmental, quality and
schedule.
ELDORADO has not implemented formal environmental management
system, but there are some aspects of management developed and
developing, as eg mission, vision, values (implemented and available on
company’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 considered
in line with good international practice for pulp and paper mills.
ELDORADO should implement a system to monitor third party companies in
charge of the site management.
The client will establish an overarching policy defining the
PS 1, paragraph 6
environmental and social objectives and principles that guide the
project to achieve sound environmental and social performance. The
policy provides a framework for the environmental and social
assessment and management process, and specifies that the project (or
business activities, as appropriate) will comply with the applicable
laws and regulations of the jurisdictions in which it is being
undertaken, including those laws implementing host country
obligations under international law. The policy should be consistent
with the principles of the Performance Standards. Under some
circumstances, clients may also subscribe to other internationally
recognized standards, certification schemes, or codes of practice and
these too should be included in the policy. The policy will indicate
who, within the client’s organization, will ensure conformance with the
policy and be responsible for its execution (with reference to an
appropriate responsible government agency or third party, as
necessary). The client will communicate the policy to all levels of its
organization.
COMPLIANT
None.
According to information available on the company’s website and on the
Forest Management Plan, a sustainability policy, mission, vision and values
have been developed and disclosed publicly.
5.
ELDORADO should integrate the existing practices in a management system,
that shall include:
(i) Training program for employees and contractors with direct responsibility
for activities relevant to social and environmental performance of the project;
Policy
6.
ELDORADO – APRIL 2012
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Identification of Risks and Impacts
7.
The client will establish and maintain a process for identifying the
PS 1, paragraph 7
environmental and social risks and impacts of the project (see
paragraph 18 for competency requirements). The type, scale, and
location of the project guide the scope and level of effort devoted to the
risks and impacts identification process. The scope of the risks and
impacts identification process will be consistent with good
international industry practice, and will determine the appropriate and
relevant methods and assessment tools. The process may comprise a
full-scale environmental and social impact assessment, a limited or
focused environmental and social assessment, or straightforward
application of environmental siting, pollution standards, design
criteria, or construction standards. When the project involves existing
assets, environmental and/or social audits or risk/hazard assessments
can be appropriate and sufficient to identify risks and impacts. If assets
to be developed, acquired or financed have yet to be defined, the
establishment of an environmental and social due diligence process
will identify risks and impacts at a point in the future when the
physical elements, assets, and facilities are reasonably understood. The
risks and impacts identification process will be based on recent
environmental and social baseline data at an appropriate level of detail.
The process will consider all relevant environmental and social risks
and impacts of the project, including the issues identified in
Performance Standards 2 through 8, and those who are likely to be
affected by such risks and impacts. The risks and impacts identification
process will consider the emissions of greenhouse gases, the relevant
risks associated with a changing climate and the adaptation
opportunities, and potential transboundary effects, such as pollution of
air, or use or pollution of international waterways.
COMPLIANT
None
The Environmental Impact Assessment (EIA) Study for the project was
developed on 2009 by DMB Construtora e Assessoria Técnica Ltda. and
considers the impacts related to the planning, implementation and
operation of the project.
The EIA did not evaluate the impacts for the decommissioning phase of the
plant, nor has presented a justification for not performing this assessment.
However, ERM understands that this is not a non compliance situation, as
the project has a long lifecycle.
The study has been approved by the environmental agency and the
preliminary license LP has been issued.
8.
Where the project involves specifically identified physical elements,
PS 1, paragraphs 8, 9
aspects, and facilities that are likely to generate impacts, environmental
and social risks and impacts will be identified in the context of the
project’s area of influence. This area of influence encompasses, as
appropriate:
 The area likely to be affected by: (i) the project and the client’s
activities and facilities that are directly owned, operated or
managed (including by contractors) and that are a component of the
project; (ii) impacts from unplanned but predictable developments
caused by the project that may occur later or at a different location;
or (iii) indirect project impacts on biodiversity or on ecosystem
services upon which Affected Communities’ livelihoods are
dependent.
 Associated facilities, which are facilities that are not funded as part
of the project and that would not have been constructed or
expanded if the project did not exist and without which the project
would not be viable.
Cumulative impacts that result from the incremental impact, on areas
or resources used or directly impacted by the project, from other
existing, planned or reasonably defined developments at the time the
risks and impacts identification process is conducted.
PARTIALLY COMPLIANT
The EIA has defined the projects areas: direct influence area, indirect
influence area and directly affected area. However, these areas do not
encompass impacts from unplanned but predictable developments caused
by the project that may occur later or at a different location; or indirect
project impacts on biodiversity or on ecosystem services upon which
Affected Communities’ livelihoods are dependent.
The EIA does not include the study of associated facilities neither assess
cumulative impacts from other existing, planned or reasonably defined
developments.
The risks and impacts identification process did not consider the emissions
of greenhouse gases.
9.
In the event of risks and impacts in the project’s area of influence
resulting from a third party’s actions, the client will address those risks
and impacts in a manner commensurate with the client’s control and
influence over the third parties, and with due regard to conflict of
interest.
Please see paragraph PS1, paragraph 5.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 1, paragraph 10
COMPLIANT
None.
There are several contractors in charge of the industrial infrastructure
project. ELDORADO has developed a management structure to supervise
these third part companies and their workers.
A company hired by ELDORADO, named Meta, is in charge to manage all
aspects associated with contractor’s workers. DuPont is in charge to
manage all health and safety aspects associated with the project.
Meta verifies the documentation of all workers that have access to the site
to identify compliance with Brazilian legislation.
An Align Meeting is held every 60 days with all the companies involved in
the project installation. Demands are raised and a work plan is developed.
ELDORADO does not conduct due diligence to monitor third party
companies in charge of the site management.
The feedstock for the pulp production will be obtained by eucalyptus
planted at ELDORADO´s farms (owned lands, leased and partnership
agreements). Wood will be supplied by third parties until 2016.
Refer to PS2 and PS6 for further information about supply chain
management.
10.
Where the client can reasonably exercise control, the risks and
impacts identification process will also consider those risks and
impacts associated with primary supply chains, as defined in
Performance Standard 2 (paragraphs 27–29) and Performance
Standard 6 (paragraph 30).
11.
Where the project involves specifically identified physical elements, PS 1, paragraph 11
aspects and facilities that are likely to generate environmental and
social impacts, the identification of risks and impacts will take into
account the findings and conclusions of related and applicable
plans, studies, or assessments prepared by relevant government
authorities or other parties that are directly related to the project and
its area of influence. These include master economic development
plans, country or regional plans, feasibility studies, alternatives
analyses, and cumulative, regional, sectoral, or strategic
environmental assessments where relevant. The risks and impacts
identification will take account of the outcome of the engagement
process with Affected Communities as appropriate.
Refer to PS1, paragraph 8 and 9.
None
12.
Where the project involves specifically identified physical elements, PS 1, paragraph 12
aspects and facilities that are likely to generate impacts, and as part
of the process of identifying risks and impacts, the client will
identify individuals and groups that may be directly and
differentially or disproportionately affected by the project because of
their disadvantaged or vulnerable status. Where individuals or
groups are identified as disadvantaged or vulnerable, the client will
propose and implement differentiated measures so that adverse
impacts do not fall disproportionately on them and they are not
disadvantaged in sharing development benefits and opportunities.
PARTIALLY COMPLIANT
There is a detailed socio economic evaluation and community profile, but
it does not identify potential vulnerable groups that may be differentially
or disproportionately affected by the project because of their
disadvantaged or vulnerable status.
Identify any potential group that may be differentially or disproportionately
affected by the expansion project and implement differentiated measures so
that adverse impacts do not fall disproportionately on them and they are not
disadvantaged in sharing development benefits and opportunities. If no group
is identified as vulnerable or differentially affected, this should be
documented (a brief statement to this fact is sufficient with supporting data).
According to IFC disadvantage or vulnerable status may stem from an
individual’s or group’s race, color, sex, language, religion, political or
other opinion, national or social origin, property, birth, or other status. It
shall 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.
There may be individuals or groups within the project’s area of influence
who are particularly vulnerable or disadvantaged and who could
experience adverse impacts from the proposed project more severely than
others. Large-scale projects with a large area of influence and multiple
Affected Communities are more likely to expose these individuals and
groups to adverse impacts than smaller-scale projects with site-specific
issues.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 1, paragraphs 13 to 16
COMPLIANT
Environmental and social management and monitoring procedures as
well as mitigation measures have been proposed in the EIA report in
response to the identified relevant impacts. The PBA and PBA reports
presented detail these programs and demonstrate their implementation
until the end of 2011.
An implementation schedule or timeline showing status of programs and
activities to be done could illustrate the progress.
Management Programs
13.
Consistent with the client’s policy and the objectives and principles
described therein, the client will establish management programs
that, in sum, will describe mitigation and performance
improvement measures and actions that address the identified
environmental and social risks and impacts of the project.
In addition to the PBA, ELDORADO shall define other measures to address
the recommendations described in this document.
Management Programs
14.
Depending on the nature and scale of the project, these programs
may consist of some documented combination of operational
procedures, 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 the
organization has control or influence, or to specific sites, facilities,
or activities. The mitigation hierarchy to address identified risks
and impacts will favor the avoidance of impacts over minimization,
and, where residual impacts remain, compensation/offset,
wherever technically and financially feasible
15.
Where the identified risks and impacts cannot be avoided, the client
will identify mitigation and performance measures and establish
corresponding actions to ensure the project will operate in
compliance with applicable laws and regulations, and meet the
requirements of Performance Standards 1 through 8. The level of
detail and complexity of this collective management program and
the priority of the identified measures and actions will be
commensurate with the project’s risks and impacts, and will take
account of the outcome of the engagement process with Affected
Communities as appropriate.
16.
The management programs will establish environmental and social
Action Plans, which will define desired outcomes and actions to
address the issues raised in the risks and impacts identification
process, as measurable events to the extent possible, with elements
such as performance indicators, targets, or acceptance criteria that
can be tracked over defined time periods, and with estimates of the
resources and responsibilities for implementation. As appropriate,
the management program will recognize and incorporate the role of
relevant actions and events controlled by third parties to address
identified risks and impacts. Recognizing the dynamic nature of the
project, the management program will be responsive to changes in
circumstances, unforeseen events, and the results of monitoring and
review.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
and 19
PARTIALLY COMPLIANT
Reportedly, specific personnel have been assigned for roles and
responsibilities within the environmental and social aspects of the project.
Currently, as reported on paragraph 5,the third part companies DuPont
and Meta are in charge of the implementation of the PBA. ELDORADO
will take over the management programs once the operation license is
issued.
Guidance for third party companies is provided by a document called
Health and Safety and Environment of contracted and subcontracted
companies Book. Documents on site were provided in order to evidence
management control of third party companies in regards to environmental
and social performance. A training matrix was developed to identify legal
training for each work category. Those legal required training does not
cover the aspects treated by this performance standard, specially the social
aspects.
Most of the staff interviewed people reported previous experience on
similar paper, pulp and forest companies.
External experts have been hired in order to perform the Environmental
Impact Assessment Study. Refer to PS 1, paragraph 7.
To develop training program to support the designated personnel to carry out
their part of the ESMS. The training program shall ensure consistence with
ELDORADO policies and procedures. The training can be formal, informal
(on-the-job), one-time, periodic, etc. The program must include third parties
with direct responsibility with activities relevant to the environmental and
social performance of the project, for example, wood suppliers, rural workers
supplier, etc.
Organizational Capacity and Competency
17.
The client, in collaboration with appropriate and relevant third
parties, will establish, maintain, and strengthen as necessary an
organizational structure that defines roles, responsibilities, and
authority to implement the ESMS. Specific personnel, including
management representative(s), with clear lines of responsibility and
authority should be designated. Key environmental and social
responsibilities should be well defined and communicated to the
relevant personnel and to the rest of the client’s organization.
Sufficient management sponsorship and human and financial
resources will be provided on an ongoing basis to achieve effective
and continuous environmental and social performance.
18.
Personnel within the client’s organization with direct responsibility
for the project’s environmental and social performance will have the
knowledge, skills, and experience necessary to perform their work,
including current knowledge of the host country’s regulatory
requirements and the applicable requirements of Performance
Standards 1 through 8. Personnel will also possess the knowledge,
skills, and experience to implement the specific measures and actions
required under the ESMS and the methods required to perform the
actions in a competent and efficient manner.
19.
The process of identification of risks and impacts will consist of an
adequate, accurate, and objective evaluation and presentation,
prepared by competent professionals. For projects posing potentially
significant adverse impacts or where technically complex issues are
involved, clients may be required to involve external experts to assist
in the risks and impacts identification process.
Emergency Preparedness and Response
20.
PS 1, paragraph 20, 21
aspects and facilities that are likely to generate impacts, the ESMS
PS4, paragraph 11
will establish and maintain an emergency preparedness and response
system so that the client, in collaboration with appropriate and
relevant third parties, will be prepared to respond to accidental and
emergency situations associated with the project in a manner
appropriate to prevent and mitigate any harm to people and/or the
environment. This preparation will include the identification of areas
where accidents and emergency situations may occur, communities
and individuals that may be impacted, response procedures,
provision of equipment and resources, designation of responsibilities,
communication, including that with potentially Affected
Communities and periodic training to ensure effective response. The
emergency preparedness and response activities will be periodically
reviewed and revised, as necessary, to reflect changing conditions.
PARTIALLY COMPLIANT
Emergency Plan should be communicated to affected community and
relevant governmental authorities with responsibility on emergency
CONSTRUCTION STAGE AND OPERATION STAGE
The contractor DuPont, which was hired to manage health and safety issues situations, e.g, local police, hospitals, fire department, etc.
during the construction stage, developed an Emergency Response Plan for
the construction works. Several accident scenarios have been considered,
such as chemicals release, fire and accidents involving employees, among
others. Emergency procedures 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 completed
and adapted for the operation stage.
The risk analysis developed for the pulp mill has not indicated accident
scenarios with the potential to affect external communities
ELDORADO informed to have identified local governmental structure to
act in emergency situations. PBA includes plans to support public security
and public health infrastructures.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
21.
Where applicable, the client will also assist and collaborate with the
potentially Affected Communities (see Performance Standard 4) and
the local government agencies in their preparations to respond
effectively to emergency situations, especially when their
participation and collaboration are necessary to ensure effective
response. If local government agencies have little or no capacity to
respond effectively, the client will play an active role in preparing for
and responding to emergencies associated with the project. The client
will document its emergency preparedness and response activities,
resources, and responsibilities, and will provide appropriate
information to potentially Affected Community and relevant
government agencies.
Monitoring and Review
22.
The client will establish procedures to monitor and measure the
PS 1, paragraphs 22 and
effectiveness of the management program, as well as compliance with 23
any related legal and/or contractual obligations and regulatory
requirements. Where the government or other third party has
responsibility for managing specific risks and impacts and associated
mitigation measures, the client will collaborate in establishing and
monitoring such mitigation measures. Where appropriate, clients will
consider involving representatives from Affected Communities to
participate in monitoring activities. The client’s monitoring program
should be overseen by the appropriate level in the organization. For
projects with significant impacts, the client will retain external
experts to verify its monitoring information. The extent of monitoring
should be commensurate with the project’s environmental and social
risks and impacts and with compliance requirements.
23.
In addition to recording information to track performance and
establishing relevant operational controls, the client should use
dynamic mechanisms, such as internal inspections and audits, where
relevant, to verify compliance and progress toward the desired
outcomes. Monitoring will normally include recording information to
track performance and comparing this against the previously
established benchmarks or requirements in the management
program. Monitoring should be adjusted according to performance
experience and actions requested by relevant regulatory authorities.
The client will document monitoring results and identify and reflect
the necessary corrective and preventive actions in the amended
management program and plans. The client, in collaboration with
appropriate and relevant third parties, will implement these
corrective and preventive actions, and follow up on these actions in
upcoming monitoring cycles to ensure their effectiveness.
24.
Senior management in the client organization will receive periodic
performance reviews of the effectiveness of the ESMS, based on
systematic data collection and analysis. The scope and frequency of
such reporting will depend upon the nature and scope of the
activities identified and undertaken in accordance with the client’s
ESMS and other applicable project requirements. Based on results
within these performance reviews, senior management will take the
necessary and appropriate steps to ensure the intent of the client’s
policy is met, that procedures, practices, and plans are being
implemented, and are seen to be effective.
PS 1, paragraph 24
PARTIALLY COMPLIANT
The PBA describes the activities, monitoring activities and the purpose of it,
that the site intends to implement in order to mitigate or manage
environmental impacts. PBA reports evidence that these monitoring
activities have been initiated. See PS 1, paragraphs 13 to 16.
Neither the PBA nor related reports measure the effectiveness of the
programs implemented.
COMPLIANT
The Sustainability Manager responds direct to ELDORADO’s CEO and has
direct and frequent access to him. Information about license process and
stakeholder relations is disclosed at the directors meetings.
Once a week and once a month there are meetings about the project
installation and a report is disclosed to the directors of the company.
Every 60 days an Align Meeting is held with all the companies involved in
the project installation. Demands are raised and a work plan is developed.
Develop measures to monitor measures to mitigate/control socio-economic
impacts.
Develop measures to evaluate effectiveness of the implemented programs.
Define measure to identify and monitor impacts on community health and
safety (refer to PS4 for further recommendation).
affected by the project and implement differentiated measures so that
adverse impacts do not fall disproportionately on them and they are not
disadvantaged in sharing development benefits and opportunities. If no
group is identified as vulnerable or differentially affected document (a brief
statement to this fact is sufficient) and justify so.
None
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PARTIALLY COMPLIANT
ELDORADO has following practices on stakeholder engagement:
 Stakeholders mapping and identification, mostly through the social
economic diagnosis; Consultation to local governmental
representatives to identify projects that can be supported by
ELDORADO;
 Consultation of a sample of citizens to identify vulnerability of the
region as part of the social economic diagnosis; Consultation of
community members to identify areas of high conservation valour and
their dependence toward it.as part of the inventory of areas of high
conservation;
 Identification of land neighbors as part of the PTEAS;
 A public hearing will be carried out for the purpose of forest
certification. The Forest Management Plan will be public disclosure;
and
 A community relationship plan is being developed.
To systematize the stakeholders identification and contact information, to
enable evaluation of stakeholder and classification according the following:
 Stakeholders affected by ELDORADO, positively and negatively, directly
and indirectly, particularly those directly and adversely affected by project
activities, including those that are disadvantaged or vulnerable;
 Stakeholders who may be able to influence the outcome of the project
because of their knowledge about the affected communities or political
influence over them;
 Legitimate stakeholders representatives, including elected officials, nonelected community leaders, leader of informal or traditional community
 Stakeholders not directly affected by the project but may have the ability to
influence or alter the relationship of the client with the affected
community.
If the impact and risk identification process define that the community will be
affected by ELDORADO, Stakeholder Engagement Plan is required. This
should include:
 risks and impacts,
 identification, characterization and priority of stakeholders, focusing on
those directly affected by the project and vulnerable groups,
 grievance mechanism (refer to PS1, paragraph 35)
 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 operation to affected community.
Information about risks and impacts identified, mitigation measures shall be
periodically disclosure to affected community, at least annually, as long the
specific items in the management programs. ELDORADO may consider using
sustainability report on the financial, environmental and social aspects to
report so.
Stakeholder Engagement
25.
Stakeholder engagement is the basis for building strong, constructive, PS 1, paragraph 25
and responsive relationships that are essential for the successful
management of a project's environmental and social impacts.
Stakeholder engagement is an ongoing process that may involve, in
varying degrees, the following elements: stakeholder analysis and
planning, disclosure and dissemination of information, consultation
and participation, grievance mechanism, and ongoing reporting to
Affected Communities. The nature, frequency, and level of effort of
stakeholder engagement may vary considerably and will be
commensurate with the project’s risks and adverse impacts, and the
project’s phase of development.
None of the above mentioned initiatives were undertaken to 2 Irmãos do
Buruti and Anastacio municipalities.
ELDORADO does not have a systematic approach to consult or to engage
stakeholders neither, for which this item is rated partial.
.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PARTIALLY COMPLIANT
Refer to PS1 paragraph 25.
NOT APPLICABLE
The project location is known.
None
Stakeholder Analysis and Engagement Planning
26.
Clients should identify the range of stakeholders that may be
PS 1, paragraph 26 and 27
interested in their actions and consider how external communications
might 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 adverse
environmental and social impacts to Affected Communities the client
will identify the Affected Communities and will meet the relevant
requirements described below.
27.
The client will develop and implement a Stakeholder Engagement
Plan that is scaled to the project risks and impacts and development
stage, and be tailored to the characteristics and interests of the
Affected Communities. Where applicable, the Stakeholder
Engagement Plan will include differentiated measures to allow the
effective participation of those identified as disadvantaged or
vulnerable. When the stakeholder engagement process depends
substantially on community representatives, the client will make
every reasonable effort to verify that such persons do in fact
represent the views of Affected Communities and that they can be
relied upon to faithfully communicate the results of consultations to
their constituents.
28.
In cases where the exact location of the project is not known, but it is PS 1, paragraph 28
reasonably expected to have significant impacts on local
communities, the client will prepare a Stakeholder Engagement
Framework, as part of its management program, outlining general
principles and a strategy to identify Affected Communities and other
relevant stakeholders and plan for an engagement process
compatible with this Performance Standard that will be implemented
once the physical location of the project is known.
Disclosure of Information
29.
Disclosure of relevant project information helps Affected
Communities and other stakeholders understand the risks, impacts
and opportunities of the project. The client will provide Affected
Communities with access to relevant information on: (i) the purpose,
nature, and scale of the project; (ii) the duration of proposed project
activities; (iii) any risks to and potential impacts on such
communities and relevant mitigation measures; (iv) the envisaged
stakeholder engagement process; and (v) the grievance mechanism.
PS 1, paragraph 29
PARTIALLY COMPLIANT
Public hearing was held to disclosure information about the EIA and the
PBA as part of the licensing process. Public meetings were held before it to
identify community concerns about the project.
 Internal newspaper to workers
There is no systematic to update the information disclosure to the affected
communities.
For information about the grievance mechanism, refer to PS1, paragraph
35.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 1, paragraph 30
PARTIALLY COMPLIANT
Systemize the stakeholder identification, consultation and engagement
process, as described on Refer to PS1, paragraph 25.
ELDORADO has the following initiatives to consultation:
 For the purpose of social economic diagnosis, a sample of citizens
were interviewed to identify vulnerability of the region;
 For the Inventory of Areas of High Biodiversity, stakeholders
were consulted to identify the areas of high biodiversity
important to the community and the use of it;
 As a result of the local vulnerabilities identified at the social
economic diagnosis, local governmental representatives were
consulted by ELDORADO to identify projects that could be
supported by ELDORADO;
 Public hearings and meetings with stakeholders were held for
license purpose.
Consultation
30.
When Affected Communities are subject to identified risks and
adverse impacts from a project, the client will undertake a process of
consultation in a manner that provides the Affected Communities
with opportunities to express their views on project risks, impacts
and mitigation measures, and allows the client to consider and
respond to them. The extent and degree of engagement required by
the consultation process should be commensurate with the project’s
risks and adverse impacts and with the concerns raised by the
Affected Communities. Effective consultation is a two-way process
that should: (i) begin early in the process of identification of
environmental and social risks and impacts and continue on an
ongoing basis as risks and impacts arise; (ii) be based on the prior
disclosure and dissemination of relevant, transparent, objective,
meaningful and easily accessible information which is in a culturally
appropriate local language(s) and format and is understandable to
Affected Communities; (iii) focus inclusive engagement on those
directly affected as opposed to those not directly affected; (iv) be free
of external manipulation, interference, coercion, or intimidation; (v)
enable meaningful participation, where applicable; and (vi) be
documented. The client will tailor its consultation process to the
language preferences of the Affected Communities, their decisionmaking process, and the needs of disadvantaged or vulnerable
groups. If clients have already engaged in such a process, they will
provide adequate documented evidence of such engagement.
The consultation process is not systemized and it was not defined
frequency of consultation
Informed Consultation and Participation
31.
For projects with potentially significant adverse impacts on Affected PS 1, paragraph 31
Communities, the client will conduct an Informed Consultation and
Participation (ICP) process that will build upon the steps outlined
above in Consultation and will result in the Affected Communities’
informed participation. ICP involves a more in-depth exchange of
views and information, and an organized and iterative consultation,
leading to the client’s incorporating into their decision-making
process the views of the Affected Communities on matters that affect
them directly, such as the proposed mitigation measures, the sharing
of development benefits and opportunities, and implementation
issues. The consultation process should (i) capture both men’s and
women’s views, if necessary through separate forums or
engagements, and (ii) reflect men’s and women’s different concerns
and priorities about impacts, mitigation mechanisms, and benefits,
where appropriate. The client will document the process, in
particular the measures taken to avoid or minimize risks to and
adverse impacts on the Affected Communities, and will inform those
affected about how their concerns have been considered.
PARTIALLY COMPLIANT
For the ELDORADO industrial project a public hearing was held for
license purpose and, previously to the public hearing, public meetings
identified stakeholders concerns. The public hearing disclosure
information about the project, impacts identified through EIA and
mitigation plans.
ELDORADO communication procedure does not include systematic
consultation to stakeholders.
For the purpose of this IFC assessment, one neighbor of the
Accommodation I, located at Tres Lagoas, was interviewed. The
accommodation has capacity to accommodate 1920 workers.
The neighbor informed that he was not disturbed by the closeness to the
accommodation. He reported to know that ELDORADO is a paper and
pulp project and to have good expectation about the project because of its
economic impacts. He also reported that he had never been contacted,
informed or consulted by ELDORADO
This consultation process is not systematically defined, as such this item is
rated partial.
Refer to PS1, paragraph 26, 27.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 1, paragraph 32
COMPLIANT
Archeological survey has been conducted in December 2011, and
identified that there was no indigenous groups or traditional people
affected by ELDORADO’s operation at Três Lagoas.
None
NOT APPLICABLE
None
Indigenous Peoples
32.
For projects with adverse impacts to Indigenous Peoples, the client is
required to engage them in a process of ICP and in certain
circumstances the client is required to obtain their Free, Prior, and
Informed Consent (FPIC). The requirements related to Indigenous
Peoples and the definition of the special circumstances requiring
FPIC are described in Performance Standard 7.
Private Sector Responsibilities Under Government-Led Stakeholder Engagement
33.
Where stakeholder engagement is the responsibility of the host
PS 1, paragraph 33
government, the client will collaborate with the responsible
government agency, to the extent permitted by the agency, to achieve
outcomes that are consistent with the objectives of this Performance
Standard. In addition, where government capacity is limited, the
client will play an active role during the stakeholder engagement
planning, implementation, and monitoring. If the process conducted
by the government does not meet the relevant requirements of this
Performance Standard, the client will conduct a complementary
process and, where appropriate, identify supplemental actions.
External Communications
34.
Clients will implement and maintain a procedure for external
PS 1, paragraph 34
communications that includes methods to (i) receive and register
external communications from the public; (ii) screen and assess the
issues raised and determine how to address them; (iii) provide, track,
and document responses, if any; and (iv) adjust the management
program, as appropriate. In addition, clients are encouraged to make
publicly available periodic reports on their environmental and social
sustainability.
PARTIALLY COMPLIANT
Refer to PS1, paragraphs 25 above and 35, below.
The ELDORADO site’s has a channel to receive communication through email or telephone number. ELDORADO did not inform the procedure to
treat grievance received through this channel, neither how community is
informed about this mechanism.
Refer to paragraph 35 for grievance mechanism.
Grievance Mechanism for Affected Communities
35.
Where there are Affected Communities, the client will establish a
PS 1, paragraph 35
grievance mechanism to receive and facilitate resolution of Affected
Communities’ concerns and grievances about the client’s
environmental and social performance. The grievance mechanism
should be scaled to the risks and adverse impacts of the project and
have Affected Communities as its primary user. It should seek to
resolve concerns promptly, using an understandable and transparent
consultative process that is culturally appropriate and readily
accessible, and at no cost and without retribution to the party that
originated the issue or concern. The mechanism should not impede
access to judicial or administrative remedies. The client will inform
the Affected Communities about the mechanism in the course of the
stakeholder engagement process.
PARTIALLY COMPLIANT
 Internal newspaper to workers
 Disclosure of information at local radios and journal.
Besides, forums and public hearings were held for the purpose of the
industry license process and disclosure information about the EIA and
PBA and identified community concerns about the project.
ELDORADO site’s has a channel to receive communication through e-mail
or telephone number.
There are mechanisms in place for grievance and to register
communication received from stakeholders:
 There is a form to register external communication from the
public. Community and neighbor might contact ELDORADO’s
office in each municipality, a telephone number, the supervisor of
the 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 contact
and action taken. Once complete, the form is delivered to one
person in charge to receive it. The complaint is registered in a
spreadsheet that contains the name of the person, data, who
received the complaint, a description of the complaint, action
taken, feedback and data.
 There is an ombudsman for industrial workers grievance
(employees and contractor’s worker).
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 and
stakeholders can complain to ELDORADO.
ELDORADO should guarantee that the grievance mechanism for affected
community contains the following:
 the grievance mechanism must be available to all stakeholders:
workers (employee, contractors, suppliers), suppliers, affected
community, and other significant categories identified by
ELDORADO;
 it shall be culturally appropriate, readily accessible to all workers,;
 it must be defined roles and responsibilities for receiving the
grievance and communication flow;
 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 to security personnel abuses.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
35.
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 the
accommodation;
 Telephone number
 E-mail
Grievances are registered and are treated by the Ombudsman, who is the
person in charge of the contractors’ workers management. Grievance is
analyzed, investigated, and feedback is provided to the worker by the
social assistant. In case of anonymous grievance, the respond is disclosure
on a board available close to the cafeteria.
Information about the ombudsman is disclosed in the Manual for
Induction and banners at the site.

The Eldorado site’s has a channel to receive communication through email or telephone number. ELDORADO did not provided information
about the structure of the grievance mechanism to stakeholders.
36.
The client will provide periodic reports to the Affected Communities PS 1, paragraph 36
that describe progress with implementation of the project Action
Plans on issues that involve ongoing risk to or impacts on Affected
Communities and on issues that the consultation process or grievance
mechanism have identified as a concern to those Communities. If the
management program results in material changes in or additions to
the mitigation measures or actions described in the Action Plans on
issues of concern to the Affected Communities, the updated relevant
mitigation measures or actions will be communicated to them. The
frequency of these reports will be proportionate to the concerns of
Affected Communities but not less than annually.
PARTIALLY COMPLIANT
For the ELDORADO industrial project a public hearing was held for
license 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 disclosure
twice a year with ongoing information about the management programs.
It is not clear if stakeholders are communicated about how to access this
information.
To include on communication channels information about how to access
PBA and other relevant public available information.
Review against IFC Performance Standard 2 (Labor and Working Conditions)
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 2, paragraph 7
PARTIALLY COMPLIANT
There is no human resource police that set out its approach to managing
workers as required by this Performance Standard.
There is current a Policy for Remuneration that states the salaries and
benefits by professional category. This Policy is not available to the
employees and general public.
There is also Policy for Training developed to be applied for industrial and
rural workers, however, the policy has not being validated by the
managers in charge of the forest activity
ELDORADO has a grievance mechanism although not defined in a formal
procedure.
Contacts with third part has a clause that stats the commitment of not
employing child or forced labour.
To develop a Human Resource Policy, procedures or ethical code
appropriate to the ELDORADO, to be applied for workers, contracted
workers and supply chain workers. The policy, procedure or ethical code
shall cover all issues treated by this performance standard, as exemplified
bellow:
 Working conditions: e.g physical environmental, health and safety
precautions, treatment of workers, disciplinary practices, respect to
workers’s personal dignity (such as refraining from physical
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;
 Non discrimination and Equal Opportunity;
 Grievance mechanism;
 Child Labour;
 Forced Labour;
 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 to publicly disclose it.
Human Resources Policies and Procedures
7.
The client will adopt and implement human resources policies and
procedures appropriate to its size and workforce that set out its
approach to managing workers consistent with the requirements of
this Performance Standard and national law.
8.
The client will provide workers with documented information that is PS 2, paragraph 8
clear and understandable, regarding their rights under national labor
and employment law and any applicable collective agreements,
including their rights related to hours of work, wages, overtime,
compensation, and benefits upon beginning the working relationship
and when any material changes occur.
COMPLIANT
None
Workers documents were revised and were in compliance with the
Brazilian legislation. Workers are provided with a contract and, during the
Inductions, it is provided information associated with legal rights:
experience period; workers permit; working hours and working hours
register; identification to access the site, legal absences, medical leave,
salary and variable remuneration, payment conditions, vacations, union
and union feed and benefits (medical assistance, life insurance,
alimentation, workers transportation).
Workers receive a manual that includes information about the site, health
and safety, legal rights, buses, working hours, work contract, ombudsman,
access to the site, etc.
Working Conditions and Terms of Employment
9.
10.
Where the client is a party to a collective bargaining agreement with a
workers’ organization, such agreement will be respected. Where such
agreements do not exist, or do not address working conditions and
terms of employment, the client will provide reasonable working
conditions and terms of employment.
PS 2, paragraph 9
Federal Decree (Decreto
Lei) 5.452/43 "Consolidação das Leis do
Trabalho" (CLT or Labour
Law Consolidation).
Law Consolidation).
COMPLIANT
There is currently a Union Agreement in place, signed with the Union of
Workers on Paper and Pulp Industry of Três Lagoas (SINDICELPA).
The client will identify migrant workers and ensure that they are
engaged on substantially equivalent terms and conditions to nonmigrant workers carrying out similar work.
PS 2, paragraph 10
Law Consolidation).
COMPLIANT
There are around 5.700 migrant workers hired by contractors to perform
activities associated with the ELDORADO project infrastructure.
Term of conditions and employment are the same those provided to local
workers. Migrant workers are also represented by the local Union
None
Contractors’ workers are represented by the Union of Construction
Workers.
None
Agreement.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 2, paragraph 11
NR24: Sanitary and
comfort at the work place
Decree 3.298/99 Regulates the Law
7.853/89 on the National
Policy for the Integration
of Disabled Person
IN 90/11
Federal Decree 58.826/66 Promulgates the ILO
Convention 110: Worker's
recruitment
Law 9777/98 - Change on
the Law 2848/40 (Criminal
Code) - Labour rights:
Slave labour
PARTIALLY COMPLIANT
ELDORADO is directly in charge for 3 accommodations for migrant
workers hired by contractors. A company, named Meta, was hired to
manage the accommodation: (1) Accomodation I, located at Três Lagoas,
has capacity for 1920 workers; (2) Accomodation II, located at Três
Lagoa,\s has capacity for 1020 workers; (3) Accomodation Selvíria, located
at Selviría, has capacity for 720 workers.
Contractors are in charge of the recruitment and transport of workers and
are recommended to comply with IN 90/11, that states the requirement to
transport migrant workers. However, this is not monitored by
ELDORADO.
ERM visited Accommodation and it was in compliance with NR24 and
consistent with the principles of non-discrimination and equal
opportunity. Besides, ELDORADO informed that there is no restriction to
freedom of movement and workers can leave or enter the accommodation
at any time, this was confirmed by one worker interviewed at
Accommodation I.
Workers are provided with a badge to access the accommodation. Bags
and suitcases are inspected by Security Personnel to prevent the entrance
of alcoholic drinks, gums and drugs.
During check in, workers are informed of the Procedure to use the
Accommodation and about inspections.. A copy of the Procedure to use
the Accommodation is also available in each of the rooms.
ELDORADO informed that Union has access to the accommodation and
that they request to be previous informed of the visit. Secondary data
review indicates that Union representatives had accessed the
Accommodation II to register workers grievance associated with the
accommodations conditions.
To monitor recruitment and transport of migrant workers, to guarantee
compliance with the Brazilian legislation, described on column “Related PR
Requirement, EHS Guidelines and Legal Standards”.
To develop a mechanism to disqualify contractors that are not monitoring
their accommodation or timely solving the findings identified by Meta.
11.
Where accommodation services are provided to workers covered by
the scope of this Performance Standard, the client will put in place
and implement policies on the quality and management of the
accommodation and provision of basic services. The accommodation
services will be provided in a manner consistent with the principles
of non-discrimination and equal opportunity. Workers’
accommodation arrangements should not restrict workers’ freedom
of movement or of association.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
There are other 2.553 contractors’ workers accommodated in 135 houses and
hotels rented by the contractors. ELDORADO has also hired Meta to monitor
these accommodations compliance with NR 24. Contractor’s
accommodation are visited once a month and a report is developed. In case
of no compliance, contractors has 1 month to solve the issues otherwise the
accommodation can be interdicted and a fine issued by ELDORADO to the
contractorERM did not visit any of contractors’ accommodations but
reviewed a sample of the reports developed by Meta for a contractor named
Paranasa. ELDORADO provided ERM with 18 reports from 7 Paranasa’s
accommodation. 11 reports identified no compliance with NR24, 1
recommended the interdiction of the accommodation and 1 report a fire at
the accommodation named Amarelinha, for which workers are being
investigated.
The management conditions for ELDORADO and contractor’s
accommodation is well structure and effective, however, as evidenced by the
reports reviewed, findings of no compliance with NR24 are constantly
identified and not timely solved.
This imposes a risk of non compliance with the Ministry of Labour in case of
inspection and risk to workers community safety.
11.
Workers’ Organizations
12.
In countries where national law recognizes workers’ rights to form and
to join workers’ organizations of their choosing without interference
and to bargain collectively, the client will comply with national law.
Where national law substantially restricts workers’ organizations, the
client will not restrict workers from developing alternative
mechanisms to express their grievances and protect their rights
regarding working conditions and terms of employment. The client
should not seek to influence or control these mechanisms
PS 2, paragraph 12
Lei) 5.452/43 "Consolidação das Leis
do Trabalho" (CLT or
Labour Law
Consolidation).
COMPLIANT
ELDORADO workers are represented by the Union of Workers on Paper
and Pulp Industry of Três Lagoas (SINDICELPA). During the Induction
workers are informed of the Union contacts and Union Agreement.
Contractors workers are represented by the Union of Workers on
Construction.
ELDORADO reported that union has access to the workers at the site and
accommodation and ELDORADO request to be previously informed of the
visit. Union representative must also be guided (scorted by an ELDORADO
representative during the visit.
ELDORADO informed that main demand of the workers is associated with
the different salary and benefits paid by contractors.
13.
In either case described in paragraph 13 of this Performance Standard,
and where national law is silent, the client will not discourage workers
from electing worker representatives, forming or joining workers’
organizations of their choosing, or from bargaining collectively, and
will not discriminate or retaliate against workers who participate, or
seek to participate, in such organizations and collective bargaining.
The client will engage with such workers’ representatives and
workers’ organizations, and provide them with information needed for
meaningful negotiation in a timely manner. Workers’ organizations are
expected to fairly represent the workers in the workforce.
PS 2, paragraph 13
Labour Law
Consolidation).
NON COMPLIANT
Monitor dismissal of contractor’s workers who were engaged on work
stoppages /strikes to avoid discrimination and guarantee freedom of
There have been 3 work stoppages of activities in the site by workers hired
by contractors: On January (1 day of stop), April (2 days of stop) and August discrimination and collective bargain.
2011 (8 days of stop). The work stoppages are considered unofficial because
it lacked the organization aspects defined by Brazilian regulation (it’s is
different of strike, which is organized and follows the legal terms).
On August, the demand was associated with salaries and commuting to
work. Companies have increased salaries 2,5% and 8% and provided feed
benefits. The negotiation was between the union and contractors, monitored
by the Labour Regional Tribunal and supported by ELDORADO.
ELDORADO reported that, 300 workers were dismissed after the work
stoppage in August 2011.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PARTIALLY COMPLIANT
Contractors are provided with a Health and Safety and Environmental Book
that contains a list of actions in which workers shall not be involved,
including discrimination because of the origin, race, color, age, gender or
physical condition. However it lacks measures to provide guidance to
contractors on how to prevent such behaviors or how to address such cases if
they occur.
Currently, ELDORADO has not taken measures to prevent and address
discrimination in employment relationship, including harassment,
intimidation and/or exploitation. However, ERM did not identified that any
non-discrimination practices are in place to govern employment
relationships.
Refer to PS2, paragraph 7, that recommends aspects to be covered by the
Human Rights Policy.
To take measures to prevent any harassment, including sexual harassment
or psychological mistreatment within the workplace, e.g:
 include a module about harassment for leaders, managers;monitor
and 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 discrimination
in employment relationship.
Non-Discrimination and Equal Opportunity
14
The client will not make employment decisions on the basis of
personal characteristics unrelated to inherent job requirements. The
client will base the employment relationship on the principle of equal
opportunity and fair treatment, and will not discriminate with respect
to any aspects of the employment relationship, such as recruitment and
hiring, compensation (including wages and benefits), working
conditions and terms of employment, access to training, job
assignment, promotion, termination of employment or retirement, and
disciplinary practices. The client will take measures to prevent and
address harassment, intimidation, and/or exploitation, especially in
regard to women. The principles of non-discrimination apply to
migrant workers.
PS 2, paragraph 14
Labour Law
Consolidation).
15.
In countries where national law provides for non-discrimination in
employment, the client will comply with national law. When national
laws are silent on non-discrimination in employment, the client will
meet this Performance Standard. In circumstances where national law
is inconsistent with this Performance Standard, the client is
encouraged to carry out its operations consistent with the intent of
paragraph 15 above without contravening applicable laws.
PS 2, paragraph 15
16.
Special measures of protection or assistance to remedy past
discrimination or selection for a particular job based on the inherent
requirements of the job will not be deemed as discrimination, provided
they are consistent with national law.
NON COMPLIANT
Identify total number of employees with disability and, if not sufficient to
comply with law 3298/99, to define measures to do so at operation phase.
ELDORADO has recently hired a doctor to identify among workers those
that
have
disability
and
if
the
company
is
in
compliance
with
the
Law
7.853
Define measures to comply with Apprentice Law.
PS 2, paragraph 15
that states a quota of 5% of workers with disability for companies with more
Decree 3.298/99 than 1,0000 workers.
Regulates the Law
7.853/89 on the National ELDORADO has not developed a plan or measure to achieve the quota
Policy for the Integration defined by law at operation phase.
ELDORADO reported that there is no apprentice at the site, which is a not
of Disabled Person.
Law 8069/90 - Establish compliance with the Apprentice Law 5.598/05 apprentices, state a quota for
the Child and Teenager apprentices. However, the company sponsors the Program My First Job, that
aims to provide technical training to almost 200 students of the local high
Statute
Federal Decree 5.598/05 schools. 50% of those participants shall be contracted by ELDORADO, which
should be enough to meet the Law 5598 quota.
- Regulates the
Although NON COMPLIANT with Federal Decree 5.598/05, the measure
employment of
undertaken seems to be sufficient to guarantee compliance with this
apprentices and other
requirement in the future.
measures.
NOT APPLICABLE

ELDORADO did not report any cases that required reparation.
Retrenchment
17.
Prior to implementing any collective dismissals, the client will carry
PS 1, paragraph 17
out an analysis of alternatives to retrenchment. If the analysis does not
identify viable alternatives to retrenchment, a retrenchment plan will
be developed and implemented to reduce the adverse impacts of
retrenchment on workers. The retrenchment plan will be based on the
principle of non-discrimination and will reflect the client’s consultation
with workers, their organizations, and, where appropriate, the
government, and comply with collective bargaining agreements if they
exist. The client will comply with all legal and contractual
requirements related to notification of public authorities, and provision
of information to, and consultation with workers and their
organizations.
NOT APPLICABLE
ELDORADO informed to be in contracting phase and there it is not planning
collective dismissal, therefore no retrenchment was developed.
For migrant workers, ELDORADO provides their return to the city of origin.
Prior to implementing any collective dismissals, the client will carry out an
analysis of alternatives to retrenchment. Retrenchment means the
elimination of a number of work positions or the dismissal or layoff of a
number of worker by an employer, generally by reason of plant closing or
for cost savings.
The retrenchment plan shall address costs and alternative solutions to
retrenchment, e.g working time reduction programs, employee capacity
building programs, and other those proposed by employees and; other
stakeholders.
If dismissal is unavoidable, the plan shall consider schedule of the dismissal,
retrenchment methods and procedure, selection criteria, severance
payments, offers to alternative employment, job placement, etc.
Selection criteria shall be objective, fair, transparent and based on non
discrimination.
Workers, government and relevant stakeholders shall be consulted to the
plan development.
No:
19.
The client should ensure that all workers receive notice of dismissal
and severance payments mandated by law and collective agreements
in a timely manner. All outstanding back pay and social security
benefits and pension contributions and benefits will be paid (i) on or
before termination of the working relationship to the workers, (ii)
where appropriate, for the benefit of the workers, or (iii) payment will
be made in accordance with a timeline agreed through a collective
agreement. Where payments are made for the benefit of workers,
workers will be provided with evidence of such payments.
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 2, paragraph 19
PS 2, paragraph 20
NR 31: Regulatory
Standard for Security
and Health of workers
on agriculture, cattle
rising, forest exploration
and others rural
activities
COMPLIANT
There is an ombudsman for workers grievance (employees and those hired
by 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 the
accommodation;
Telephone number
E-mail
Grievances are registered and are treated by the Ombudsman, who is the
person in charge of the contractors’ workers management. . Grievance is
analyzed, investigated, and feedback is provided to the worker by the social
assistant. In case of anonymous grievance, the respond is disclosure on a
board available close to the cafeteria.
Information about the ombudsman is disclosure at the Manual for Induction
and banners at the site.
PS 2, paragraph 21
Federal Decree 5.598/05
- Regulates the
employment of
measures.
Promulgate the 182 ILO
Convention and 190 ILO
Recommendation
concerning the worst
forms of child labour
and immediate action to
eliminate them,
convened in Geneva,
June 17 1999.
Recommendation on
minimum age for
admission to
employment.
Decree 6.481/2008 Regulates Articles 3 and
COMPLIANT
None
ELDORADO informed that there is no worker under 18 years old
performing any activity at the site. Copies of documents related to
contractor’s worker are verified by ELDORADO, for which they believe they
are not in risk of child labour.
ELDORADO sponsors the Regional Program to Combat the Sexual
Exploration of Children, leaded by the Public Ministry for Children and the
Três Lagoas’ Network for the Protection of Children.
This program is part of the workers induction providing information about
children’s right.
COMPLIANT
None
For dismissal, ELDORADO identifies if the worker has any legal restriction
to be dismissal. Human resource personnel also evaluate with the manager
the reasons for the dismissal of the workers. ELDORADO is developing a
Plan to Evaluate Workers Performance.
For Workers Contractors, ELDORADO verifies on a monthly bases
documents that probes that contractors have paid social security benefits and
contributions defined by Brazilian Law.
Grievance Mechanism
20.
The client will provide a grievance mechanism for workers (and their
organizations, where they exist) to raise workplace concerns. The client
will inform the workers of the grievance mechanism at the time of
recruitment and make it easily accessible to them. The mechanism
should involve an appropriate level of management and address
concerns promptly, using an understandable and transparent process
that provides timely feedback to those concerned, without any
retribution. The mechanism should also allow for anonymous
complaints to be raised and addressed. The mechanism should not
impede access to other judicial or administrative remedies that might
be available under the law or through existing arbitration procedures,
or substitute for grievance mechanisms provided through collective
agreements.
None
Protecting the Work Force
Child Labor
21.
The client will not employ children in any manner that is economically
exploitative, or is likely to be hazardous or to interfere with the child’s
education, or to be harmful to the child’s health or physical, mental,
spiritual, moral, or social development. The client will identify the
presence of all persons under the age of 18. Where national laws have
provisions for the employment of minors, the client will follow those
laws applicable to the client. Children under the age of 18 will not be
employed in hazardous work. All work of persons under the age of 18
will be subject to an appropriate risk assessment and regular
monitoring of health, working conditions, and hours of work.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
4 of the ILO Convention
182 concerning the worst
and immediate action to
eliminate them,
convened in Geneva,
June 17 1999.
Standard (Instrução
Normativa) SIT n° 66/06
- States on work
inspection to combat
child labour and protect
teenager work.
Forced Labor
The client will not employ forced labor, which consists of any work or
service not voluntarily performed that is exacted from an individual
under threat of force or penalty. This covers any kind of involuntary or
compulsory labor, such as indentured labor, bonded labor, or similar
labor-contracting arrangements. The client will not employ trafficked
persons.
PS 2, paragraph 22
Law 9777/98 - Change
on the Law 2848/40
(Criminal Code) Labour rights: Slave
labour
COMPLIANT
None
ELDORADO informed that the operation is not in risk of employment of
slave like conditions. ELDORADO hired Meta to verify the documentation
of all contractor’s workers. All workers directly hired by ELDORADO are
formal registered as long as workers hired by third parts. This was
evidenced by documents verification.
ELDORADO informed that overtime is controlled. All workers are provided
with a badge that electronic compute the total hours worked at the site per
day. The shift is 8 hours and workers can perform 2 hour of overtime. If the
worker stays longer than 10 hours, he must register in the system the
justification and manager is requested to authorize.
PS2, Paragraph 23
Brazilian Regulatory
Norm NR-6, Personal
Protective Equipment –
PPE.
IFC General
Environmental, Health
and Safety (EHS)
Guidelines
IFC Environmental,
Health and Safety
Guidelines – Pulp and
Paper Mills
CONSTRUCTION STAGE
PARTIALLY COMPLIANT
ERM sample checked the occupational health & safety documents and
programs that are legally required by the Brazilian regulations. For one of
the contractors that is working in the Project construction (Serpal, a civil
construction company), ERM checked, among others, the following main
programs/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 required
documents/programs. However, a deficiency was observed regarding the
Regulatory Norm NR-6, associated with PPE delivery records. The delivery
records do not fully match the list of PPEs that must be provided to each
employee as function of the job performed, according to a PPE requirement
list included in their Occupational Risk Prevention Plan. Additionally, some
PPE deliveries were not properly registered.
23.
The client will provide a safe and healthy work environment, taking
into account inherent risks in its particular sector and specific classes of
hazards 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 disease
arising from, associated with, or occurring in the course of work by
minimizing, as far as reasonably practicable, the causes of hazards. In a
manner consistent with good international industry practice, as
reflected in various internationally recognized sources including the
World Bank Group Environmental, Health and Safety Guidelines, the
client will address areas that include the (i) identification of potential
hazards to workers, particularly those that may be life-threatening; (ii)
provision of preventive and protective measures, including
modification, substitution, or elimination of hazardous conditions or
substances; (iii) training of workers; (iv) documentation and reporting
of occupational accidents, diseases, and incidents; and (v) emergency
prevention, preparedness, and response arrangements. For additional
information related to emergency preparedness and response refer to
Performance Standard 1.
ELDORADO must guarantee that all PPEs be delivered to the employees,
the PPE delivery properly registered and that all PPEs be adequate to the
risks identified and listed in the PPRA.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
OPERATION STAGE
NOT POSSIBLE TO EVALUATE
ERM cannot evaluate compliance with the Occupational, Health and Safety
requirements, given that the pulp mill is not yet operating.
In the Operation Stage, ELDORADO should comply with the Brazilian
Health & Safety requirements and IFC General Environmental, Health and
Safety (EHS) Guidelines and the IFC Environmental, Health and Safety
Guidelines – Pulp and Paper Mills. This will include , but not limited to,
implementing the following main programs:

Occupational Risks Prevention Program as required by Brazilian
standard NR-09, for the industrial operations;

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 reporting;

Occupational diseases records, investigations and reporting;
PARTIALLY COMPLIANT
Currently, ELDORADO has 186 employees and around 6.000 workers hired
by third parts.
ELDORADO provides induction to employees and workers hired by third
part 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 conduct
to contractors’ workers.
Refer to the whole PS2 paragraphs to detailed information about
management of subcontractors.
In summary, ELDORADO is partially compliant on the following items:
 PS2, Working conditions and terms of employment, paragraph 11: non
compliances with contractors’ accommodation are constantly identified;
 PS2, Workers organization, paragraph 13: contractors’ workers were
dismissed after a work stoppage;
 PS2, Non discrimination and freedom of association, paragraph 14: there
are no measures in place to prevent discrimination
Refer to PS1 paragraph 11, 13 and 14.
COMPLIANT
See grievance Mechanism Paragraph 20.
None
24.
With respect to contracted workers the client will take commercially
reasonable efforts to ascertain that the third parties who engage these
workers are reputable and legitimate enterprises and have an
appropriate ESMS that will allow them to operate in a manner
consistent with the requirements of this Performance Standard, except
for paragraphs 18–19, and 27–29.
PS 2, paragraph 24
25.
The client will establish policies and procedures for managing and
monitoring the performance of such third party employers in relation
to the requirements of this Performance Standard. In addition, the
client will use commercially reasonable efforts to incorporate these
requirements in contractual agreements with such third party
employers.
PS 2, paragraph 25
26.
The client will ensure that contracted workers, covered in paragraphs
24–25 of this Performance Standard, have access to a grievance
mechanism. In cases where the third party is not able to provide a
grievance mechanism the client will extend its own grievance
mechanism to serve workers engaged by the third party.
PS 2, paragraph 26
Supply Chain
27.
Where there is a high risk of child labor or forced labor in the primary PS 2, paragraph 27
supply chain, the client will identify those risks consistent with
paragraphs 21 and 22 above. If child labor or forced labor cases are
identified, the client will take appropriate steps to remedy them. The
client will monitor its primary supply chain on an ongoing basis in
order to identify any significant changes in its supply chain and if new
risks or incidents of child and/or forced labor are identified, the client
will take appropriate steps to remedy them.
PARTIALLY COMPLIANT
To identify categories of significant suppliers in the primary supply chain in
Suppliers contracts have a clause that states that both parts are responsible to high risk of child labour and forced labor.
avoid child employment or forced labour.
To define measures to monitor significant suppliers on employment of child
labour and forced labour. The measures shall be defined according to the
suppliers risk. High risk suppliers shall be audited.
28.
Additionally, where there is a high risk of significant safety issues
related to supply chain workers, the client will introduce procedures
and mitigation measures to ensure that primary suppliers within the
supply chain are taking steps to prevent or to correct life-threatening
situations.
Refer to PS2, paragraph 27
PS 2, paragraph 28
None
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 2, paragraph 29
None
Supply Chain
29.
The ability of the client to fully address these risks will depend upon
the client’s level of management control or influence over its primary
suppliers. Where remedy is not possible, the client will shift the
project’s primary supply chain over time to suppliers that can
demonstrate that they are complying with this Performance Standard.
Review against IFC Performance Standard 3 (Resource Efficiency and Pollution Prevention)
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 3 Paragraph 4
Federal CONAMA
Resolution 01/86
State Law 2257/2001
Nº:
4.
During the project life-cycle, the client will consider ambient
conditions and apply technically and financially feasible resource
efficiency and pollution prevention principles and techniques that are
best suited to avoid, or where avoidance is not possible, minimize
adverse impacts on human health and the environment. The principles
and techniques applied during the project life-cycle will be tailored to
the hazards and risks associated with the nature of the project and
consistent with good international industry practice (GIIP), as reflected
in various internationally recognized sources, including the World
Bank Group Environmental, Health and Safety Guidelines (EHS
Guidelines).
5.
The client will refer to the EHS Guidelines or other internationally
PS 3 Paragraph 5
recognized sources, as appropriate, when evaluating and selecting
resource efficiency and pollution prevention and control techniques for
the project. The EHS Guidelines contain the performance levels and
measures that are normally acceptable and applicable to projects.
When host country regulations differ from the levels and measures
presented in the EHS Guidelines, clients will be required to achieve
whichever is more stringent. If less stringent levels or measures than
those provided in the EHS Guidelines are appropriate in view of
specific project circumstances, the client will provide full and detailed
justification for any proposed alternatives through the environmental
and social risks and impacts identification and assessment process.
This justification must demonstrate that the choice for any alternate
performance levels is consistent with the objectives of this Performance
Standard.
PARTIALLY COMPLIANT
The ELDORADO pulp mill is still under implementation. According to
None Required
reviewed documents and information provided to ERM during the site visit,
ELDORADO project implementation followed the legally required steps in
Brazil for a pulp mill project. This included, among others, the development
of an Environmental Impact Assessment (EIA) that took into consideration
local environmental conditions, such as water availability and quality and air
background air quality.
The EIA considered the main impacts associated with a project of such
magnitude and adequate mitigation measures from the environmental
standpoint, for the implementation and for the operation stages. Although
ELDORADO has not anticipated the impacts of the plant decommissioning,
ERM understands that pulp mills are not designed to be decommissioned on
short-term basis. As per ERM experience, Pulp mills are constantly in
modernization process, which could extend indefinitely.
Prevention and control measures adopted in the project implementation, that
are further detailed in the assessment of EHS guidelines, are considered in
line with good international practice for pulp and paper mills.
COMPLIANT
As reported by ELDORADO and according to reviewed documents and
None required.
information provided to ERM during the site visit, the ELDORADO Project
is in line with the best available technologies for pulp and paper
manufacturing
Through documents review and information provided by the site contacts
during the visit, ERM could identify examples of pollutants minimization,
such as dry debarking systems (effluents), continuous digestion, closed
circuit pulp washing and screening (lower effluent flow and load), use of
oxygen delignification prior to the bleaching stages (lower chemical use and
effluent 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 by
ERM in documents review, the process technology incorporates the latest
developments in pulp and paper industry associated with energy efficiency.
The ELDORADO pulp mill will not only be self-sufficient in energy but will
also connect to the National Electricity System to sell the excess energy
produced.
Nº:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
COMPLIANT
As previously mentioned, production activities will incorporate the best
available technology for pulp production. Further discussions are presented
in the specific sections of this table.
None required
Resource Efficiency
6.
The client will implement technically and financially feasible and cost
effective measures for improving efficiency in its consumption of
energy, water, as well as other resources and material inputs, with a
focus on areas that are considered core business activities. Such
measures will integrate the principles of cleaner production into
product design and production processes with the objective of
conserving raw materials, energy, and water. Where benchmarking
data are available, the client will make a comparison to establish the
relative level of efficiency.
Greenhouse Gases
7.
8.
In addition to the resource efficiency measures described above, the
client will consider alternatives and implement technically and
financially feasible and cost-effective options to reduce project-related
GHG emissions during the design and operation of the project. These
options may include, but are not limited to, alternative project
locations, 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 COMPLIANT
The ELDORADO Pulp mill of Três Lagoas/MS does not have an
estimate of carbon dioxide emission equivalents for the Project.
Production has not yet started.
Some measures adopted in the project are aligned with the reduction of
greenhouse gas emissions, such as the use of renewable energy sources
associated with biomass burning, co-generation of heat and power and
chemicals recovery, among others.
The site should develop an estimate of greenhouse gas (GHG) emissions at
the project stage, according to internationally recognized methodology, such
as the Guidelines of the Intergovernmental Panel on Climate Change (IPCC)
or equivalent.
The GHG emissions estimate should be annually reviewed.
For projects that are expected to or currently produce more than 25,000
tonnes of CO2-equivalent annually, the client will quantify direct
emissions from the facilities owned or controlled within the physical
project boundary, as well as indirect emissions associated with the offsite production of energy used by the project. Quantification of GHG
emissions will be conducted by the client annually in accordance with
internationally recognized methodologies and good practice.
Nº:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 3, Paragraph 9
IFC General
and Safety (EHS)
Guidelines
IFC Environmental,
Health and Safety
Paper Mills
Federal MS Ordinance
518/2004, altered and
revoked by MS
Ordinance 2914/2011
(issued on December 12,
2011), which establishes
drinking water
standards in Brazil.
Technical requirement
of Operating Permit
116/2011, issued by the
State Environmental
Agency Imasul on April
12, 2011, valid for four
years, for the temporary
water and wastewater
treatment systems.
COMPLIANT
None required
As previously stated, the ELDORADO project incorporates the best available
technologies for pulp mills.
The impact of the pulp mill operations in the neighborhood regarding water
availability is regarded as low, considering that water will be abstracted
from Paraná River. The EIA developed for ELDORADO pulp mill took into
account water availability as one factor for location alternatives. A flow
measurement period of 22 years was considered for Paraná River. Within
this period, the average flow was 7,299 m³/s, with a maximum flow of 28,222
³/s and minimum of 1,597 m³/s. The characteristic flow (Q95) was 2,070 m³/s
(occurring 95% of the time).
The project incorporates strategies to reduce water consumption, such as dry
wood debarking, closed circuit pulp washing and screening, counter-current
pulp washing in the bleaching lines, among others.
The design water intake for industrial purposes, used for the dimensioning
of the water treatment plant to be installed in ELDORADO pulp mill is 7,500
m³/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 water
consumption for the design flow will result in approximately 42.4 m³/Adt.
However, Eldorado expects to work with a water consumption of
approximately 5,400 m³/h, resulting in a specific consumption of 30.5
m³/ADt.
For the operation stage, ELDORADO holds the water abstraction
authorization issued by the National Water Agency – ANA (Agência
Nacional de Águas), authorizing a water intake of 7,500 m³/h.
For the construction stage, ELDORADO installed a temporary water
treatment system with 120 m³/h capacity. The water treatment plant is a
conventional physical-chemical treatment consisting of coagulation,
flocculation, clarification (clarifier with lamellae settlers) and filtration.
ELDORADO holds the Environmental Operating Permit # 116/2011, issued
by the State Environmental Agency – IMASUL on April 13, 2011, valid for
four years, authorizing the operation of the temporary water treatment
system. It also holds the water abstraction permit from ANA, authorizing a
water intake of 120 m³/h from Paraná River.
Water Consumption
9.
When the project is a potentially significant consumer of water, in
addition to applying the resource efficiency requirements of this
Performance Standard, the client shall adopt measures that avoid or
reduce water usage so that the project’s water consumption does not
have significant adverse impacts on others. These measures include,
but are not limited to, the use of additional technically feasible water
conservation measures within the client’s operations, the use of
alternative water supplies, water consumption offsets to reduce total
demand for water resources to within the available supply, and
evaluation of alternative project locations.
According to technical requirement of the Environmental Operating Permit
116/2011, the site should prepare and submit to the State Environmental
Agency monitoring reports every six months, considering the drinking water
standards established by MS Ordinance 518/2004. ELDORADO has
submitted monitoring reports to the Environmental Agency as required,
which showed compliance with the applicable drinking water standards for
the analyzed parameters. As per documents review, ELDORADO has
developed a drinking water quality monitoring plan, as required, and has
submitted monitoring reports to the competent authorities, with analysis of
the main drinking water standards (microbiological, free residual chlorine,
turbidity, pH among others). Additionally, ELDORADO has conducted an
analysis for the complete set of parameters established in Ordinance
518/2004, which includes inorganic parameters, organic parameters
(including pesticides) and organoleptic parameters. No deviations were
observed
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 3, Paragraphs 10 and
11
IFC General
and Safety (EHS)
Guidelines
IFC Environmental,
Health and Safety
Paper Mills
CONAMA Resolution
03/1990, which
establishes the water
quality standards
(primary and secondary
standards)
CONAMA resolution
382/2006, which
establishes the air
emission standards for
the type of industries
specified in its annexes,
including pulp and
paper mills.
Ambient Air Quality
PARTIALLY COMPLIANT
ERM reviewed two air quality monitoring reports developed by the hired
consulting company Storm & Smoke – Consultoria Ambiental e Prestadora
de 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
approximately 6.0 km East from ELDORADO Pulp Mill site)

24-hour monitoring at one point in the city of Três Lagoas (distant
approximately 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 and
total suspended particles), NO2, ozone, carbon monoxide and SOx. The area
is considered homogeneous in what refers to air quality.
The results indicated that the monitored parameters meet the air quality
standards established in Brazilian regulations and the WHO Ambient Air
Quality Guidelines, except for Particulate Matter PM10, in July, 2011, which
exceeded the guideline value of 50 µg/m³ (24-hour average concentration of
52.92µg/m³).
The second report refers to a monitoring campaign conducted in September
2011. The results show that all the parameters comply with the Brazilian
regulations and WHO Ambient Air Quality Guidelines, except for PM10,
which exceeded the Interim target 3 value of 75µg/m³ (24-hour average
concentration of 87.95µG/m³).
The PM10 concentrations are apparently related to seasonal variations. The
monitoring campaign conducted in March (rainy season) showed much
lower result (24-hour average of 8.3 µg/m³) than the campaigns conducted in
July and September (dry season).
Brazilian regulations do not establish air quality standards for Particulate
Matter PM2.5. As such, this parameter has not been monitored in the air
quality monitoring campaigns conducted by ELDORADO. However, this
parameter is addressed in the IFC EHS guidelines.
10.
The client will avoid the release of pollutants or, when avoidance is not
feasible, minimize and/or control the intensity and mass flow of their
release. This applies to the release of pollutants to air, water, and land
due to routine, non-routine, and accidental circumstances with the
potential for local, regional, and transboundary impacts. Where
historical pollution such as land or ground water contamination exists,
the client will seek to determine whether it is responsible for
mitigation measures. If it is determined that the client is legally
responsible, then these liabilities will be resolved in accordance with
national law, or where this is silent, with GIIP.
The air quality monitoring campaigns conducted to date have not included
the monitoring of Particulate Matter PM2.5 . Regardless of Brazilian
regulations not establishing a quality standard for PM2.5, ELDORADO
should include this parameter in the next monitoring campaigns, to assure
compliance with international standards and IFC Guidelines.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
An air quality monitoring station will be installed in a location to be defined
in Três Lagoas, for the monitoring of Particulates, TRS, NOx, SOx and CO.
The monitoring station will reportedly be operational by the time of the plant
commissioning.
Atmospheric emissions dispersion modeling in the EIA took into account the
construction of a 120-m high stack. The dispersion model was reviewed in
August 2011. A new dispersion study has been developed considering the
actual stack height of 145 m and the late inclusion of a sodium chlorate plant
within the industrial complex.
The air dispersion model was developed taking into account the installation
of a 145-m high structure that will support the exhaust ducts of the recovery
boiler, power boiler and lime kiln and different meteorological conditions,
for the average annual concentrations and 24-hour concentrations (primary
and secondary air quality standards), and considering the use of different
fuels.
The mathematical modeling analyzed the concentrations of inhalable
particles, NO2, SO2, CO, TRS and Cl2. According to the dispersion model, the
highest 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 conclusion
is that, based on the modeling for each evaluated pollutant, no additional
impact on the regional air quality will be caused by the pulp mill operation.
ELDORADO will also establish an Odor Perception Network. The OPN will
be formed by volunteers from the neighboring communities trained to
contact the company in case any characteristic odor is perceived. The
volunteers will be trained (qualified) through workshops, visits to the plant
to be able to distinguish any odor that could be attributed to the industrial
process. The network is to be trained until mid-2012, prior to ELDORADO
commissioning stage.
10.
11.
To address potential adverse project impacts on existing ambient
conditions, the client will consider relevant factors, including, for
example (i) existing ambient conditions; (ii) the finite assimilative
capacity of the environment; (iii) existing and future land use; (iv) the
project’s proximity to areas of importance to biodiversity; and (v) the
potential for cumulative impacts with uncertain and/or irreversible
consequences. In addition to applying resource efficiency and
pollution control measures as required in this Performance Standard,
when the project has the potential to constitute a significant source of
emissions in an already degraded area, the client will consider
additional strategies and adopt measures that avoid or reduce negative
effects. These strategies include, but are not limited to, evaluation of
project location alternatives and emissions offsets.
11.
IFC General
and Safety (EHS)
Guidelines
IFC Environmental,
Health and Safety
Paper Mills
CONAMA resolution
382/2006, which
establishes the air
emission standards for
the type of industries
specified in its annexes,
including pulp and
paper mills.
Atmospheric Emissions
None Required
COMPLIANT
Regarding the construction stage, ELDORADO has established a program to
reduce fugitive emissions related to re-suspension of particulates resulting
from vehicles traffic and wind action. This program includes wetting of
unpaved using tank trucks. During the site visit, due to the weather
conditions (occurrence of precipitation in the three days of visit), no wetting
was 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, lime
kiln and power boiler for gas flow, temperature, pressure, moisture, oxygen,
total reduced sulfur (TRS), NOx, SOX, Carbon monoxide and particulates.
ERM reviewed the process guarantees provided by the suppliers of the main
emission sources, namely the recovery boiler, the power boiler and the lime
kiln.
Taking into account the process guarantees, ERM verified compliance with
the limits established by the Brazilian regulations and the more stringent IFC
Environmental, Health and Safety Guidelines – Pulp and Paper Mills.
The guaranteed air emissions of each source comply with the emission
standards established by Brazilian regulations for pulp and paper mills.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
11.
Similarly, process guarantees result in the following specific emissions:
Specific emission
(kg/ADt)
IFC Guideline
Standard (kg/Adt)
TRS
0.017
0.5
SO2
0.399
0.5
NO2
1.084
1.5
0.27
0.5
Parameter
Particulates
11
CONAMA Resolution
357/2005, which
establishes the surface
water quality standards
in Brazil.ye
SURFACE WATER QUALITY
None required
COMPLIANT
Reportedly the surface water monitoring plan will continue as proposed to
the State Environmental Agency.
As a basic Environmental Plan and to meet technical requirement of the
Environmental Installation Permit, ELDORADO has developed a surface
water monitoring program. Six monitoring points were defined in the area
of direct influence of the pulp mill:
1. Santa Vera Creek (southern property boundary), downstream of the
future pulp mill;
2. Santa Vera Creek, upstream of the future pulp mill
3. Bebedouro creek (northern property boundary), upstream of the future
pulp 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 on
September 19 and 20, 2011. Water and sediments samples were collected and
the analytical results compared with the quality standards established by
Federal CONAMA Resolution 357/2005. Total phosphorus was detected in
all monitoring points (except point 01) above the water quality standard.
Benthonic invertebrates were also monitored and one invasive species was
detected (Melanoides tuberculata).The monitoring report recommends the
continuation of invertebrates monitoring, because this indicator is influenced
by human interferences in the environment.
PS3 Paragraphs 10 and
11
CONAMA Resolution
430/2011, which
establishes national
wastewater discharge
standards. State
Deliberação CECA/MS
03/1997, which
establishes the
standards in the State of
Mato Grosso do Sul.
WASTEWATER MANAGEMENT
ELDORADO to confirm whether they can meet the IFC standard for
phosphorous.
PARTIALLY COMPLIANT
According to the pulp mill project and information provided to ERM during
the site visit, effluents will be treated in an on-site wastewater treatment
system and discharged into Paraná River via an effluent outfall, installed
upstream of the pulp water intake point. comprising primary clarification for
solids-containing effluents, neutralization of
The effluent treatment system will consist primary treatment (solidscontaining effluent) and a biological treatment for effluents joint treatment
(activated sludge).
ERM reviewed the process guarantees provided by the effluent treatment
system supplier.
Taking into account the process guarantees, ERM compared the effluent
estimated quality with the IFC EHS guidelines and the applicable
wastewater discharge standards.
ERM evidenced compliance with the standards.
Similarly, the process guarantees result in the following specific flow and
loads:
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
11.
Parameter
Specific value
IFC Guideline
Flow (m³/ADt)

Average

Design
BOD (kg/ADt)
28.9
36.8
50.0
0.59
1.0
TSS (kg/ADt)
1.11
1.5
AOX (kg/ADt)
0.14
0.26
Total Nitrogen (kg/ADt)
0.18
0.04
0.20
Total Phosphorus (kg/Adt)
0.03
Although the estimated total phosphorus content is roughly higher than the
IFC specific standard, ERM understands that ELDORADO can adjust the
treatment process to lower the treated effluent phosphorus concentration.

PS3 Paragraphs 10
and 11
Federal CONAMA
Resolution 01/1990,
which establishes that
the emission of noise
from any industrial
activity should comply
with the conditions
established in NBR
10151/00
Brazilian Standard NBR
10151/00, which
describes procedures for
identifying the
acceptability of noise in
inhabited areas.
ENVIRONMENTAL NOISE
ELDORADO will have to conduct additional noise monitoring campaigns
prior to commissioning and during operations.
COMPLIANT
For the development of the EIA, a noise monitoring campaign was
conducted in November, 2009, so as to establish the background condition of
the area where the industrial complex is inserted. No activities were being
carried out at the time of monitoring. Meteorological data during the day of
the monitoring campaign was obtained from the National Meteorology
Institute (INMET) and the adopted parameters were from the automatic
meteorological station located in the municipality of Valparaíso, State of São
Paulo, approximately 100 km distant from Três Lagoas. The noise
monitoring 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 to
the 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 Federal
CONAMA Resolution 01/1990, which establishes that noise levels for
acoustic comfort defined in the Brazilian Standard NBR 10151. The noise
levels measured at monitoring points 1 and 2 (next to the highway) exceeded
the limit for rural areas and daily period established in the mentioned
standard. This was attributed to the vehicles traffic at the highway, given
that at points 3 and 4, the noise levels resulted significantly lower than the
established limit.
The established limit for rural areas during the day (from 7:00 am to 10:00
pm) is 40 dB(A). The limit for night period is 35 dB (A).
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS3, Paragraph 12
Brazilian Standard NBR
10004, which classifies
the wastes into three
categories: Class I
(hazardous), Class IIA
(non-hazardous, noninert) and Class IIB
(inerts).
CONAMA Resolution
313/2002, which
establishes the National
Waste Inventory and
requires industrial
activities to develop a
waste inventory to be
submitted to the State
Environmental Agency;
Federal CONAMA
Resolution 362/2000,
which establishes
guidelines for collection
and disposal of spent
lubricating oils
Federal CONAMA
which establishes criteria
for treatment and
disposal of clinical
wastes
State Law 2080/2000,
which establishes
procedures and criteria
regarding waste
generation, packing,
storage, collection,
transport and disposal.
OPERATION STAGE
COMPLIANT
The consulting company Poyry Tecnologia developed a Solid Waste
Management Plan (PGRS – Plano de Gerenciamento de Resíduos Sólidos) for
the industrial complex, addressing the waste management during the
ELDORADO operation stage.
The PRGS includes procedures and responsibilities related to the
management of:

Clinical wastes (hazardous);

Industrial wastes, including dregs and grits from causticizing, sand
from wood handling, eucalyptus bark (if not burned in the power
boiler), rejects from pulp washing and screening, ash from the power
boiler, screened material form the water and wastewater treatment
systems and primary and secondary sludge;

Non-industrial waste: generated at the process support areas, include
hazardous wastes, such as spent lubricating oils, batteries, burnt
fluorescent tubes, expired chemicals, wastes contaminated with oils,
grease and solvents and batteries, among others; non-hazardous
wastes, 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 to
receive non-hazardous wastes (Class IIA according to applicable Brazilian
standards) and inert wastes (Class II B). According to documents reviewed,
the landfill will be constructed following the best practices, including cells
lining, leak detection, protection against storm water runoff and leachate
collection and treatment. Additionally, the landfill will be installed for a twoyear operation, while ELDORADO evaluates composting alternatives to
minimize the amount of landfilled wastes.
Wastes
12.
The client will avoid the generation of hazardous and non-hazardous
waste materials. Where waste generation cannot be avoided, the client
will reduce the generation of waste, and recover and reuse waste in a
manner that is safe for human health and the environment. Where
waste cannot be recovered or reused, the client will treat, destroy, or
dispose of it in an environmentally sound manner that includes the
appropriate control of emissions and residues resulting from the
handling and processing of the waste material. If the generated waste
is considered hazardous, the client will adopt GIIP alternatives for its
environmentally sound disposal while adhering to the limitations
applicable to its transboundary movement. When hazardous waste
disposal is conducted by third parties, the client will use contractors
that are reputable and legitimate enterprises licensed by the relevant
government regulatory agencies and obtain chain of custody
documentation to the final destination. The client should ascertain
whether licensed disposal sites are being operated to acceptable
standards and where they are, the client will use these sites. Where this
is not the case, clients should reduce waste sent to such sites and
consider alternative disposal options, including the possibility of
developing their own recovery or disposal facilities at the project site.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards

PS3 Paragraph 12
CONAMA Resolution
307/2002, establishes the
standards to manage
civil construction wastes
and classifies the wastes
according to its origin.
CONAMA Resolution
348/2004, modified the
CONAMA Resolution
307/2002, and included
asbestos in the
hazardous wastes
category.
CONSTRUCTION STAGE
PARTIALLY COMPLIANT
As 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 wastes
generated by each contractor working in the construction site, centralize the
temporary storage and give proper destination.
Each contractor, in its turn, temporarily store generated hazardous waste in a
temporary storage area, until it is removed by Podium to the central waste
management facility.
During the site visit, ERM sample checked the contractor’s installations and
some deficiencies were noted. At the installations of Serpal (power boiler
civil construction contractor), the hazardous waste storage area is small
(approximately 4.0 m²), apparently insufficient to accommodate the wastes
generated (oily wastes, spent solvent, etc.) until the transfer to the central
waste facility by Podium. As a result, reportedly because Podium had not yet
removed the wastes from the generation point, six drums were observed
outside the storage area, directly on unpaved soil, covered with a plastic
sheet (no evidence of leakage was observed). Additionally, the wastes were
not adequately labeled.
ELDORADO should inspect the contractors’s installations and make sure
that hazardous wastes are being stored in covered, secondarily contained
and paved areas.
ELDORADO should require the following actions from Podium:
 Expedite the construction of the hazardous waste temporary storage
area;
 Develop a procedure for handling, storage and disposal of asbestoscontaining wastes that assure not only environmental compliance with
applicable regulations, but also health and safety regulations;
 Segregate asbestos-containing wastes and give them appropriate final
disposal as hazardous waste;
 Develop a procedure for asbestos-containing wastes management,
including handling, storage and disposal. The procedure should contain
the guidance for asbestos-waste handling, the required PPE to be
provided to employees and employees training requirements;
 Appropriately train the employees responsible for asbestos-containing
wastes handling.
Wastes
12.
As for Podium installations, ERM observed that a waste temporary storage
area was under construction, reportedly according to applicable standards
(covered and provided with secondary containment, and sealed floor). A
hazardous waste load was waiting for shipment packed within a truck
dumpster, 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 not
being disposed of as waste. Instead, they are currently being crushed to be
later used in the forest areas to cover access and internal circulation roads..
The final disposal given to the construction wastes, according to information
provided by Podium and documents reviewed, has been adequate, except for
asbestos-containing wastes. ERM observed a pile (approximately 50 m²) of
fiber-cement roof tiles on an unpaved area and evidenced that part of the
tiles are asbestos-containing and part asbestos-free (with synthetic fibers). It
is not possible to visually determine the percentage of each type. Asbestoscontaining construction waste is classified under Brazilian regulations as
hazardous waste and must be disposed of as such. Podium has not
developed a procedure for handling and disposal of asbestos-containing
wastes, that are being disposed of as non-hazardous waste.
PS 3 Paragraph 12
Federal CONAMA
which establishes the
criteria and soil quality
oriented values and
guidance for the
management of
contaminated areas.
As reported during the visit of the construction site and according to
documents reviewed, the future pulp mill will incorporate technical criteria
and construction features designed to prevent soil/groundwater
contamination. Among others, the following could be mentioned:

All the lagoons part of the wastewater and storm water collection and
treatment will be lined with compacted soil and synthetic membranes
(HDPE).

The wood yard will be paved and contained, being the storm water
runoff directed to a storm water lagoon (to be further treated or
discharged);

All production areas will be concrete paved and diked;

All chemicals storage tanks will be installed inside impermeable
containment basins.
None required
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Wastes

12.
The industrial landfill will be lined and equipped with a leak detection
system
A soil/groundwater monitoring plan was initiated after the earth works
completion and monitoring wells (piezometers) were installed as part of the
Basic Environmental Plan proposed in the Environmental Impact
Assessment and required by the State Environmental Agency - IMASUL. The
complete system will comprise the installation of thirty three piezometers
(until August 2011, 21 wells had already been installed). Soil and
groundwater 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 the
capillary fringe zone. No parameters exceeding the established reference
values (CONAMA Resolution 420/2009) were detected in the soil samples
analyzed.
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 several
monitoring wells (aluminum in 16, iron in 13 and manganese in 10 out of 21
wells). The occurrence of these metals is attributed to background conditions
and geological characteristics of the soil at the area where the pulp mill will
be installed.
Hazardous Materials Management
13.
Hazardous materials are sometimes used as raw material or produced
as product by the project. The client will avoid or, when avoidance is
not possible, minimize and control the release of hazardous materials.
In this context, the production, transportation, handling, storage, and
use of hazardous materials for project activities should be assessed.
The client will consider less hazardous substitutes where hazardous
materials are intended to be used in manufacturing processes or other
operations. The client will avoid the manufacture, trade, and use of
chemicals and hazardous materials subject to international bans or
phase-outs due to their high toxicity to living organisms,
environmental persistence, potential for bioaccumulation, or potential
for depletion of the ozone layer.
PS3 Paragraph 13
COMPLIANT
Chapter 9 of the Environmental Impact Assessment (EIA) presents a Risk
Assessment study developed for ELDORADO Cellulose Plant. The study
identified accidental scenarios related to the release of flammable materials
(methanol and diesel oil), proposed mitigating measures and established
emergency response procedures. The study also mentions that a HAZOP
(Hazards and Operability) study is being developed and will identify
potential process deviations and risks, and also recommendations to
minimize the risks.
A Quantitative Risk Assessment study was developed in July 2011 by
company AGR Engenharia as part of the Preliminary Environmental Study.
The study assessed the risks of the Pulp Mill Plant and the sodium chlorate
plant (Ilha Química) recently included in the project. This study also
evaluated the potential accidents that could result in the release of toxic and
flammable materials. A HAZID (hazards identification) was developed and
identified 197 risks, of which 68 are related to toxic or flammable material
release. Main chemical releases identified are: methanol, hydrogen, chlorine
dioxide, hydrochloric acid, diesel oil, hydrogen sulfide, natural gas and
liquefied petroleum gas. The study also developed a consequence modeling
of each of the 68 scenarios identified and verified that none of them have the
potential to affect communities. In order to prevent the accidental scenarios
identified and mitigate the risks, the study proposed several
recommendations.
The mitigating measures recommended in the Risk Assessment study
related to release of flammable materials must be accomplished during the
operating phase of the facility. In addition, after the HAZOP study
conclusion, all recommendations generated must be incorporated into the
process design in order to minimize the risks.
The recommendations proposed in the Quantitative Risk Assessment must
be accomplished during the operating phase of the facility.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 3 Paragraphs 14, 15,
16 and 17
NOT APPLICABLE
According to information provided by the site contacts, no pesticides are or
will be used at industrial complex.
During the site visit, ERM has not identified any pesticide storage area.
Pesticide Use and Management
14.
The client will, where appropriate, formulate and implement an
integrated pest management (IPM) and/or integrated vector
management (IVM) approach targeting economically significant pest
infestations and disease vectors of public health significance. The
client’s IPM and IVM program will integrate coordinated use of pest
and environmental information along with available pest control
methods, including cultural practices, biological, genetic, and, as a last
resort, chemical means to prevent economically significant pest
damage and/or disease transmission to humans and animals.
15.
When pest management activities include the use of chemical
pesticides, the client will select chemical pesticides that are low in
human toxicity, that are known to be effective against the target
species, and that have minimal effects on non-target species and the
environment. When the client selects chemical pesticides, the selection
will be based upon requirements that the pesticides be packaged in
safe containers, be clearly labelled for safe and proper use, and that the
pesticides have been manufactured by an entity currently licensed by
relevant regulatory agencies.
16.
The client will design its pesticide application regime to (i) avoid
damage to natural enemies of the target pest, and where avoidance is
not possible, minimize, and (ii) avoid the risks associated 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 in accordance with the Food and
Agriculture Organization’s International Code of Conduct on the
Distribution and Use of Pesticides or other GIIP.
17.
The client will not purchase, store, use, manufacture, or trade in
products that fall in WHO Recommended Classification of Pesticides
by 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 appropriate
controls on manufacture, procurement, or distribution and/or use of
these chemicals. These chemicals should not be accessible to personnel
without proper training, equipment, and facilities to handle, store,
apply, and dispose of these products properly.
Review against IFC Performance Standard 4 (Community Health, Safety, and Security)
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PARTIALLY COMPLIANT
The increase of transport flow on the inhabitant areas is assessed and
community is informed about it.
Awareness programs should be applied to employees, contractors, their
families and affected communities.
5.
The client will evaluate the risks and impacts to the health and safety
PS4, paragraph 5
of the Affected Communities during the project life-cycle and will
EHS Guidelines Paper
establish preventive and control measures consistent with good
and Pulp item 1.3
international industry practice (GIIP), such as in the World Bank
Group Environmental, Health and Safety Guidelines (EHS Guidelines)
or other internationally recognized sources. The client will identify
risks and impacts and propose mitigation measures that are
commensurate with their nature and magnitude. These measures will
favor the avoidance of risks and impacts over minimization.
There is a system to combat fire in place (fire brigade). Neighbors and local
government are informed on how to contact the fire brigade in case of fire.
Include workers providing transportation services on educational programs
related to STIs and prevention of fatalities and injuries.
There are measures in place to manage waste and to avoid dissemination of
water-borne diseases and endemic (as leishmaniasis and dengue).
The assessment of public health as detailed on these performance standards
is not commonly requested on license process.
ELDORADO is involving in the following programs/action:
 participating with the health surveillance system on a program to
combat leishmaniasis;
 provision of information about sexual transmitted illness (STIs) to
workers as part of the Program for Public Health and Safety;
 support the Tres Lagoas municipality to monitor Dengue and to
define 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 workers
about alcoholism, smoking, besides, monitoring workers occupational health
The social diagnosis assessment undertaken for the 7 municipalities were the
main farms are located indicates as the main vulnerability the lack of
appropriate health public facilities. ELDORADO has met with public
authorities to discuss local facility, areas that must be improved and projects
that could be supported by ELDORADO. Minutes of these meetings were
reviewed by ERM.
As reported in the PBA reports, ELDORADO has met with public authorities
to discuss local infrastructure, areas that must be improved and projects that
could 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.
Refer
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
COMPLIANT
Security techniques implemented on construction and predicted to
installation are appropriate to this kind of projects
The protection techniques adopted at the project, lining of treatment pounds
and landfill, storm water contamination treatment, are designed and
constructed to avoid risk that could impact community health and safety.
The site is designed to be accessible to disable people once construction
phase is over.
None
COMPLIANT
The EIA, chapter 9, describe the risk assessment and canaries of community
exposure to risk of hazardous material during transportation (methanol,
sulfuric acid, caustic soda). Mitigate measures were recommended.
Refer to PS3 Paragraph 13.
Refer to PS3 Paragraph 13.
Infrastructure and Equipment Design and Safety
6.
The client will design, construct, operate, and decommission the
structural elements or components of the project in accordance with
GIIP, taking into consideration safety risks to third parties or Affected
Communities. When new buildings and structures will be accessed by
members of the public, the client will consider incremental risks of the
public’s potential exposure to operational accidents and/or natural
hazards and be consistent with the principles of universal access.
Structural elements will be designed and constructed by competent
professionals, and certified or approved by competent authorities or
professionals. When structural elements or components, such as dams,
tailings dams, or ash ponds are situated in high-risk locations, and
their failure or malfunction may threaten the safety of communities,
the client will engage one or more external experts with relevant and
recognized experience in similar projects, separate from those
responsible for the design and construction, to conduct a review as
early as possible in project development and throughout the stages of
project design, construction, operation, and decommissioning. For
projects that operate moving equipment on public roads and other
forms of infrastructure, the client will seek to avoid the occurrence of
incidents and injuries to members of the public associated with the
operation of such equipment.
Hazardous Materials Management and Safety
7.
The client will avoid or minimize the potential for community
exposure to hazardous materials and substances that may be released
by the project. Where there is a potential for the public (including
workers and their families) to be exposed to hazards, particularly those
that may be life-threatening, the client will exercise special care to
avoid or minimize their exposure by modifying, substituting, or
eliminating the condition or material causing the potential hazards.
Where hazardous materials are part of existing project infrastructure or
components, the client will exercise special care when conducting
decommissioning activities in order to avoid exposure to the
community. The client will exercise commercially reasonable efforts to
control the safety of deliveries of hazardous materials, and of
transportation and disposal of hazardous wastes, and will implement
measures to avoid or control community exposure to pesticides, in
accordance with the requirements of Performance Standard 3.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Ecosystem Services
8.
The project’s direct impacts on priority ecosystem services may result
in adverse health and safety risks and impacts to Affected
Communities. With respect to this Performance Standard, ecosystem
services are limited to provisioning and regulating services as defined
in paragraph 2 of Performance Standard 6. For example, land use
changes or the loss of natural buffer areas such as wetlands,
mangroves, and upland forests that mitigate the effects of natural
hazards such as flooding, landslides, and fire, may result in increased
vulnerability and community safety-related risks and impacts. The
diminution or degradation of natural resources, such as adverse
impacts on the quality, quantity, and availability of freshwater, may
result in health-related risks and impacts. Where appropriate and
feasible, the client will identify those risks and potential impacts on
priority ecosystem services that may be exacerbated by climate change.
Adverse impacts should be avoided, and if these impacts are
unavoidable, the client will implement mitigation measures in
accordance 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 with
paragraphs 25–29 of Performance Standard 5.
Refer to PS 6, paragraphs 6 and 7
Community Exposure to Disease
9.
10.
PS4, paragraph 9
exposure to water-borne, water-based, water-related, and vector-borne
diseases, and communicable diseases that could result from project
activities, taking into consideration differentiated exposure to and
higher sensitivity of vulnerable groups. Where specific diseases are
endemic in communities in the project area of influence, the client is
encouraged to explore opportunities during the project life-cycle to
improve environmental conditions that could help minimize their
incidence.
The client will avoid or minimize transmission of communicable
diseases that may be associated with the influx of temporary or
permanent project labor.
None
PS4, paragraph 10
11.
In addition to the emergency preparedness and response requirements PS4, paragraph 11
described in Performance Standard 1, the client will also assist and
collaborate with the Affected Communities, local government
agencies, and other relevant parties, in their preparations to respond
effectively to emergency situations, especially when their participation
and collaboration are necessary to respond to such emergency
situations. If local government agencies have little or no capacity to
respond effectively, the client will play an active role in preparing for
and responding to emergencies associated with the project. The client
will document its emergency preparedness and response activities,
resources, and responsibilities, and will disclose appropriate
information to Affected Communities, relevant government agencies,
or other relevant parties.
COMPLIANT
CONSTRUCTION STAGE AND OPERATION STAGE
The contractor DuPont, which was hired to manage health and safety issues
during the construction stage, developed an Emergency Response Plan for
the construction works, identifying hazard conditions, basic procedures for
emergency situations, definition of responsibilities, material assets
preservation, training, resources and minimization of emergency impacts.
Several accident scenarios have been considered, such as chemicals release,
fire and accidents involving employees, among others. Emergency
procedures 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 completed
and adapted for the operation stage.
Although the risk analysis developed for the pulp mill has not identified
accident scenarios with the potential to affect external communities, the
Emergency plan prepared for the operation stage should cover assistance to
nearby communities and cooperation with local authorities, emergency
services and other potentially affected stakeholders.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
When the client retains direct or contracted workers to provide
PS4, paragraph 12
security to safeguard its personnel and property, it will assess risks
posed by its security arrangements to those within and outside the
project site. In making such arrangements, the client will be guided by
the principles of 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 to ensure 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 Affected Communities; and require them to act
within the applicable law. The client will not sanction any use of force
except when used for preventive and defensive purposes in proportion
to the nature and extent of the threat. The client will provide a
grievance mechanism for Affected Communities to express concerns
about the security arrangements and acts of security personnel.
PARTIALLY COMPLIANT
Meta is in charge to manage the site support facilities, which include the
security personnel arrangements, provided by Security. Reportedly, Meta is
in charge to verify the documents of those providing security.
Security personnel arrangements is provided at the site and the 3
accommodations managed by ELDORADO. Those providing security are in
charge to supervise the access to the site and accommodation.
ELDORADO does not provide training to security personnel, neither there is
a systemic procedure to verify if those providing security are not involved in
past abuses.
Ensure the grievance procedure and Stakeholder Engagement Plan (PS1
Paragh 25) are designed to identify any concerns from local government,
13.
The client will assess and document risks arising from the project’s use PS4, paragraph 13
of government security personnel deployed to provide security
services. The client will seek to ensure that security personnel will act
in a manner consistent with paragraph 12 above, and encourage the
relevant public authorities to disclose the security arrangements for the
client’s facilities to the public, subject to overriding security concerns.
NOT APPLICABLE
The project will not use government security personnel to provide security
services.
14.
The client will consider and, where appropriate, investigate all
allegations of unlawful or abusive acts of security personnel, take
action (or urge appropriate parties to take action) to prevent
recurrence, and report unlawful and abusive acts to public authorities.
PARTIALLY COMPLIANT
There is a grievance mechanism to workers that can receive complaint about
security personnel abuses. ELDORADO informed that all grievances
received are treated and investigated. If the abuse or inadequate behavior is
proved, the person providing security might be removed to another position
or dismissed.
ELDORADO has no procedure to investigate and treat cases of human right
abuses, if committed by those providing security personnel, neither to
communicate public authority about it.
Security Personnel
12.
PS4, paragraph 14
Define procedures on the correct code of conduct and use of the force by
security personnel. This shall include measures to investigate and address
any complaints regarding potential human right abuses committed by those
providing security.
To monitor those providing security arrangement to identify compliance
with the above mentioned procedures.
Review against IFC Performance Standard 5 (Land Acquisition and Involuntary Resettlement)
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
COMPLIANT
ELDORADO is installed in a 900 hectare area. This area was bought by
ELDORADO and was part of a cattle raising farm.
ELDORADO informed that there were 3 houses in the farm in which 3
workers families leaved in. According to ELDORADO, those families were
removed to the part of the farm that still belongs to the farm’s previous
owner.
The EIA has no information about resettlement, physical or economical,
which suggests that no resettlement was carried about to ELDORADO
installation.
Reportedly, there is no judicial land dispute.
None
General
Project Design
8.
The client will consider feasible alternative project designs to avoid or
minimize physical and/or economic displacement, while balancing
environmental, social, and financial costs and benefits, paying
particular attention to impacts on the poor and vulnerable.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Compensation and Benefits for Displaced Persons
9.
When displacement cannot be avoided, the client will offer displaced
communities and person’s compensation for loss of assets at full
replacement cost and other assistance to help them improve or restore
their standards of living or livelihoods, as provided in this
Performance Standard. Compensation standards will be transparent
and applied consistently to all communities and persons affected by
the displacement. Where livelihoods of displaced persons are landbased, or where land is collectively owned, the client will, where
feasible, offer the displaced land-based compensation. The client will
take possession of acquired land and related assets only after
compensation has been made available and, where applicable,
resettlement sites and moving allowances have been provided to the
displaced persons in addition to compensation. The client will also
provide opportunities to displaced communities and persons to derive
appropriate development benefits from the project.
NOT APPLICABLE
Items below are not applicable because no physical or economic resettlement
was carried out.
Community Engagement
10.
The client will engage with Affected Communities, including host
communities, through the process of stakeholder engagement
described in Performance Standard 1. Decision-making processes
related to resettlement and livelihood restoration should include
options and alternatives, where applicable. Disclosure of relevant
information and participation of Affected Communities and persons
will continue during the planning, implementation, monitoring, and
evaluation of compensation payments, livelihood restoration activities,
and resettlement to achieve outcomes that are consistent with the
objectives of this Performance Standard.16 Additional provisions
apply to consultations with Indigenous Peoples, in accordance with
NOT APPLICABLE
Grievance Mechanism
11.
The client will establish a grievance mechanism consistent with
Performance Standard 1 as early as possible in the project development
phase. This will allow the client to receive and address specific
concerns about compensation and relocation raised by displaced
persons or members of host communities in a timely fashion, including
a recourse mechanism designed to resolve disputes in an impartial
manner.
NOT APPLICABLE
Resettlement and Livelihood Restoration Planning and Implementation
12.
Where involuntary resettlement is unavoidable, either as a result of a
negotiated settlement or expropriation, a census will be carried out to
collect appropriate socio-economic baseline data to identify the
persons who will be displaced by the project, determine who will be
eligible for compensation and assistance, and discourage ineligible
persons, such as opportunistic settlers, from claiming benefits. In the
absence of host government procedures, the client will establish a cutoff date for eligibility. Information regarding the cut-off date will be
well documented and disseminated throughout the project area.
NOT APPLICABLE
13.
In cases where affected persons reject compensation offers that meet
the requirements of this Performance Standard and, as a result,
expropriation or other legal procedures are initiated, the client will
explore opportunities to collaborate with the responsible government
agency, and, if permitted by the agency, play an active role in
resettlement planning, implementation, and monitoring (see
paragraphs 30–32).
NOT APPLICABLE
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
No:
14.
The client will establish procedures to monitor and evaluate the
implementation of a Resettlement Action Plan or Livelihood
Restoration Plan (see paragraphs 19 and 25) and take corrective action
as necessary. The extent of monitoring activities will be commensurate
with the project’s risks and impacts. For projects with significant
involuntary resettlement risks, the client will retain competent
resettlement professionals to provide advice on compliance with this
Performance Standard and to verify the client’s monitoring
information. Affected persons will be consulted during the monitoring
process.
NOT APPLICABLE
15.
Implementation of a Resettlement Action Plan or Livelihood
Restoration Plan will be considered completed when the adverse
impacts of resettlement have been addressed in a manner that is
consistent with the relevant plan as well as the objectives of this
Performance Standard. It may be necessary for the client to
commission an external completion audit of the Resettlement Action
Plan or Livelihood Restoration Plan to assess whether the provisions
have been met, depending on the scale and/or complexity of physical
and economic displacement associated with a project. The completion
audit should be undertaken once all mitigation measures have been
substantially completed and once displaced persons are deemed to
have been provided adequate opportunity and assistance to
sustainably restore their livelihoods. The completion audit will be
undertaken by competent resettlement professionals once the agreed
monitoring period is concluded. The completion audit will include, at
a minimum, a review of the totality of mitigation measures
implemented by the Client, a comparison of implementation outcomes
against agreed objectives, and a conclusion as to whether the
monitoring process can be ended
NOT APPLICABLE
16.
Where the exact nature or magnitude of the land acquisition or
restrictions on land use related to a project with potential to cause
physical and/or economic displacement is unknown due to the stage
of project development, the client will develop a Resettlement and/or
Livelihood Restoration Framework outlining general principles
compatible with this Performance Standard. Once the individual
project components are defined and the necessary information
becomes available, such a framework will be expanded into a specific
Resettlement Action Plan or Livelihood Restoration Plan and
procedures in accordance with paragraphs 19 and 25 below.
NOT APPLICABLE
Displacement
17.
Displaced persons may be classified as persons (i) who have formal
legal rights to the land or assets they occupy or use; (ii) who do not
have formal legal rights to land or assets, but have a claim to land that
is recognized or recognizable under national law; or (iii) who have no
recognizable legal right or claim to the land or assets they occupy or
use. The census will establish the status of the displaced persons.
NOT APPLICABLE
18.
Project-related land acquisition and/or restrictions on land use may
result in the physical displacement of people as well as their economic
displacement. Consequently, requirements of this Performance
Standard in respect of physical displacement and economic
displacement may apply simultaneously.
NOT APPLICABLE
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Physical Displacement
19.
In the case of physical displacement, the client will develop a
Resettlement Action Plan that covers, at a minimum, the applicable
requirements of this Performance Standard regardless of the number of
people affected. This will include compensation at full replacement
cost for land and other assets lost. The Plan will be designed to
mitigate the negative impacts of displacement; identify development
opportunities; develop a resettlement budget and schedule; and
establish the entitlements of all categories of affected persons
(including host communities). Particular attention will be paid to the
needs of the poor and the vulnerable. The client will document all
transactions to acquire land rights, as well as compensation measures
and relocation activities.
NOT APPLICABLE
20.
If people living in the project area are required to move to another
location, the client will (i) offer displaced persons choices among
feasible resettlement options, including adequate replacement housing
or cash compensation where appropriate; and (ii) provide relocation
assistance suited to the needs of each group of displaced persons. New
resettlement sites built for displaced persons must offer improved
living conditions. The displaced persons’ preferences with respect to
relocating in pre-existing communities and groups will be taken into
consideration. Existing social and cultural institutions of the displaced
persons and any host communities will be respected.
NOT APPLICABLE
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 or
higher 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. Cash
compensation levels should be sufficient to replace the lost land and
other assets at full replacement cost in local markets.
NOT APPLICABLE
22.
In the case of physically displaced persons under paragraph 17 (iii), the
client will offer them a choice of options for adequate housing with
security of tenure so that they can resettle legally without having to
face the risk of forced eviction. Where these displaced persons own
and occupy structures, the client will compensate them for the loss of
assets other than land, such as dwellings and other improvements to
the land, at full replacement cost, provided that these persons have
been occupying the project area prior to the cut-off date for eligibility.
Based on consultation with such displaced persons, the client will
provide relocation assistance sufficient for them to restore their
standard of living at an adequate alternative site.
NOT APPLICABLE
23.
The client is not required to compensate or assist those who encroach
on the project area after the cut-off date for eligibility, provided the
cut-off date has been clearly established and made public.
NOT APPLICABLE
24.
Forced evictions will not be carried out except in accordance with law
and the requirements of this Performance Standard.
NOT APPLICABLE
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
25.
In the case of projects involving economic displacement only, the client
will develop a Livelihood Restoration Plan to compensate affected
persons and/or communities and offer other assistance that meets the
objectives of this Performance Standard. The Livelihood Restoration
Plan will establish the entitlements of affected persons and/or
communities and will ensure that these are provided in a transparent,
consistent, and equitable manner. The mitigation of economic
displacement will be considered complete when affected persons or
communities have received compensation and other assistance
according to the requirements of the Livelihood Restoration Plan and
this Performance Standard, and are deemed to have been provided
with adequate opportunity to re-establish their livelihoods.
NOT APPLICABLE
26.
If land acquisition or restrictions on land use result in economic
displacement defined as loss of assets and/or means of livelihood,
regardless of whether or not the affected people are physically
displaced, the client will meet the requirements in paragraphs 27–29
below, as applicable.
NOT APPLICABLE
27.
Economically displaced persons who face loss of assets or access to
assets will be compensated for such loss at full replacement cost.
 In cases where land acquisition or restrictions on land use affect
commercial structures, affected business owners will be
compensated for the cost of re-establishing commercial activities
elsewhere, for lost net income during the period of transition, and
for 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 which
are recognized or recognizable under national law (see paragraph
17 (i) and (ii)), replacement property (e.g., agricultural or
commercial sites) of equal or greater value will be provided, or,
where appropriate, cash compensation at full replacement cost.
 Economically displaced persons who are without legally
recognizable claims to land (see paragraph 17 (iii)) will be
compensated 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 or assist opportunistic settlers who encroach on the
project area after the cut-off date for eligibility.
NOT APPLICABLE
28.
In addition to compensation for lost assets, if any, as required under
paragraph 27, economically displaced persons whose livelihoods or
income levels are adversely affected will also be provided
opportunities to improve, or at least restore, their means of incomeearning capacity, production levels, and standards of living:
 For persons whose livelihoods are land-based, replacement land
that has a combination of productive potential, locational
advantages, and other factors at least equivalent to that being lost
should be offered as a matter of priority.
 For persons whose livelihoods are natural resource-based and
where project-related restrictions on access envisaged in paragraph
5 apply, implementation of measures will be made to either allow
continued access to affected resources or provide access to
alternative resources with equivalent livelihood-earning potential
and accessibility. Where appropriate, benefits and compensation
associated with natural resource usage may be collective in nature
rather than directly oriented towards individuals or households.
NOT APPLICABLE
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
28.

29.
Transitional support should be provided as necessary to all
economically displaced persons, based on a reasonable estimate of the
time required to restore their income-earning capacity, production
levels, and standards of living.
If circumstances prevent the client from providing land or similar
resources as described above, alternative income earning
opportunities may be provided, such as credit facilities, training,
cash, or employment opportunities. Cash compensation alone,
however, is frequently insufficient to restore livelihoods.
NOT APPLICABLE
Private Sector Responsibilities Under Government-Managed Resettlement
30.
Where land acquisition and resettlement are the responsibility of the
outcomes that are consistent with this Performance Standard. In
addition, where government capacity is limited, the client will play an
active role during resettlement planning, implementation, and
monitoring, as described below.
NOT APPLICABLE
31.
In the case of acquisition of land rights or access to land through
compulsory means or negotiated settlements involving physical
displacement, the client will identify and describe government
resettlement measures. If these measures do not meet the relevant
requirements of this Performance Standard, the client will prepare a
Supplemental Resettlement Plan that, together with the documents
prepared by the responsible government agency, will address the
relevant requirements of this Performance Standard (the General
Requirements and requirements for Physical Displacement and
Economic Displacement above). The client will need to include in its
Supplemental Resettlement Plan, at a minimum (i) identification of
affected people and impacts; (ii) a description of regulated activities,
including the entitlements of displaced persons provided under
applicable national laws and regulations; (iii) the supplemental
measures to achieve the requirements of this Performance Standard as
described in paragraphs 19–29 in a way that is permitted by the
responsible agency and implementation time schedule; and (iv) the
financial and implementation responsibilities of the client in the
execution of its Supplemental Resettlement Plan.
NOT APPLICABLE
32.
will identify and describe the measures that the responsible
government agency plans to use to compensate Affected Communities
and persons. If these measures do not meet the relevant requirements
of this Performance Standard, the client will develop an Environmental
and Social Action Plan to complement government action. This may
include additional compensation for lost assets, and additional efforts
to restore lost livelihoods where applicable.
NOT APPLICABLE
Review against IFC Performance Standard 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources)
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 6, paragraphs 6 and 7
EHS Guidelines for
Forest Harvesting
Operations
PARTIALLY COMPLIANT
Evaluate potentially impacts on ecosystem services through the existing
studies (Industrial and Forest operations) and the data obtained in the
According to the EIA, the studies conducted during the previous license
implementation of the environmental programs.
showed only the initial situation of the area of influence and allow only a
general prediction of the impacts on biodiversity (related to the change in the
land use, increase in the nuisance to native species and restrictions to
resources usage). The reports of the monitoring programs (PBA) allow
comparisons of data, yet still are not related to ecosystems services.
General
6.
The risks and impacts identification process as set out in Performance
Standard 1 should consider direct and indirect project-related impacts
on biodiversity and ecosystem services and identify any significant
residual impacts. This process will consider relevant threats to
biodiversity and ecosystem services, especially focusing on habitat
loss, degradation and fragmentation, invasive alien species,
overexploitation, hydrological changes, nutrient loading, and
pollution. It will also take into account the differing values attached to
biodiversity and ecosystem services by Affected Communities and,
where appropriate, other stakeholders. Where paragraphs 13–19 are
applicable, the client should consider project-related impacts across the
potentially affected landscape or seascape.
7.
As a matter of priority, the client should seek to avoid impacts on
biodiversity and ecosystem services. When avoidance of impacts is not
possible, measures to minimize impacts and restore biodiversity and
ecosystem services should be implemented. Given the complexity in
predicting project impacts on biodiversity and ecosystem services over
the long term, the client should adopt a practice of adaptive
management in which the implementation of mitigation and
management measures are responsive to changing conditions and the
results of monitoring throughout the project’s lifecycle.
8.
Where paragraphs 13–15 are applicable, the client will retain
competent professionals to assist in conducting the risks and impacts
identification process. Where paragraphs 16–19 are applicable, the
client should retain external experts with appropriate regional
experience to assist in the development of a mitigation hierarchy that
complies with this Performance Standard and to verify the
implementation of those measures.
Licensing process does not require and does not include identification and
analysis of impacts on eco-system services. Therefore there is no information
regarding this issue in the documentation presented.
See PS6, paragraphs 1315
See PS6, paragraphs 13-15
EHS Guidelines for
Forest Harvesting
Operations
COMPLIANT
According to documentation and information provided during site visit,
compensation has been done and from the legal point of view ELDORADO
is in compliance. However, ERM was not able to verify if the seedling
nursery operated by City Hall (due to timing and distance constraints),
which was object of the compensation, is destined to produce native species
for recovery of natural vegetation.
As required by this item, offset or compensation measures should achieve a
measurable conservation outcome. Although the seedling nursery belongs
to the City Hall and ELDORADO financially supports it, the company
should monitor if the seedlings are contributing to the recovery of natural
vegetation (i.e. recuperation of preservation areas, conservation units). This
monitoring may be done through periodic audits at the seedling nursery.
9.
Habitat is defined as a terrestrial, freshwater, or marine geographical
unit or airway that supports assemblages of living organisms and their
interactions with the non-living environment. For the purposes of
implementation of this Performance Standard, habitats are divided
into modified, natural, and critical. Critical habitats are a subset of
modified or natural habitats.
10.
For the protection and conservation of biodiversity, the mitigation
hierarchy includes biodiversity offsets, which may be considered only
after appropriate avoidance, minimization, and restoration measures
have been applied. A biodiversity offset should be designed and
implemented to achieve measurable conservation outcomes that can
reasonably be expected to result in no net loss and preferably a net
gain of biodiversity; however, a net gain is required in critical habitats.
The design of a biodiversity offset must adhere to the “like-for-like or
better” principle and must be carried out in alignment with best
available information and current practices. When a client is
considering the development of an offset as part of the mitigation
strategy, external experts with knowledge in offset design and
implementation must be involved.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PARTIALLY COMPLIANT
The EIA presents quantitative data on fauna and flora.
The EIA evaluated the impacts on flora and fauna (vegetation removal), as
minor, and did not evaluate impacts on biodiversity, considering that the
project is located in an area previously modified. It also presents mitigation
and management actions.
PBA presents monitoring programs in order to minimize the impacts and
risks identified.
Evaluate potentially impacts on biodiversity through the existing studies
(Industrial and Forest operations) and the data obtained in the
implementation of the environmental programs.
Modified Habitat
11.
Modified habitats are areas that may contain a large proportion of
plant and/or animal species of non-native origin, and/or where
12
human activity has substantially modified an area’s primary ecological
functions and species composition. Modified habitats may include
areas managed for agriculture, forest plantations, reclaimed coastal
zones, and reclaimed wetlands.
12.
This Performance Standard applies to those areas of modified habitat
that include significant biodiversity value, as determined by the risks
and impacts identification process required in Performance Standard
1. The client should minimize impacts on such biodiversity and
implement mitigation measures as appropriate.
Some modified habitats might contain high biodiversity values or areas that
trigger a critical habitat designation.
Natural Habitat
13.
Natural habitats are areas composed of viable assemblages of plant
and/or animal species of largely native origin, and/or where human
activity has not essentially modified an area’s primary ecological
functions 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 for
development of the project on modified habitat;
 Consultation has established the views of stakeholders, including
Affected Communities, with respect to the extent of conversion and
degradation; and
 Any conversion or degradation is mitigated according to the
mitigation hierarchy.
15.
In areas of natural habitat, mitigation measures will be designed to
achieve no net loss of biodiversity where feasible. Appropriate actions
include:
 Avoiding impacts on biodiversity through the identification and
protection of set-asides;
 Implementing measures to minimize habitat fragmentation, such as
biological corridors;
 Restoring habitats during operations and/or after operations; and
 Implementing biodiversity offsets.
and 15
NOT APPLICABLE
The EIA reports that the area has been previously modified and therefore
considered as modified habitat. Therefore this item is not applicable.
Critical Habitat
16.
Critical habitats are areas with high biodiversity value, including (i)
habitat of significant importance to Critically Endangered and/or
Endangered species; (ii) habitat of significant importance to endemic
and/or restricted-range species; (iii) habitat supporting globally
significant concentrations of migratory species and/or congregatory
species; (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 project
activities unless all of the following are demonstrated:
development of the project on modified or natural habitats that are
not critical;
 The project does not lead to measurable adverse impacts on those
biodiversity values for which the critical habitat was designated,
and on the ecological processes supporting those biodiversity
values;
PS 6, paragraphs 16 to 19 NOT APPLICABLE
The EIA reports that the area has been previously modified and therefore
considered as modified habitat. Therefore this item is not applicable.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PS 6, paragraph 20
Federal Law nº 4771,
September 15th, 1965 and
alterations
Federal Law nº 6.938,
August 31st, 1981 and
alterations
Conama Resolution nº
369, March 28th, 2006
April 27th,1981
COMPLIANT
According to documentation seen on site visit and information provided by ELDORADO should adopt measures to avoid/eliminate disturbing factors
ELDORADO, the Legal Reserve of the site has term of provisional
and monitor if natural regeneration occurs, and prepare a recovery plan, if
registration of the legal reserve for existing area of 81,5336 ha. Reportedly,
necessary.
the area has been georeferenced, but not delimited by fence and according to
the law the company is not obliged to recover the area. Also, according to
lay-out and information provided during site visit the Permanent
Preservation Area (PPA), of 200m from the riverside, is being respected.
ELDORADO is not actively managing the lands to bring the PPA and the
Legal reserve back into their natural state, based on a report that concludes
that in Cerrado biome is better to leave them for natural reforestation.
Critical Habitat
17.


The project does not lead to a net reduction in the global and/or
national/regional population of any Critically Endangered or
Endangered species over a reasonable period of time; and
A robust, appropriately designed, and long-term biodiversity
monitoring and evaluation program is integrated into the client’s
management program.
18.
In such cases where a client is able to meet the requirements defined in
paragraph 17, the project’s mitigation strategy will be described in a
Biodiversity Action Plan and will be designed to achieve net gains of
those biodiversity values for which the critical habitat was designated.
19.
In instances where biodiversity offsets are proposed as part of the
mitigation strategy, the client must demonstrate through an
assessment that the project’s significant residual impacts on
biodiversity will be adequately mitigated to meet the requirements of
paragraph 17.
Legally Protected and Internationally Recognized Areas
20.
In circumstances where a proposed project is located within a legally
protected area or an internationally recognized area, the client will
meet the requirements of paragraphs 13 through 19 of this
Performance Standard, as applicable. In addition, the client will:
 Demonstrate that the proposed development in such areas is
legally permitted;
 Act in a manner consistent with any government recognized
management plans for such areas;
 Consult protected area sponsors and managers, Affected
Communities, Indigenous Peoples and other stakeholders on the
proposed project, as appropriate; and
 Implement additional programs, as appropriate, to promote and
enhance the conservation aims and effective management of the
area.
Natural regeneration of the bioma Cerrado can occur once there is a near
sources of propagates (other Cerrado areas surrounding). If natural
regeneration is the intent, then measures should be adopted to
avoid/eliminate disturbing factors (eg fire, opening trails, movement of
domesticated animals like cattle and horses).
Invasive Alien Species
21.
Intentional or accidental introduction of alien, or non-native, species of PS 6, paragraphs 21 to 23 NOT APPLICABLE
flora and fauna into areas where they are not normally found can be a
No information about invasive species was identified in the EIA and PBA
significant threat to biodiversity, since some alien species can become
presented.
invasive, spreading rapidly and out-competing native species.
22.
The client will not intentionally introduce any new alien species (not
currently established in the country or region of the project) unless this
is carried out in accordance with the existing regulatory framework for
such introduction. Notwithstanding the above, the client will not
deliberately introduce any alien species with a high risk of invasive
behavior regardless of whether such introductions are permitted under
the existing regulatory framework. All introductions of alien species
will be subject to a risk assessment (as part of the client’s
environmental and social risks and impacts identification process) to
determine the potential for invasive behavior. The client will
implement measures to avoid the potential for accidental or
unintended introductions including the transportation of substrates
and vectors (such as soil, ballast, and plant materials) that may harbor
alien species.
No:
23.
Where alien species are already established in the country or region of
the proposed project, the client will exercise diligence in not spreading
them into areas in which they have not already been established. As
practicable, the client should take measures to eradicate such species
from the natural habitats over which they have management control.
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Management of Ecosystem Services
24.
Where a project is likely to adversely impact ecosystem services, as
determined by the risks and impacts identification process, the client
25
will conduct a systematic review to identify priority ecosystem
services. Priority ecosystem services are two-fold: (i) those services on
which 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
for its operations (e.g., water). When Affected Communities are likely
to be impacted, they should participate in the determination of priority
ecosystem services in accordance with the stakeholder engagement
process as defined in Performance Standard 1.
25.
With respect to impacts on priority ecosystem services of relevance to
Affected Communities and where the client manages directly or have
significant influence over such ecosystem services, adverse impacts
should be avoided. If these impacts are unavoidable, the client will
minimize them and implement mitigation measures that aim to
maintain the value and functionality of priority services. With respect
to impacts on priority ecosystem services on which the project
depends, clients should minimize impacts on ecosystem services and
implement measures that increase resource efficiency of their
operations, as described in Performance Standard 3. Additional
provisions for ecosystem services are included in Performance
Standards 4, 5, 7, and 8.
Considerations regarding the analysis of impacts on ecosystem services are
presented on PS 6 paragraphs 6 and 7.
Sustainable Management of Living Natural Resources
26.
Clients who are engaged in the primary production of living natural
PS 6, paragraphs 26-30
resources, including natural and plantation forestry, agriculture,
animal husbandry, aquaculture, and fisheries, will be subject to the
requirements of paragraphs 26 through 30, in addition to the rest of
this Performance Standard. Where feasible, the client will locate landbased agribusiness and forestry projects on unforested land or land
already converted. Clients who are engaged in such industries will
manage living natural resources in a sustainable manner, through the
application of industry-specific good management practices and
available technologies. Where such primary production practices are
codified in globally, regionally, or nationally recognized standards, the
client will implement sustainable management practices to one or
more relevant and credible standards as demonstrated by independent
verification or certification.
27.
Credible globally, regionally, or nationally recognized standards for
sustainable management of living natural resources are those which (i)
are objective and achievable; (ii) are founded on a multi-stakeholder
consultative process; (iii) encourage step-wise and continual
improvements; and (iv) provide for independent verification or
certification through appropriate accredited bodies for such standards.
28.
Where relevant and credible standard(s) exist, but the client has not yet
obtained independent verification or certification to such standard(s),
the client will conduct a pre-assessment of its conformity to the
applicable standard(s) and take actions to achieve such verification or
certification over an appropriate period of time.
NOT APPLICABLE
The project is not engaged in the activities described in these requirements.
See assessment on Forestry Operations (Annex C)
No:
29.
In the absence of a relevant and credible global, regional, or national
standard for the particular living natural resource in the country
concerned, the client will:
 Commit to applying good international industry operating
principles, management practices, and technologies; and
 Actively engage and support the development of a national
standard, where relevant, including studies that contribute to the
definition and demonstration of sustainable practices.
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Supply Chain
30.
For further information about wood supply, refer to Annex C Gap
Analysis Table Forest Operation, PS6 paragraph 30.
Where a client is purchasing primary production (especially but not
exclusively food and fiber commodities) that is known to be produced
in regions where there is a risk of significant conversion of natural
and/or critical habitats, systems and verification practices will be
adopted as part of the client’s ESMS to evaluate its primary
suppliers.21 The systems and verification practices will (i) identify
where 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 that
they are not contributing to significant conversion of natural and/or
critical habitats (this may be demonstrated by delivery of certified
product, or progress towards verification or certification under a
credible scheme in certain commodities and/or locations); and (iv)
where possible, require actions to shift the client’s primary supply
chain over time to suppliers that can demonstrate that they are not
significantly adversely impacting these areas. The ability of the client
to fully address these risks will depend upon the client’s level of
management control or influence over its primary suppliers.
Review against IFC Performance Standard 7 (Indigenous Peoples)
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
None.
General
Avoidance of Adverse Impacts
8.
The client will identify, through an environmental and social risks and PS 7, paragraphs 8 to 22
impacts assessment process, all communities of Indigenous Peoples
within the project area of influence who may be affected by the project,
as well as the nature and degree of the expected direct and indirect
economic, social, cultural (including cultural heritage), and
environmental impacts on them.
COMPLIANT
As described on PS1, paragraph 32, an archeological survey has been
conducted in December 2011, and identified that there was no indigenous
groups or traditional people affected by ELDORADO’s operation. It
identified one indigenous group in the municipality of Brasilandia named
Ofayé-Xavante, 96 km away from ELDORADO industrial site.
9.
Adverse impacts on Affected Communities of Indigenous Peoples
should be avoided where possible. Where alternatives have been
explored and adverse impacts are unavoidable, the client will
minimize, restore, and/or compensate for these impacts in a culturally
appropriate manner commensurate with the nature and scale of such
impacts and the vulnerability of the Affected Communities of
Indigenous Peoples. The client’s proposed actions will be developed
with the ICP of the Affected Communities of Indigenous Peoples and
contained in a time-bound plan, such as an Indigenous Peoples Plan,
or a broader community development plan with separate components
for Indigenous Peoples.
NOT APPLICABLE
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Participation and Consent
10.
The client will undertake an engagement process with the Affected
Communities of Indigenous Peoples as required in Performance
Standard 1. This engagement process includes stakeholder analysis
and engagement planning, disclosure of information, consultation, and
participation, in a culturally appropriate manner. In addition, this
process will:
 Involve Indigenous Peoples’ representative bodies and
organizations (e.g., councils of elders or village councils), as well as
members of the Affected Communities of Indigenous Peoples; and
 Provide sufficient time for Indigenous Peoples’ decision-making
processes.
NOT APPLICABLE
General
11.
Affected Communities of Indigenous Peoples may be particularly
vulnerable to the loss of, alienation from or exploitation of their land
and access to natural and cultural resources. In recognition of this
vulnerability, in addition to the General Requirements of this
Performance Standard, the client will obtain the FPIC of the Affected
Communities of Indigenous Peoples in the circumstances described in
paragraphs 13–17 of this Performance Standard. FPIC applies to project
design, implementation, and expected outcomes related to impacts
affecting the communities of Indigenous Peoples. When any of these
circumstances apply, the client will engage external experts to assist in
the identification of the project risks and impacts.
NOT APPLICABLE
12.
There is no universally accepted definition of FPIC. For the purposes of
Performance Standards 1, 7 and 8, “FPIC” has the meaning described
in this paragraph. FPIC builds on and expands the process of ICP
described in Performance Standard 1 and will be established through
good faith negotiation between the client and the Affected
Communities of Indigenous Peoples. The client will document: (i) the
mutually accepted process between the client and Affected
Communities of Indigenous Peoples, and (ii) evidence of agreement
between the parties as the outcome of the negotiations. FPIC does not
necessarily require unanimity and may be achieved even when
individuals or groups within the community explicitly disagree.
NOT APPLICABLE
Circumstances Requiring Free, Prior, and Informed Consent
Impacts on Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use
13.
Indigenous Peoples are often closely tied to their lands and related
natural resources. Frequently, these lands are traditionally owned or
under customary use. While Indigenous Peoples may not possess legal
title 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 and
community, can often be substantiated and documented.
NOT APPLICABLE
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
14.
If the client proposes to locate a project on, or commercially develop
natural resources on lands traditionally owned by, or under the
customary use of, Indigenous Peoples, and adverse impacts can be
expected, the client will take the following steps:
 Document efforts to avoid and otherwise minimize the area of land
proposed for the project;
 Document efforts to avoid and otherwise minimize impacts on
natural resources and natural areas of importance to Indigenous
People;
 Identify and review all property interests and traditional resource
uses prior to purchasing or leasing land;
 Assess and document the Affected Communities of Indigenous
Peoples’ resource use without prejudicing any Indigenous Peoples’
land claim. The assessment of land and natural resource use should
be gender inclusive and specifically consider women’s role in the
management and use of these resources;
 Ensure that Affected Communities of Indigenous Peoples are
informed of their land rights under national law, including any
national law recognizing customary use rights; and
 Offer Affected Communities of Indigenous Peoples compensation
and due process in the case of commercial development of their
land and natural resources, together with culturally appropriate
sustainable development opportunities, including:
 Providing land-based compensation or compensation-in-kind in
lieu of cash compensation where feasible.
 Ensuring continued access to natural resources, identifying the
 equivalent replacement resources, or, as a last option, providing
compensation and identifying alternative livelihoods if project
development results in the loss of access to and the loss of
natural resources independent of project land acquisition.
 Ensuring fair and equitable sharing of benefits associated with
project usage of the resources where the client intends to utilize
natural resources that are central to the identity and livelihood
of Affected Communities of Indigenous People and their usage
thereof exacerbates livelihood risk.
 Providing Affected Communities of Indigenous Peoples with
access, usage, and transit on land it is developing subject to
overriding health, safety, and security considerations.
NOT APPLICABLE
Relocation of Indigenous Peoples from Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use
15.
The client will consider feasible alternative project designs to avoid the
relocation of Indigenous Peoples from communally held lands and
natural resources subject to traditional ownership or under customary
use. If such relocation is unavoidable the client will not proceed with
the project unless FPIC has been obtained as described above. Any
relocation of Indigenous Peoples will be consistent with the
requirements of Performance Standard 5. Where feasible, the relocated
Indigenous Peoples should be able to return to their traditional or
customary lands, should the cause of their relocation cease to exist.
NOT APPLICABLE
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
Critical Cultural Heritage
16.
Where a project may significantly impact on critical cultural heritage
that is essential to the identity and/or cultural, ceremonial, or spiritual
aspects of Indigenous Peoples lives, priority will be given to the
avoidance of such impacts. Where significant project impacts on
critical cultural heritage are unavoidable, the client will obtain the
FPIC of the Affected Communities of Indigenous Peoples.
NOT APPLICABLE
17.
Where a project proposes to use the cultural heritage including
knowledge, innovations, or practices of Indigenous Peoples for
commercial purposes, the client will inform the Affected Communities
of Indigenous Peoples of (i) their rights under national law; (ii) the
scope and nature of the proposed commercial development; (iii) the
potential consequences of such development; and (iv) obtain their
FPIC. The client will also ensure fair and equitable sharing of benefits
from commercialization of such knowledge, innovation, or practice,
consistent with the customs and traditions of the Indigenous Peoples.
NOT APPLICABLE
Mitigation and Development Benefits
18.
The client and the Affected Communities of Indigenous Peoples will
identify mitigation measures in alignment with the mitigation
hierarchy described in Performance Standard 1 as well as
opportunities for culturally appropriate and sustainable development
benefits. The client will ensure the timely and equitable delivery of
agreed measures to the Affected Communities of Indigenous Peoples.
NOT APPLICABLE
19.
The determination, delivery, and distribution of compensation and
other benefit sharing measures to the Affected Communities of
Indigenous Peoples will take account of the laws, institutions, and
customs of these communities as well as their level of interaction with
mainstream society. Eligibility for compensation can either be
individually or collectively-based, or be a combination of both. Where
compensation occurs on a collective basis, mechanisms that promote
the effective delivery and distribution of compensation to all eligible
members of the group will be defined and implemented.
NOT APPLICABLE
20.
Various factors including, but not limited to, the nature of the project,
the project context and the vulnerability of the Affected Communities
of Indigenous Peoples will determine how these communities should
benefit from the project. Identified opportunities should aim to address
the goals and preferences of the Indigenous Peoples including
improving their standard of living and livelihoods in a culturally
appropriate manner, and to foster the long-term sustainability of the
natural resources on which they depend.
NOT APPLICABLE
Private Sector Responsibilities Where Government is Responsible for Managing Indigenous Peoples Issues
21.
Where the government has a defined role in the management of
Indigenous Peoples issues in relation to the project, the client will
collaborate with the responsible government agency, to the extent
feasible and permitted by the agency, to achieve outcomes that are
consistent with the objectives of this Performance Standard. In
active role during planning, implementation, and monitoring of
activities to the extent permitted by the agency.
NOT APPLICABLE
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
No:
22.
The client will prepare a plan that, together with the documents
relevant requirements of this Performance Standard. The client may
need to include (i) the plan, implementation, and documentation of the
process of ICP and engagement and FPIC where relevant; (ii) a
description of the government-provided entitlements of affected
Indigenous Peoples; (iii) the measures proposed to bridge any gaps
between such entitlements, and the requirements of this Performance
Standard; and (iv) the financial and implementation responsibilities of
the government agency and/or the client.
NOT APPLICABLE
Review against IFC Performance Standard 8 (Cultural Heritage)
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
The client should apply internationally recognized practices to site surveys,
excavation, preservation and publication, in addition to compliance with
national law. An internationally recognized practice is defined as the
exercise of professional skill, knowledge, diligence, prudence and foresight
that would reasonably be expected from experienced professionals engaged
in the same type of undertaking under the same or similar circumstances
globally. Where the client is in doubt on what constitutes internationally
recognized practice, international peer reviewers are able to provide
guidance.
6.
In addition to complying with applicable law on the protection of
cultural heritage, including national law implementing the host
country’s obligations under the Convention Concerning the Protection
of the World Cultural and Natural Heritage, the client will identify and
protect cultural heritage by ensuring that internationally recognized
practices for the protection, field-based study, and documentation of
cultural heritage are implemented.
COMPLIANT
Archeological survey has been conducted in December 2011. The study has
revealed a set of 10 archaeological sites and related chipped lithic remains.
Both the inclusion of topographic sites on average slope, and the
characteristics of the lithic material allow characterizing these locations as
campsites for hunter-gatherers to prehistoric hunting activities, fishing and
gathering. This study has been submitted to the Institute for National
Historical and Artistic Heritage (IPHAN – Instituto do Patrimônio Histórico e
Artístico Nacional) and waits for the issuance of technical opinion.
7.
Where the risk and identification process determines that there is a
chance of impacts to cultural heritage, the client will retain competent
professionals to assist in the identification and protection of cultural
heritage. The removal of nonreplicable cultural heritage is subject to
the additional requirements of paragraph 10 below. In the case of
critical cultural heritage, the requirements of paragraphs 13–15 will
apply.
PARTIALLY COMPLIANT
Recommendations provided in the archaeological study should be
implemented by ELDORADO.
Within the archaeological study, developed by external professionals, an
impact assessment of the archaeological sites has been conducted in the
areas of reforestation of ELDORADO considered to have direct impact. In all
sites the impacts were considered negative, direct, temporary and
irreversible.
PS 8, paragraph 7
Chance Find Procedures
8.
The client is responsible for siting and designing a project to avoid
significant adverse impacts to cultural heritage. The environmental
and social risks and impacts identification process should determine
whether the proposed location of a project is in areas where cultural
heritage is expected to be found, either during construction or
operations. In such cases, as part of the client’s ESMS, the client will
develop provisions for managing chance finds through a chance find
procedure which will be applied in the event that cultural heritage is
subsequently discovered. The client will not disturb any chance find
further until an assessment by competent professionals is made and
actions consistent with the requirements of this Performance Standard
are identified.
See PS 8, paragraph 6
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
PARTIALLY COMPLIANT
Study has been submitted to the Institute for National Historical and Artistic
Heritage (IPHAN – Instituto do Patrimônio Histórico e Artístico Nacional)
however it does not involve consultations with affected communities and
therefore does not incorporate in its decision-making process the
considerations of these affected communities.
ELDORADO presented the Program “ELDORADO PES NO CHÃO”, in
which the company preserves as a local heritage houses that were built with
tiles made of the local riverbed clay. There is evidence of consultation made
with the owners of the houses.
Consultation is an important means of identifying it, documenting its
presence and significance, assessing potential impacts, and exploring
mitigation options. Requirements on the community engagement of
Affected Communities can be found in paragraphs 25 through 33 of
ELDORADO should continue to make special efforts to consult with the
historical or traditional users or owners of tangible cultural heritage,
especially inhabitants of the area impacted by a project within the host
country, since the interests of these users or owners may be different than
the desires expressed by competent experts or government officials.
ELDORADO should provide early notification and engage with such
groups regarding possible public use, relocation of or other adverse impacts
on cultural heritage resources. The consultation process should actively seek
to identify concerns of these users or owners of tangible cultural heritage,
and, where possible, ELDORADO should take these concerns into account
in the way its project manages cultural heritage.
Consultation
9.
Where a project may affect cultural heritage, the client will consult
PS 8, paragraph 9
with Affected Communities within the host country that use, or have
used within living memory, the cultural heritage for long-standing
cultural purposes. The client will consult with the Affected
Communities to identify cultural heritage of importance, and to
incorporate into the client’s decision-making process the views of the
Affected Communities on such cultural heritage. Consultation will also
involve the relevant national or local regulatory agencies that are
entrusted with the protection of cultural heritage.
Community Access
10.
PS 8, paragraph 10
NOT APPLICABLE
According information from archeological survey presented to IPHAN (refer
to Annex A) the site does not prevent access to cultural heritages or
previously cultural heritage sites. Therefore this requirement is not
applicable.
Where the client has encountered tangible cultural heritage that is
PS 8, paragraph 11
replicable and not critical, the client will apply mitigation measures
that favor avoidance. Where avoidance is not feasible, the client will
apply a mitigation hierarchy as follows:
 Minimize adverse impacts and implement restoration measures, in
situ, that ensure maintenance of the value and functionality of the
cultural heritage, including maintaining or restoring any ecosystem
processes4 needed to support it;
 Where restoration in situ is not possible, restore the functionality of
the cultural heritage, in a different location, including the
ecosystem processes needed to support it;
 The permanent removal of historical and archaeological artefacts
and structures is carried out according to the principles of
paragraphs 6 and 7 above; and
 Only where minimization of adverse impacts and restoration to
ensure maintenance of the value and functionality of the cultural
heritage are demonstrably not feasible, and where the Affected
Communities are using the tangible cultural heritage for longstanding cultural purposes, compensate for loss of that tangible
cultural heritage.
COMPLIANT
Within the archaeological study, mitigation measures, related to impacts
identified, 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 of
an archaeological monitoring program. The measures suggested to be taken
immediately after the implementation of the project were: the publication of
illustrated book for the general public to the socialization of knowledge
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 the
communities surrounding the project.
Where the client’s project site contains cultural heritage or prevents
access to previously accessible cultural heritage sites being used by, or
that have been used by, Affected Communities within living memory
for long-standing cultural purposes, the client will, based on
consultations under paragraph 9, allow continued access to the
cultural site or will provide an alternative access route, subject to
Removal of Replicable Cultural Heritage
11.
It was recommended by the archaeological survey to perform during
implementation of the enterprise the following actions:
- Archaeological survey project in 10 sites located in view of scientific
relevance and susceptibility of the sites to erosion in the area of
reforestation;
- Monitoring the implementation of the project to avoid impacts on local
archaeological heritage in the area indirectly impacted by the change in soil
structure;
-Continue activities related to heritage education in the communities
surrounding the project, based on publication of a scientific communication
book about the archaeological site.
ERM recommends to expand the area of study, since there will be purchase
of wood, and partnership contracts to plant eucalyptus in other areas
beyond the areas owned by ELDORADO. Therefore these areas could
present cultural heritage that was not identified due to the limited area
previously defined in the study present to IPHAN.
No:
Related PS
Requirements, EHS
Pulp and Paper) and
Legal Standards
NOT APPLICABLE
According information from archaeological survey presented to IPHAN, the
sites do not present non-replicable cultural heritage.
Refer to PS 8, paragraph 11.
Removal of Non-Replicable Cultural Heritage
12.
Most cultural heritage is best protected by preservation in its place,
PS 8, paragraph 12
since removal is likely to result in irreparable damage or destruction of
the cultural heritage. The client will not remove any nonreplicable
cultural heritage, unless all of the following conditions are met:
 There are no technically or financially feasible alternatives to
removal;
 The overall benefits of the project conclusively outweigh the
anticipated cultural heritage loss from removal; and
 Any removal of cultural heritage is conducted using the best
available technique.
13.
Critical cultural heritage consists of one or both of the following types PS 8, paragraphs 13, 14
of cultural heritage: (i) the internationally recognized heritage of
and 15
communities who use, or have used within living memory the cultural
heritage for long-standing cultural purposes; or (ii) legally protected
cultural heritage areas, including those proposed by host governments
for such designation.
14.
The client should not remove, significantly alter, or damage critical
cultural heritage. In exceptional circumstances when impacts on
critical cultural heritage are unavoidable, the client will use a process
of Informed Consultation and Participation (ICP) of the Affected
Communities as described in Performance Standard 1 and which uses
a good faith negotiation process that results in a documented outcome.
The client will retain external experts to assist in the assessment and
protection of critical cultural heritage.
15.
Legally protected cultural heritage areas are important for the
protection and conservation of cultural heritage, and additional
measures are needed for any projects that would be permitted under
the applicable national law in these areas. In circumstances where a
proposed project is located within a legally protected area or a legally
defined buffer zone, the client, in addition to the requirements for
critical cultural heritage cited in paragraph 14 above, will meet the
following requirements:
 Comply with defined national or local cultural heritage regulations
or the protected area management plans;
 Consult the protected area sponsors and managers, local
communities and other key stakeholders on the proposed project;
and
enhance the conservation aims of the protected area.
NOT APPLICABLE
According information from archeological survey presented to IPHAN (See
document list) there is no critical cultural heritage and the project is not
inserted in legally cultural protected areas. Therefore, these requirements are
not applicable.
Project’s Use of Cultural Heritage
16.
Where a project proposes to use the cultural heritage, including
knowledge, innovations, or practices of local communities for
commercial purposes, the client will inform these communities of (i)
their rights under national law; (ii) the scope and nature of the
proposed commercial development; and (iii) the potential
consequences of such development. The client will not proceed with
such commercialization unless it (i) enters into a process of ICP as
described in Performance Standard 1 and which uses a good faith
negotiation process that results in a documented outcome and (ii)
provides for fair and equitable sharing of benefits from
commercialization of such knowledge, innovation, or practice,
consistent with their customs and traditions.
NOT APPLICABLE
The scope and nature of the proposed project does not involve the use of
cultural heritage, therefore this requirement is not applicable.
Annex D
Gap Analysis Table – Forestry
Operations
Review against IFC Performance Standard 1 (Assessment and Management of Environmental and Social Risks and Impacts)
No:
Related PS
Requirements, EHS
Guidelines (General
and Forest) and Legal
Standards
5.
The client, in coordination with other responsible government agencies PS 1, paragraph 5
and third parties as appropriate, will conduct a process of
environmental and social assessment, and establish and maintain an
ESMS appropriate to the nature and scale of the project and
commensurate with the level of its environmental and social risks and
impacts. 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 preparedness
and response; (vi) stakeholder engagement; and (vii) monitoring and
review.
COMPLIANT
Keep the process of implementing the whole management tools.
Regarding management system for Forest operations, ELDORADO
has presented a document called Forest Management Plan in which includes
the environmental management system and all the tools for planning,
control and development of the business. This document explains how the
management system works and what is considered in each step. Also a
software was presented for project management which includes
environmental activities such as procedures regarding assessment of
planting or wood cutting areas. A procedure 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 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 each
professional category. The matrix was evidenced and it does not include
training programs for employees and contractors with direct responsibility
for relevant social and environmental performance.
The PTEAS procedure states that all staff in charge of it shall be trained on
this procedures according while other staff shall be trained through intranet
about PTEAS. This training is not included on the training matrix and it was
not evidenced the PTEAS training is in place.
ERM was not able to check if there is monitoring and review of the actions
proposed and executed by the multidisciplinary team.
The management system is apparently fully organized, but some of the tools
and actions are not yet being implemented.
The client will establish an overarching policy defining the
PS 1, paragraph 6
environmental and social objectives and principles that guide the
project to achieve sound environmental and social performance. The
policy provides a framework for the environmental and social
assessment and management process, and specifies that the project (or
business activities, as appropriate) will comply with the applicable
laws and regulations of the jurisdictions in which it is being
undertaken, including those laws implementing host country
obligations under international law. The policy should be consistent
with the principles of the Performance Standards. Under some
circumstances, clients may also subscribe to other internationally
recognized standards, certification schemes, or codes of practice and
these too should be included in the policy. The policy will indicate
who, within the client’s organization, will ensure conformance with the
policy and be responsible for its execution (with reference to an
appropriate responsible government agency or third party, as
necessary). The client will communicate the policy to all levels of its
organization.
COMPLIANT
According to information available on the company’s website and on the
Forest Management Plan, a sustainability policy, mission, vision and values
have been developed and disclosed publicly.
Policy
6.
None.
ELDORADO – APRIL, 2012
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
The client will establish and maintain a process for identifying the
environmental and social risks and impacts of the project (see
paragraph 18 for competency requirements). The type, scale, and
location of the project guide the scope and level of effort devoted to the
risks and impacts identification process. The scope of the risks and
impacts identification process will be consistent with good
international industry practice, and will determine the appropriate and
relevant methods and assessment tools. The process may comprise a
full-scale environmental and social impact assessment, a limited or
focused environmental and social assessment, or straightforward
application of environmental siting, pollution standards, design
criteria, or construction standards. When the project involves existing
assets, environmental and/or social audits or risk/hazard assessments
can be appropriate and sufficient to identify risks and impacts. If assets
to be developed, acquired or financed have yet to be defined, the
establishment of an environmental and social due diligence process
will identify risks and impacts at a point in the future when the
physical elements, assets, and facilities are reasonably understood. The
risks and impacts identification process will be based on recent
environmental and social baseline data at an appropriate level of detail.
The process will consider all relevant environmental and social risks
and impacts of the project, including the issues identified in
Performance Standards 2 through 8, and those who are likely to be
affected by such risks and impacts. The risks and impacts identification
process will consider the emissions of greenhouse gases, the relevant
risks associated with a changing climate and the adaptation
opportunities, and potential transboundary effects, such as pollution of
air, or use or pollution of international waterways.
PARTIALLY COMPLIANT
Conduct the PTEAS in all farms operated by ELDORADO before
Environmental aspects and impacts have been assessed and are documented intervention.
in a spreadsheet provided by ELDORADO. This assessment was developed
by Poyry Silviconsult in order to evaluate the impacts associated with the
forest activities. Also, a document named Forest Management Plan has been
provided and it includes monitoring activities in order to check if the
impacts are being mitigated and minimized.
8.
PS 1, paragraphs 8, 9, 10
aspects, and facilities that are likely to generate impacts, environmental and 11
and social risks and impacts will be identified in the context of the
project’s area of influence. This area of influence encompasses, as
appropriate:
 The area likely to be affected by: (i) the project and the client’s
activities and facilities that are directly owned, operated or
managed (including by contractors) and that are a component of
the project; (ii) impacts from unplanned but predictable
developments caused by the project that may occur later or at a
different location; or (iii) indirect project impacts on biodiversity or
on ecosystem services upon which Affected Communities’
livelihoods are dependent.
 Associated facilities, which are facilities that are not funded as part
of the project and that would not have been constructed or
expanded if the project did not exist and without which the project
would not be viable.
 Cumulative impacts that result from the incremental impact, on
areas or resources used or directly impacted by the project, from
other existing, planned or reasonably defined developments at the
time the risks and impacts identification process is conducted.
PARTIALLY COMPLIANT

Identify areas likely to be affected by the operation at São Paulo and
Minas Gerais state and Dois Irmãos dos Buruti and Anastacio
The Forest Management Plan defined the area affected by the project. It does
municipalities.
not include the lands at São Paulo and Minas Gerais state (that will supply
wood for the first years of operation) and Dois Irmãos dos Buruti and
Anastacio municipalities, where ELDORADO owns 4 land and lease 2 lands. Cumulative impacts should be assessed. Cumulative impacts are those that
result from the incremental impact of the project when added to other
existing, planned and reasonably predictable future projects and
The procedure defined (PTEAS) do not assess cumulative impacts from
other existing, planned or reasonably defined developments.
developments.
9.
In the event of risks and impacts in the project’s area of influence
PS 1, paragraph 9
resulting from a third party’s actions, the client will address those risks
and impacts in a manner commensurate with the client’s control and
influence over the third parties, and with due regard to conflict of
interest.
COMPLIANT
Risks and impacts of forest operation performed by rural labour contractors
are covered by the implementation of ELDORADO’s procedure in the land
and covered by contract agreement.
Risk and impacts from wood and land supply are covered by contract
agreements.
7.
A social and economic diagnosis was developed for 7 municipalities where
ELDORADO’s operates: Tres Lagoas, Selvíria, Água Clara, Inocencia, Ribas
do Rio Pardo, Santa Rita do Pardo, Aparecida do Taboado. This study
identified the main vulnerabilities of the municipalities as establishes
indicators to monitor ELDORADO’s contribution to local development.
As a result of this study, ELDORADO will cross the main vulnerability of
the region with the impacts of the industrial and forest operation that could
optimize the positive impacts and mitigate de adverse impacts.
Specific impacts of forest operation on land are identified through the
procedure for the Development of Environmental, Social and Technical
Project (PTEAS) which should be applied to every farm 1 or 2 months before
intervention (planting and harvesting) to support land management.
This procedure is dated December 2011 and PTEAS was not carried out at
farms in which planting was performed before this. Those farms will be
assessed through the PTEAS procedure only before harvesting.
Specific gaps in the existing assessments are pointed in the PS 2 to 8.
None
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 1, paragraph 10
No:
10.
Where the client can reasonably exercise control, the risks and impacts
identification process will also consider those risks and impacts
associated with primary supply chains, as defined in Performance
Standard 2 (paragraphs 27–29) and Performance Standard 6 (paragraph
30).
11.
PS 1, paragraph 11
aspects and facilities that are likely to generate environmental and
social impacts, the identification of risks and impacts will take into
account the findings and conclusions of related and applicable plans,
studies, or assessments prepared by relevant government authorities or
other parties that are directly related to the project and its area of
influence. These include master economic development plans, country
or regional plans, feasibility studies, alternatives analyses, and
cumulative, regional, sectoral, or strategic environmental assessments
where relevant. The risks and impacts identification will take account
of the outcome of the engagement process with Affected Communities
as appropriate.
Refer to Paragraph 8
None
12.
aspects and facilities that are likely to generate impacts, and as part of
the process of identifying risks and impacts, the client will identify
individuals and groups that may be directly and differentially or
disproportionately affected by the project because of their
disadvantaged or vulnerable status. Where individuals or groups are
identified as disadvantaged or vulnerable, the client will propose and
implement differentiated measures so that adverse impacts do not fall
disproportionately on them and they are not disadvantaged in sharing
development benefits and opportunities.
PARTIALLY COMPLIANT
There is a social economic diagnosis, an inventory of areas of high
conservation and archeological survey that identify vulnerabilities of the
areas.
The social economic studies undertaken did not aim to identify vulnerable
groups that may be differentially or disproportionately affected by the
project because of their disadvantaged or vulnerable status.
According to IFC disadvantage or vulnerable status may stem from an
individual’s or group’s race, color, sex, language, religion, political or other
opinion, national or social origin, property, birth, or other status. It shall 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.
There may be individuals or groups within the project’s area of influence
who are particularly vulnerable or disadvantaged and who could experience
adverse impacts from the proposed project more severely than others.
affected by the expansion project and implement differentiated measures so
that adverse impacts do not fall disproportionately on them and they are not
disadvantaged in sharing development benefits and opportunities. If no
group is identified as vulnerable or differentially affected document (a brief
statement to this fact is sufficient) justify so.
PS 1, paragraph 12
PARTIALLY COMPLIANT
Monitor significant suppliers, like wood suppliers, to identify if they are
following ELDORADO´s requirements.
For contract purpose, ELDORADO requests the wood suppliers several
documents and clearance certification to identify legal risks associated with For detailed information, Refer to PS2, paragraph 25, and PS6, paragraph 30.
the farm and the wood transaction before contract is signed by both parts.
There is no monitor procedure in place after the contract is signed, even
though wood is supplied 2 to 4 years after it. Refer to PS2 and PS6 for
further information about supply chain management.
Reportedly, ELDORADO will persuade the certification of Chain of Custody
which should guarantee the origin of the wood supplied by third part.
Other suppliers are monitored by the person in charge of the contract to
identify if the practice of contracting workers is according to Brazilian
legislation. For payment reasons, the supplier shall provide the clearance
certification for taxes and contribution charges.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
COMPLIANT
Risks and impacts have been identified, organized inside a management
program and implemented within the management system. Documents
have been provided in order to show compliance in this issue.
Refer to PS1, paragraph 7-12 to impact and risk identification.
Management Programs
13.
14.
Consistent with the client’s policy and the objectives and principles
described therein, the client will establish management programs that,
in sum, will describe mitigation and performance improvement
measures and actions that address the identified environmental and
social risks and impacts of the project.
Depending on the nature and scale of the project, these programs may
consist of some documented combination of operational procedures,
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 the organization has control or
influence, or to specific sites, facilities, or activities. The mitigation
hierarchy to address identified risks and impacts will favor the
avoidance of impacts over minimization, and, where residual impacts
remain, compensation/offset, wherever technically and financially
feasible.
15.
Where the identified risks and impacts cannot be avoided, the client
will identify mitigation and performance measures and establish
corresponding actions to ensure the project will operate in compliance
with applicable laws and regulations, and meet the requirements of
Performance Standards 1 through 8. The level of detail and complexity
of this collective management program and the priority of the
identified measures and actions will be commensurate with the
project’s risks and impacts, and will take account of the outcome of the
engagement process with Affected Communities as appropriate.
16.
The management programs will establish environmental and social
Action Plans, which will define desired outcomes and actions to
address the issues raised in the risks and impacts identification
process, as measurable events to the extent possible, with elements
such as performance indicators, targets, or acceptance criteria that can
be tracked over defined time periods, and with estimates of the
resources and responsibilities for implementation. As appropriate, the
management program will recognize and incorporate the role of
relevant actions and events controlled by third parties to address
identified risks and impacts. Recognizing the dynamic nature of the
project, the management program will be responsive to changes in
circumstances, unforeseen events, and the results of monitoring and
review.
In addition to the Forest Management Plan, ELDORADO shall define other
measures to address the recommendations described in this document.
These documents are: Forest Management Plan, Inventory of Areas of High
Conservation Value for critic sociocultural and / or essential social functions
and Impact Assessment of the Forest activities developed by Poyry
Silviconsult.
The Forest Management Plan will be revised annually.
17.
The client, in collaboration with appropriate and relevant third parties, PS 1, paragraphs 17 and
will establish, maintain, and strengthen as necessary an organizational 18
structure that defines roles, responsibilities, and authority to
implement the ESMS. Specific personnel, including management
representative(s), with clear lines of responsibility and authority
should be designated. Key environmental and social responsibilities
should be well defined and communicated to the relevant personnel
and to the rest of the client’s organization. Sufficient management
sponsorship and human and financial resources will be provided on an
ongoing basis to achieve effective and continuous environmental and
social performance.
PARTIALLY COMPLIANT
Reportedly specific personnel have been assigned for roles and
responsibilities within the environmental and social aspects of the project.
A Matrix for functions and responsibilities was developed defining workers
categories, activity performed and profile.
A training matrix was developed to identify legal training for each work
category. Those legal required training does not cover the aspects treated by
this performance standard, specially the social aspects.
Reportedly, rural worker’s supervisors will be training in people’s
management.
Develop training program to support the designated personnel to carry out
their part of the ESMS. The training program should ensure consistency with
ELDORADO policies and procedures. The training can be formal, informal
(on-the-job), one-time, periodic, etc. The program must include third parties
with direct responsibility with activities relevant to the environmental and
social performance of the project, for example, wood suppliers, rural
workers supplier, etc and include documented training records.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
Most 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 the
contract for the following issues: environmental performance, heath and
safety, operational performance, payment of taxes and contributions
charges. No evidence was provided to document this.
18.
Personnel within the client’s organization with direct responsibility for
the project’s environmental and social performance will have the
knowledge, skills, and experience necessary to perform their work,
including current knowledge of the host country’s regulatory
requirements and the applicable requirements of Performance
Standards 1 through 8. Personnel will also possess the knowledge,
skills, and experience to implement the specific measures and actions
required under the ESMS and the methods required to perform the
actions in a competent and efficient manner.
19.
The process of identification of risks and impacts will consist of an
adequate, accurate, and objective evaluation and presentation,
prepared by competent professionals. For projects posing potentially
significant adverse impacts or where technically complex issues are
involved, clients may be required to involve external experts to assist
in the risks and impacts identification process.
PS 1, paragraph 19
COMPLIANT
None
See PS 1, paragraph 7 to 12
20.
PS 1, paragraph 20 and
aspects and facilities that are likely to generate impacts, the ESMS will 21
establish and maintain an emergency preparedness and response
system so that the client, in collaboration with appropriate and relevant
third parties, will be prepared to respond to accidental and emergency
situations associated with the project in a manner appropriate to
prevent and mitigate any harm to people and/or the environment.
This preparation will include the identification of areas where
accidents and emergency situations may occur, communities and
individuals that may be impacted, response procedures, provision of
equipment and resources, designation of responsibilities,
communication, including that with potentially Affected Communities
and periodic training to ensure effective response. The emergency
preparedness and response activities will be periodically reviewed and
revised, as necessary, to reflect changing conditions.
21.
Where applicable, the client will also assist and collaborate with the
potentially Affected Communities (see Performance Standard 4) and
the local government agencies in their preparations to respond
effectively to emergency situations, especially when their participation
and collaboration are necessary to ensure effective response. If local
government agencies have little or no capacity to respond effectively,
the client will play an active role in preparing for and responding to
emergencies associated with the project. The client will document its
emergency preparedness and response activities, resources, and
responsibilities, and will provide appropriate information to
potentially Affected Community and relevant government agencies.
COMPLIANT
The company has provided documentation of an Emergency
Plan 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 on
emergency behavior in case of fire, there is telephone for emergency and
there is a fire combat car available. Record of firefighting training was
presented for Três Lagoas unit. (See document list).
The emergency plan addresses on how information is disclosed to affected
communities, relevant government agencies or other relevant parties.
None
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
22.
The client will establish procedures to monitor and measure the
effectiveness of the management program, as well as compliance with 23
any related legal and/or contractual obligations and regulatory
requirements. Where the government or other third party has
responsibility for managing specific risks and impacts and associated
mitigation measures, the client will collaborate in establishing and
monitoring such mitigation measures. Where appropriate, clients will
consider involving representatives from Affected Communities to
participate in monitoring activities. The client’s monitoring program
should be overseen by the appropriate level in the organization. For
projects with significant impacts, the client will retain external experts
to verify its monitoring information. The extent of monitoring should
be commensurate with the project’s environmental and social risks and
impacts and with compliance requirements.
23.
In addition to recording information to track performance and
establishing relevant operational controls, the client should use
dynamic mechanisms, such as internal inspections and audits, where
relevant, to verify compliance and progress toward the desired
outcomes. Monitoring will normally include recording information to
track performance and comparing this against the previously
established benchmarks or requirements in the management program.
Monitoring should be adjusted according to performance experience
and actions requested by relevant regulatory authorities. The client will
document monitoring results and identify and reflect the necessary
corrective and preventive actions in the amended management
program and plans. The client, in collaboration with appropriate and
relevant third parties, will implement these corrective and preventive
actions, and follow up on these actions in upcoming monitoring cycles
to ensure their effectiveness.
24.
Senior management in the client organization will receive periodic
performance reviews of the effectiveness of the ESMS, based on
systematic data collection and analysis. The scope and frequency of
such reporting will depend upon the nature and scope of the activities
identified and undertaken in accordance with the client’s ESMS and
other applicable project requirements. Based on results within these
performance reviews, senior management will take the necessary and
appropriate steps to ensure the intent of the client’s policy is met, that
procedures, practices, and plans are being implemented, and are seen
to be effective.
PS 1, paragraph 24
PARTIALLY COMPLIANT
Develop procedures to monitor and measure performance of the social
Documents provided do not contain the procedures to monitor and measure management program including impacts on community health and safety
(refer to PS4 for further recommendation).
on a regular basis the key characteristics and performance of the social
management program, including the use of external experts if required.
COMPLIANT
None.
The Sustainability Manager responds direct to ELDORADO’s CEO and has
direct and frequent access to him. Information about license process and
stakeholder relations is disclosure at the directors meetings.
Once a week and once a month there are meetings about the project
installation and a report is disclosure. Information about forest activities are
also treated at these meetings.
The management plan is reviewed once a year and it should be updated
every time a new activity is implemented. There is also a monthly meeting
among managers and each coordinator, where targets and monitoring
measures are discussed. Targets were implemented in December/2011.
25.
Stakeholder engagement is the basis for building strong, constructive,
and responsive relationships that are essential for the successful
management of a project's environmental and social impacts.
Stakeholder engagement is an ongoing process that may involve, in
varying degrees, the following elements: stakeholder analysis and
planning, disclosure and dissemination of information, consultation
and participation, grievance mechanism, and ongoing reporting to
Affected Communities. The nature, frequency, and level of effort of
stakeholder engagement may vary considerably and will be
commensurate with the project’s risks and adverse impacts, and the
project’s phase of development.
PS 1, paragraph 25
PARTIALLY COMPLIANT
ELDORADO has implemented the following practices on stakeholder
engagement:

Stakeholders mapping and identification, mostly through the social
economic diagnosis; Consultation with local governmental
representatives to identify projects that can be supported by
ELDORADO;

Consultation of a sample of citizens to identify vulnerability of the
region as part of the social economic diagnosis; Consultation of
community members to identify areas of high conservation value
and their dependence toward it.as part of the inventory of areas of
high conservation value.

Identification of land neighbors as part of the PTEAS;

A public hearing will be carried out for the purpose of forest
To comply with this performance standard ELDORADO should develop a
Stakeholder Engagement Plan. Such a plan should consider whether
stakeholders are:




positively or negatively affected by ELDORADO;
directly or indirectly impacted, particularly those directly and adversely
affected by project activities, including those that are disadvantaged or
vulnerable;
stakeholders who may be able to influence the outcome of the project
because of their knowledge about the affected communities or political
influence over them;
Legitimate stakeholders representatives, including elected officials, nonelected community leaders, leader of informal or traditional community
No:
Related PS
Requirements, EHS
Guidelines (General
Standards

certification. The Forest Management Plan will be publicly
disclosed during the public meeting;
None of the above mentioned initiatives were undertaken to 2 Irmãos do
Buruti and Anastacio municipalities.
ELDORADO does not have a systematic approach to consult or to engage
stakeholders neither, and as such this item is rated partially completed.

Stakeholders not directly affected by the project but may have the ability
to influence or alter the relationship of the client with the affected
community.
The Stakeholder Engagement Plan should also include:
 risks and impacts,
 identification, characterization and priority of stakeholders, focusing on
those directly affected by the project and vulnerable groups,
 grievance mechanism,
 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 operation to affected community.
Information about risks and impacts identified, mitigation measures shall be
periodically disclosure to affected community, at least annually, as long the
specific items in the management programs. ELDORADO may consider
using sustainability report on the financial, environmental and social aspects
to report so.
Stakeholder Analysis and Engagement Planning
26.
Clients should identify the range of stakeholders that may be interested PS 1, paragraph 26,27
in their actions and consider how external communications might
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 adverse environmental and
social impacts to Affected Communities the client will identify the
Affected Communities and will meet the relevant requirements
described below.
27.
The client will develop and implement a Stakeholder Engagement Plan
that is scaled to the project risks and impacts and development stage,
and be tailored to the characteristics and interests of the Affected
Communities. Where applicable, the Stakeholder Engagement Plan
will include differentiated measures to allow the effective participation
of those identified as disadvantaged or vulnerable. When the
stakeholder engagement process depends substantially on community
representatives, the client will make every reasonable effort to verify
that such persons do in fact represent the views of Affected
Communities and that they can be relied upon to faithfully
communicate the results of consultations to their constituents.
28.
In cases where the exact location of the project is not known, but it is
PS 1, paragraph 28
reasonably expected to have significant impacts on local communities,
the client will prepare a Stakeholder Engagement Framework, as part
of its management program, outlining general principles and a strategy
to identify Affected Communities and other relevant stakeholders and
PARTIALLY COMPLIANT
PARTIALLY COMPLIANT
ELDORADO is still on process to acquire lands, which means that the
exact location of some of the forest operation is not known yet.
ELDORADO has defined that the preference area to acquire land is in a
ratio of 100 km away from the factory. A socio economic diagnosis was
Refer to the PS1, paragraph 25 for recommendation on Stakeholder
Engagement Plan.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
plan for an engagement process compatible with this Performance
Standard that will be implemented once the physical location of the
project is known.
undertaken for this area to support the Community Relationship Plan.
Disclosure of Information
29.
Disclosure of relevant project information helps Affected Communities PS 1, paragraph 29
and other stakeholders understand the risks, impacts and
opportunities of the project. The client will provide Affected
Communities with access to relevant information on: (i) the purpose,
nature, and scale of the project; (ii) the duration of proposed project
activities; (iii) any risks to and potential impacts on such communities
and relevant mitigation measures; (iv) the envisaged stakeholder
engagement process; and (v) the grievance mechanism.
PARTIALLY COMPLIANT
A public hearing will be held for the purpose of forest certification. The
Forest Management Plan will be presented at the hearing and public
available at the company’s website.
This item is rated partial because the public hearing was not held yet by the
time of this evaluation.
Provide to affected community the following information during the
hearing:

the purpose, nature, and scale of the project;

the duration of proposed project activities;

any risks to and potential impacts on such communities and
relevant mitigation measures;

the envisaged stakeholder engagement process;

and the grievance mechanism.
PARTIALLY COMPLIANT
Systemize the stakeholder identification, consultation and engagement
process, as described on Refer to PS1, paragraph 25.
Consultation
30.
When Affected Communities are subject to identified risks and adverse PS 1, paragraph 30 and
impacts from a project, the client will undertake a process of
31
consultation in a manner that provides the Affected Communities with PS 8, paragraph 9
opportunities to express their views on project risks, impacts and
mitigation measures, and allows the client to consider and respond to
them. The extent and degree of engagement required by the
consultation process should be commensurate with the project’s risks
and adverse impacts and with the concerns raised by the Affected
Communities. Effective consultation is a two-way process that should:
(i) begin early in the process of identification of environmental and
social risks and impacts and continue on an ongoing basis as risks and
impacts arise; (ii) be based on the prior disclosure and dissemination of
relevant, transparent, objective, meaningful and easily accessible
information which is in a culturally appropriate local language(s) and
format and is understandable to Affected Communities; (iii) focus
inclusive engagement on those directly affected as opposed to those
not directly affected; (iv) be free of external manipulation, interference,
coercion, or intimidation; (v) enable meaningful participation, where
applicable; and (vi) be documented. The client will tailor its
consultation process to the language preferences of the Affected
Communities, their decision-making process, and the needs of
disadvantaged or vulnerable groups. If clients have already engaged in
such a process, they will provide adequate documented evidence of
such engagement.
ELDORADO has the following initiatives to consultation:

For the purpose of social economic diagnosis, a sample of citizens
were interviewed to identify vulnerability of the region;

For the Inventory of Areas of High Biodiversity, stakeholders were
consulted to identify the areas of high biodiversity important to the
community and the use of it;

Neighbors of the lands were ELDORADO operates (owned lands,
leased lands and partnerships agreements) are identified through
PTEAS and information is provided by ELDORADO;

As a result of the local vulnerabilities identified at the social
economic diagnosis, local governmental representatives were
consulted by ELDORADO to identify projects that could be
supported by ELDORADO;

A public hearing will be held for the purpose of forest certification
The consultation process is not systemized and it was not defined frequency
of consultation
No consultation process has been carried out at Dois Irmaos do Buruti and
Anastacio municipalities, were ELDORADO owns and operate lands.
Informed Consultation and Participation
31.
For projects with potentially significant adverse impacts on Affected
PS 1, paragraph 31
Communities, the client will conduct an Informed Consultation and
Participation (ICP) process that will build upon the steps outlined
above in Consultation and will result in the Affected Communities’
informed participation. ICP involves a more in-depth exchange of
views and information, and an organized and iterative consultation,
leading to the client’s incorporating into their decision-making process
the views of the Affected Communities on matters that affect them
directly, such as the proposed mitigation measures, the sharing of
development benefits and opportunities, and implementation issues.
The consultation process should (i) capture both men’s and women’s
views, if necessary through separate forums or engagements, and (ii)
reflect men’s and women’s different concerns and priorities about
impacts, mitigation mechanisms, and benefits, where appropriate. The
client will document the process, in particular the measures taken to
avoid or minimize risks to and adverse impacts on the Affected
Communities, and will inform those affected about how their concerns
have been considered.
Conduct the public hearing as planned..
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 1, paragraph 32
PARTIALLY COMPLIANT
According to ELDORADO, there is no indigenous or traditional people at
ELDORADO’s land. ERM did not identified indigenous or traditional
people in the lands visited or working for ELDORADO, which was
confirmed by workers interviewed.
Identify the influence of the operation at Dois Irmãos do Buruti and
Anastacio municipalities over indigenous or traditional people through the
PTEAS.
Indigenous Peoples
32.
For projects with adverse impacts to Indigenous Peoples, the client is
required to engage them in a process of ICP and in certain
circumstances the client is required to obtain their Free, Prior, and
Informed Consent (FPIC). The requirements related to Indigenous
Peoples and the definition of the special circumstances requiring FPIC
are described in Performance Standard 7.
In case impact on indigenous or traditional people is identified,
ELDORADO must comply with the performance standard 7 and the
recommendations described therein.
A study undertook for the municipalities of Anastacio and Dois Irmaos do
Buruti identified 7 indigenous land in the region, but it lacked to identify
impacts of the operation on indigenous and traditional people located in the Include impacted indigenous people’s representatives, if applicable, within
region (more information on PS7). Potential impacts, if existing, will be
Stakeholder Engagement Plan described in PS1, paragraph 25, 27.
identified through the PTEAS, scheduled to June to December 2012.
Indigenous people are not currently being engaged in the relationship
process undertook by ELDORADO.
Private Sector Responsibilities Under Government-Led Stakeholder Engagement
33.
PS 1, paragraph 33
NOT APPLICABLE
PS 1, paragraph 34
COMPLIANT
There is a form to register external communication from the public. The
questionnaire is available at ELDORADO’s office in the cities of Tres
Lagoas, Agua Clara, Silviria and Inocencia. The form is also available with
rural supervisors and kept on the cars that take rounds on the farms.
The form registers the name of the person, stakeholders category, reason for
contact, name of the person who receive the contact and action taken. Once
complete, the form is delivered a signed person from Social Area that
provides feedback.
Reportedly a public hearing will be held for certification purpose and the
Forest Management Plan will be presented and public available.
Where there are Affected Communities, the client will establish a
PS 1, paragraph 35
grievance mechanism to receive and facilitate resolution of Affected
Communities’ concerns and grievances about the client’s
environmental and social performance. The grievance mechanism
should be scaled to the risks and adverse impacts of the project and
have Affected Communities as its primary user. It should seek to
resolve concerns promptly, using an understandable and transparent
consultative process that is culturally appropriate and readily
accessible, and at no cost and without retribution to the party that
originated the issue or concern. The mechanism should not impede
access to judicial or administrative remedies. The client will inform the
Affected Communities about the mechanism in the course of the
stakeholder engagement process.
PARTIALLY COMPLIANT

There are two mechanism in place for grievance:

The Program “Human Resouce in the field”, in which a
representative from Human Resource visits workers in the field
twice 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 in
each municipality, a telephone number, the supervisor of the farm
or those responsible to perform rounds on the farms. The form is
delivered to the responsible person and included in a spreadsheet
that contains the name of the person, data, who received the
complaint, a description of the complaint, action taken, feedback
and data. ERM reviewed the spreadsheet and it contained 13
Where stakeholder engagement is the responsibility of the host
outcomes that are consistent with the objectives of this Performance
Standard. In addition, where government capacity is limited, the client
will play an active role during the stakeholder engagement planning,
implementation, and monitoring. If the process conducted by the
government does not meet the relevant requirements of this
Performance Standard, the client will conduct a complementary
process and, where appropriate, identify supplemental actions.
External Communications
34.
Clients will implement and maintain a procedure for external
communications that includes methods to (i) receive and register
external communications from the public; (ii) screen and assess the
issues raised and determine how to address them; (iii) provide, track,
and document responses, if any; and (iv) adjust the management
program, as appropriate. In addition, clients are encouraged to make
publicly available periodic reports on their environmental and social
sustainability.
35.
The grievance mechanism must be part of the Stakeholder Engagement Plan.
It is recommended to expand the disclosure on how community and
stakeholders can complain to ELDORADO.
ELDORADO should guarantee that the grievance mechanism for affected
community contains the following:

the grievance mechanism must be available to all stakeholders:
workers (employee, contractors, suppliers), suppliers, affected
community, and other significant categories identified by
ELDORADO;

it shall be culturally appropriate, readily accessible to all workers,;

it must be defined roles and responsibilities for receiving the
grievance and communication flow;

it must also define the channel for provision of feedback and time
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
complains related to request of finance support to social programs,
neighbor broken fence, measure to combat fire and ELDORADO’s
workers performing maintenance activities in a neighbor land.

to 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.
36.
The client will provide periodic reports to the Affected Communities
PS 1, paragraph 36
that describe progress with implementation of the project Action Plans
on issues that involve ongoing risk to or impacts on Affected
Communities and on issues that the consultation process or grievance
mechanism have identified as a concern to those Communities. If the
management program results in material changes in or additions to the
mitigation measures or actions described in the Action Plans on issues
of concern to the Affected Communities, the updated relevant
mitigation measures or actions will be communicated to them. The
frequency of these reports will be proportionate to the concerns of
Affected Communities but not less than annually.
PARTIALLY COMPLIANT
Reportedly a public hearing will be held for certification purpose and the
Forest Management Plan will be presented and public available.
Conduct the public hearing and to disclosure information about the Forest
management Plan.
Develop a systematic approach to inform community about risk and
impacts. Refer to PS1, paragraph 25, for the Stakeholder Development Plan.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
Human Resources Policies and Procedures
7.
The client will adopt and implement human resources policies and
PS 2, paragraph 7
procedures appropriate to its size and workforce that set out its
approach to managing workers consistent with the requirements of this
Performance Standard and national law.
PARTIALLY COMPLIANT
There is no human resource police that set out its approach to managing
workers as required by this Performance Standard.
There is current a Policy for Remuneration that states the salaries and
benefits by professional category. This Policy is not available to the
employees and general public.
There is also Policy for Training developed to be applied for industrial and
rural workers, however, the policy has not being validated by the managers
in charge of the forest activity
Develop a Human Resource Policy, procedures or ethical code appropriate
to the ELDORADO, to be applied for workers, contracted workers and
supply chain workers. The policy, procedures or ethical code shall cover all
issues treated by this performance standard, as exemplified bellow:

Working conditions: e.g physical environmental, health and safety
precautions, treatment of workers, disciplinary practices, respect to
workers’s personal dignity (such as refraining from physical
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;

Non discrimination and Equal Opportunity;

Grievance mechanism;

Child Labour;

Forced Labour;

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 ot ethical
code. It is recommended to public disclosure it.
8.
The client will provide workers with documented information that is
clear and understandable, regarding their rights under national labor
and employment law and any applicable collective agreements,
including their rights related to hours of work, wages, overtime,
compensation, and benefits upon beginning the working relationship
and when any material changes occur.
PS 2, paragraph 8
Labour Law
Consolidation).
Federal Decree
58.826/66 - Promulgates
the ILO Convention 110:
Worker's recruitment
on the Law 2848/40
(Criminal Code) Labour rights: Slave
labour
Federal Standard SIT
76/09 - Rural works
police: Workers
recruitment/transport.
Union Convention
issued by the Federation
of Rural Workers of
Mato Grosso do Sul State
PRATIALLY COMPLIANT
During the Inductions process, staff is provide with information associated
with legal rights and other information about working conditions: workers
permit; working hours and working hours register; identification to access
the site, legal absences, medical leave, salary and variable remuneration,
payment conditions, vacations and benefits (medical assistance, life
insurance, alimentation, workers transportation). This was confirmed by
workers interviewed.
Include on rural workers induction information about freedom of
association and union representation.
PS 2, paragraph 9
PARTIALLY COMPLIANT
There is currently a Union Agreement with the Union of Rural Workers of
Andradina in place and Union Convention issued by the Federation of
Rural Workers of Mato Grosso do Sul State.
Some workers interviewed reported not being aware about union
representation and how to join the union. Information about freedom of
association is not included on the induction for rural workers.
Workers documentation was reviewed and a contract was signed between
ELDORADO and the workers.
ERM interviewed 16 workers and 10 workers hired by contractors.
ELDORADO has currently 1556 workers on forest activities, 88% of them are
rural workers, around 1370.
9.
Where the client is a party to a collective bargaining agreement with a
workers’ organization, such agreement will be respected. Where such
agreements do not exist, or do not address working conditions and
terms of employment, the client will provide reasonable working
Please see recommendation for PS2, paragraph 10, above.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
conditions and terms of employment.
Union Convention issued by the Federation of Rural Workers of Mato
Grosso do Sul State, clause 15, state that migrant workers shall not be hired
by third part on behalf of the company, in except of if the third part is a
regular and formal company as defined by law. As reported bellow on
paragraph 10 one worker reported that he was hired by a third part that
charged him with a fee.
10.
The client will identify migrant workers and ensure that they are
engaged on substantially equivalent terms and conditions to nonmigrant workers carrying out similar work.
PS 2, paragraph 10
NOT COMPLYING
ELDORADO has currently 1556 workers, 88% of them are rural workers,
around 1370. 37% of those are migrant workers from Maranhão, Piauí and
Bahia States.
Term of conditions and employment are the same as those provided to local
workers: remuneration, overtime, hours of work, weekly rest, health and
safety, etc. Migrant workers are also represented by the local Union
Agreement.
ELDORADO reported that workers are recruited by a third part contracted
by 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 to
Multipla, which will not be charged from the worker. The contract does not
detail the procedure to contract migrant workers.
Develop 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 issued
to 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 are
forbidden to subcontract others to the recruitment process.
ERM interviewed 9 migrant workers. One of them reported that he was not
recruited by Multipla but by a local man, who charged him a fee of R$150,00
for the recruitment process. The charge of a fee from migrant workers is not
complying with the ILO Convention 110, and the Federal Decree 58.826/66,
that promulgates it, and Law 9777/98 and the Union Convention issued by
the Federation of Rural Workers of Mato Grosso do Sul State, clause 15.
Three migrant workers reported that they traveled to Tres Lagoas in a bus
rented by ELDORADO and that they did not pay for the travel.
ELDORADO reported that workers came on regular bus, and the travel
expenses were paid by ELDORADO. ELDORADO informed that it did not
issue the Declaration of the transport of Workers (CDTT), which does not
comply with the Federal Standard SIT 76/09. This law states that the
transport of workers recruited to work in an area other than their origin shall
be communicated to Labour regional authority (Superintendências
Regionais do Trabalho- SRTE), SRTE through the Declaration of the
transport of Workers (CDTT). The enticement and transport of workers to
different location of their origin is a crime under Art. 207 of the Penal Code.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 2, paragraph 11
NR 31: Regulatory
and Health of workers on
agriculture, cattle rising,
forest exploration and
others rural activities
NR24: Sanitary and
comfort at the work place
of Disabled Person.
PARTIALLY COMPLIANT
Ensure that accommodations are in compliance with NR 31 and NR24.
ELDORADO is directly in charge of 3 accommodations for employees
directly hired by it. A company, named Foco, was hired to build and
manage the accommodation: (1) Accommodation Agua Clara, located at
Agua Clara, has capacity for 340workers; (2) Accomodation Inocencia,
located at Inocencia. has capacity for 180 workers.. Currently, there is a total
of 330 workers in both accommodations.
The third accommodation is a house close to Accommodation Agua Clara
that has capacity for 40 workers. For the purpose of this report, will call this
accommodation “Agua Clara II”.
11.
Where accommodation services are provided to workers covered by
the scope of this Performance Standard, the client will put in place and
implement policies on the quality and management of the
accommodation and provision of basic services. The accommodation
services will be provided in a manner consistent with the principles of
non-discrimination and equal opportunity. Workers’ accommodation
arrangements should not restrict workers’ freedom of movement or of
association.
ERM visited the three accommodations. .
At Accommodation Agua Clara II, 1 room had no window and does not
comply with NR31 and NR 24, paragraph 24.5.26
ELDORADO informed that there is no restriction to freedom of movement
and workers can leave or enter the accommodation at any time. This was
confirmed by workers interviewed at the accommodation .
Workers’ Organizations
12.
In countries where national law recognizes workers’ rights to form and
to join workers’ organizations of their choosing without interference
and to bargain collectively, the client will comply with national law.
Where national law substantially restricts workers’ organizations, the
client will not restrict workers from developing alternative
mechanisms to express their grievances and protect their rights
regarding working conditions and terms of employment. The client
should not seek to influence or control these mechanisms
PS 2, paragraph 12
Labour Law
Consolidation).
13.
In either case described in paragraph 13 of this Performance Standard,
and where national law is silent, the client will not discourage workers
from electing worker representatives, forming or joining workers’
organizations of their choosing, or from bargaining collectively, and
will not discriminate or retaliate against workers who participate, or
seek to participate, in such organizations and collective bargaining. The
client will engage with such workers’ representatives and workers’
organizations, and provide them with information needed for
meaningful negotiation in a timely manner. Workers’ organizations are
expected to fairly represent the workers in the workforce.
PS 2, paragraph 13
Labour Law
Consolidation).
COMPLIANT
ELDORADO’s rural workers are represented by the Federation of Rural
Workers of Mato Grosso do Sul State and the Union of Rural Workers of
Andradina.
PARTIALLY COMPLIANT
LDORADO reported that workers are informed about union contribution
during the induction. Some workers interviewed reported not being
informed about possibility to join an union or union representation.
None
Include at the rural workers induction and other training the information
about union contacts and union agreement
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
The client will not make employment decisions on the basis of personal
characteristics unrelated to inherent job requirements. The client will
base the employment relationship on the principle of equal
opportunity and fair treatment, and will not discriminate with respect
to any aspects of the employment relationship, such as recruitment and
hiring, compensation (including wages and benefits), working
conditions and terms of employment, access to training, job
assignment, promotion, termination of employment or retirement, and
disciplinary practices. The client will take measures to prevent and
address harassment, intimidation, and/or exploitation, especially in
regard to women. The principles of non-discrimination apply to
migrant workers.
PS 2, paragraph 14
Labour Law
Consolidation).
PARTIALLY COMPLIANT
ERM’s limited interview with workers did not identify any discriminatory
practice performed by ELDORADO or its contractors.
Refer to PS2, paragraph 7,that recommends aspects to be covered by the
Human Rights Policy.
Take measures to prevent any harassment, including sexual harassment or
psychological mistreatment within the workplace, e.g:

Include a module about harassment for leaders, managers and
rural workers supervisors;

Monitor and treat cases of harassment identified through
ombudsman.

Include on all workers induction information about harassment.

Define measures and orient contractors to prevent discrimination
in employment relationship.
In countries where national law provides for non-discrimination in
employment, the client will comply with national law. When national
laws are silent on non-discrimination in employment, the client will
meet this Performance Standard. In circumstances where national law
is inconsistent with this Performance Standard, the client is encouraged
to carry out its operations consistent with the intent of paragraph 15
above without contravening applicable laws.
PS 2, paragraph 15
Non-Discrimination and Equal Opportunity
14
15.
16.
PS 2, paragraph 15
of Disabled Person.
Law 8069/90 - Establish
the Child and Teenager
Statute
Federal Decree 5.598/05 Regulates the
employment of
measures.
Special measures of protection or assistance to remedy past
discrimination or selection for a particular job based on the inherent
requirements of the job will not be deemed as discrimination, provided
they are consistent with national law.
Currently, ELDORADO has not taken measures to prevent and address
discrimination in employment relationship, including harassment,
intimidation and/or exploitation.
PARTIALLY COMPLIANT
Identify total number of employees with disability and, if not sufficient to
comply with law 3298/99, to define measures to do so at operation phase.
ELDORADO has recently hired a doctor to identify among workers those
that have disability and if the company is in compliance with the Law 7.853 Define measure to comply with Apprentice Law.
that states a quota of 5% of workers with disability for companies with more
than 1,0000 workers.
ELDORADO has not developed a plan or measure to achieve the quota
defined by law at operation phase.
ELDORADO informed that there is no apprentice at the site, which is a not
compliance with the Apprentice Law 5.598/05 apprentices, state a quota for
apprentices. However, the company sponsors the Program My First Job,
that aims to provide technical training to almost 200 students of the local
high 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 measure
undertaken seems to be sufficient to achieve compliance with this
requirement in the future.
Brazilian companies typically face difficulty in complying with both laws
NOT APPLICABLE
ERM did not identify any case that demanded reparation.
Retrenchment
17.
Prior to implementing any collective dismissals, the client will carry
PS 2, paragraph 17
out an analysis of alternatives to retrenchment. If the analysis does not
identify viable alternatives to retrenchment, a retrenchment plan will
be developed and implemented to reduce the adverse impacts of
retrenchment on workers. The retrenchment plan will be based on the
principle of non-discrimination and will reflect the client’s consultation
with workers, their organizations, and, where appropriate, the
government, and comply with collective bargaining agreements if they
exist. The client will comply with all legal and contractual
requirements related to notification of public authorities, and provision
of information to, and consultation with workers and their
organizations.
NOT APPLICABLE
ELDORADO reported that they are in contracting phase and there are no
plans for collective dismissal, therefore no retrenchment plan has been
developed.
Prior to implementing any collective dismissals, the client should carry out
an analysis of alternatives to retrenchment. Retrenchment means the
elimination of a number of work positions or the dismissal or layoff of a
number of worker by an employer, generally by reason of plant closing or
for cost savings.
For migrant workers, ELDORADO provides their return to the city of origin. The retrenchment plan should address costs and alternative solutions to
retrenchment, e.g working time reduction programs, employee capacity
building programs, and other those proposed by employees and; other
stakeholders.
If dismissal is unavoidable, the plan shall consider schedule of the dismissal,
retrenchment methods and procedure, selection criteria, severance
payments, offers to alternative employment, job placement, etc.
Selection criteria shall be objective, fair, transparent and based on non
discrimination.
Workers, government and relevant stakeholders shall be consulted to the
plan development.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 2, paragraph 19
COMPLIANT
For dismissal, ELDORADO identifies if the worker has any legal restriction
to be dismissal. Human resource personnel also evaluate with the manager
the reasons for the dismissal of the workers. ELDORADO is developing a
Plan to Evaluate Workers Performance.
For Workers Contractors, ELDORADO verifies on a monthly bases
documents that probes that contractors have paid social security benefits
and contributions defined by Brazilian Law for dismissal proposes.
None
NR 31: Regulatory
COMPLIANT
None
There is a grievance mechanism for rural workers named “Human Resource
in the field”. A representative from Human Resource visit workers in the
field twice a month to register their demands. ERM reviewed a spreadsheet
containing the name of the worker, complaint, feedback provided, and time
of response.
PS 2, paragraph 21
Federal Decree 5.598/05 Regulates the
employment of
measures.
Recommendation
forms of child labour and
immediate action to
eliminate them,
convened in Geneva,
June 17 1999.
Recommendation on
minimum age for
admission to
employment.
Decree 6.481/2008 -
COMPLIANT
ELDORADO informed that there is no worker under 18 years old
performing any activity at the site. Copies of documents related to
contractor’s worker are verified by ELDORADO, for which they believe
they are not in risk of child labour.
ELDORADO sponsors the Regional Program to Combat the Sexual
Exploration of Children, leaded by the Public Ministry for Children and the
Três Lagoas’ Network for the Protection of Children.
This program is part of the workers induction providing information about
children’s right.
Retrenchment
19.
The client should ensure that all workers receive notice of dismissal
and severance payments mandated by law and collective agreements
in a timely manner. All outstanding back pay and social security
benefits and pension contributions and benefits will be paid (i) on or
before termination of the working relationship to the workers, (ii)
where appropriate, for the benefit of the workers, or (iii) payment will
be made in accordance with a timeline agreed through a collective
agreement. Where payments are made for the benefit of workers,
workers will be provided with evidence of such payments.
Grievance Mechanism
20.
The client will provide a grievance mechanism for workers (and their
organizations, where they exist) to raise workplace concerns. The client
will inform the workers of the grievance mechanism at the time of
recruitment and make it easily accessible to them. The mechanism
should involve an appropriate level of management and address
concerns promptly, using an understandable and transparent process
that provides timely feedback to those concerned, without any
retribution. The mechanism should also allow for anonymous
complaints to be raised and addressed. The mechanism should not
impede access to other judicial or administrative remedies that might
be available under the law or through existing arbitration procedures,
or substitute for grievance mechanisms provided through collective
agreements.
Protecting the Work Force
Child Labor
21.
The client will not employ children in any manner that is economically
exploitative, or is likely to be hazardous or to interfere with the child’s
education, or to be harmful to the child’s health or physical, mental,
spiritual, moral, or social development. The client will identify the
presence of all persons under the age of 18. Where national laws have
provisions for the employment of minors, the client will follow those
laws applicable to the client. Children under the age of 18 will not be
employed in hazardous work. All work of persons under the age of 18
will be subject to an appropriate risk assessment and regular
monitoring of health, working conditions, and hours of work.
None
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
Regulates Articles 3 and
4 of the ILO Convention
182 concerning the worst
forms of child labour and
immediate action to
eliminate them,
convened in Geneva,
June 17 1999.
Satndard (Instrução
Normativa) SIT n° 66/06
- States on work
inspection to combat
child labour and protect
teenager work.
Forced Labor
Forced
Labor
The client will not employ forced labor, which consists of any work or
service not voluntarily performed that is exacted from an individual
under threat of force or penalty. This covers any kind of involuntary or
compulsory labor, such as indentured labor, bonded labor, or similar
labor-contracting arrangements. The client will not employ trafficked
persons.
PS 2, paragraph 22
on the Law 2848/40
(Criminal Code) - Labour
rights: Slave labour
COMPLIANT
ELDORADO informed that the operation is not in risk of employment of
slave like conditions. All workers directly hired by ELDORADO are formal
registered and ELDORADO verifies the documentation of contractor’s
workers. This was evidenced by documents verification.
ELDORADO informed that total hours of work are 8 plus 2 hours of
employment commuting to work. The supervisor worker is in charge to
register working hours.
Workers reported to perform overtime occasionally on Saturday, for which
overtime is paid.
PS 2, paragraph 23
IFC General EHS –
Occupational Health and
safety
COMPLIANT
None
ERM visited workers in the field, working on eucalyptus plantation at Barra
Mansa farm. Bathrooms were available, as long as potable water, a covered
place to have meals, in compliance with NR31.
According to reviewed documents and information provided to ERM
during interviews with health and safety technicians and workers,
ELDORADO is in compliance with this requirement. This was confirmed by
visual inspection of workers using adequate PPE and review of documents
on field.
ELDORADO informed that there were no occupational diseases among
workers. ERM also could not identify studies that assessed potential
occupational diseases.
None
23.
The client will provide a safe and healthy work environment, taking
into account inherent risks in its particular sector and specific classes of
hazards 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 disease
arising from, associated with, or occurring in the course of work by
minimizing, as far as reasonably practicable, the causes of hazards. In a
manner consistent with good international industry practice, as
reflected in various internationally recognized sources including the
World Bank Group Environmental, Health and Safety Guidelines, the
client will address areas that include the (i) identification of potential
hazards to workers, particularly those that may be life-threatening; (ii)
provision of preventive and protective measures, including
modification, substitution, or elimination of hazardous conditions or
substances; (iii) training of workers; (iv) documentation and reporting
of occupational accidents, diseases, and incidents; and (v) emergency
prevention, preparedness, and response arrangements. For additional
information related to emergency preparedness and response refer to
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
NR 31: Regulatory
Labour Law
Consolidation).
PARTIALLY COMPLIANT
There are 577 contractors workers hired by Plantar, J&S and Ruah to
perform rural activities. ELDORADO developed a procedure (Contracts
Verification 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 are
verified on a monthly basis and a report is issued for each verification. In
case the contractor is not complying with the items, a part of the contractor
payment is retained until compliance is achieved.
Refer to PS2, paragraph 7, that recommends aspects to be covered by the
Human ResourcesPolicy.
24.
25.
With respect to contracted workers the client will take commercially
reasonable efforts to ascertain that the third parties who engage these
workers are reputable and legitimate enterprises and have an
appropriate ESMS that will allow them to operate in a manner
consistent with the requirements of this Performance Standard, except
for paragraphs 18–19, and 27–29.
The client will establish policies and procedures for managing and
monitoring the performance of such third party employers in relation
to the requirements of this Performance Standard. In addition, the
client will use commercially reasonable efforts to incorporate these
requirements in contractual agreements with such third party
employers.
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 in
employment relationship, and harassment.
Reportedly, ELDORADO’s practice is to verify contractor’s workers
documentation and health and safety conditions in place and to revise
documentation quarterly. The person in charge of the contractor monitors
contractor’s operational performance and legal fiscal requirements.
Clearance certificate for fiscal workers payment are provided monthly.
There is no policy or procedure to monitoring the contractor performance
associated with the other aspects of this performance standard, e.g no
discrimination, equal of opportunity,, treatment of workers, etc.
ERM revised documentation of five workers from Plantar, four workers
from J&S Florestal and three for Ruah and they were in compliance with the
26.
The client will ensure that contracted workers, covered in paragraphs
24–25 of this Performance Standard, have access to a grievance
mechanism. In cases where the third party is not able to provide a
grievance mechanism the client will extend its own grievance
mechanism to serve workers engaged by the third party.
PS 2, paragraph 26
PARTIALLY COMPLIANT

Though its own grievance mechanism, ELDORADO registers
contractor’s workers complaints and direct it to the contract company.

ELDORADO does not monitor or orient contractors (J&S, Plantar and
Ruah) on implementing a grievance mechanism.
Guarantee that contractor’s workers are provided with a grievance
mechanism (developed either by the contractor or by ELDORADO).
PS 2, paragraph 27
PARTIALLY COMPLIANT

Wood Supply
ERM visited one supplier of wood. The supplier owns a 20,000 hectare and
2,000 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 several
documents and clearance certification to identify legal risks associated with
the farm and the wood transaction. Those documents and certificates could,
in thesis, demonstrate any judicial action against the farm due to child
labour or forced labour.
Identify categories of significant suppliers in the primary supply chain in
high risk of child labour and forced labor.
Define measures to monitor significant suppliers on employment of child
labour and forced labour. The measures shall be defined according to the
suppliers risk. High risk suppliers shall be audited.
For wood suppliers that are not FSC certified, the measure shall be
conducted between the contract signature and the harvesting of the wood.
For Vô Fiorino Farm and Buba, it is suggested to revise the contracts or to
identify other legal measure to include the clause that both parts will not
employ child or forced labour.
Supply Chain
27.
Where there is a high risk of child labor or forced labor in the primary
supply chain, the client will identify those risks consistent with
paragraphs 21 and 22 above. If child labor or forced labor cases are
identified, the client will take appropriate steps to remedy them. The
client will monitor its primary supply chain on an ongoing basis in
order to identify any significant changes in its supply chain and if new
risks or incidents of child and/or forced labor are identified, the client
will take appropriate steps to remedy them.
The contract has a clause that states that both parts are responsible to avoid
to 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 ELDORADO
does not monitor suppliers during this period. Not monitoring wood
suppliers that are not FSC certified poses a risk to the company.
Land Supply
ELDORADO’s contract with land supply has a clause that states that both
parts are responsible to avoid the employment of child or forced labour. The
farms Vô Fiorindo and Buba were leased by the company MMX and then
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
transferred to ELDORADO. The contract signed by MMX and the farmers
does not contain specific clause about child and forced labour. No other
measure has been taken to identify and avoid the employment of child and
forced labour by these land suppliers.
At Buba Farm, ELDORADO leases part of the property, while the rest is
cattle raising.
Supply Chain
28.
29.
Additionally, where there is a high risk of significant safety issues
related to supply chain workers, the client will introduce procedures
and mitigation measures to ensure that primary suppliers within the
supply chain are taking steps to prevent or to correct life-threatening
situations.
29
COMPLIANT
None
There is no formal procedure to classify supplier’s risks, but primary
suppliers (contractors) are verified on contractual terms and through IVC, as
explained on paragraph 25.
The ability of the client to fully address these risks will depend upon
the client’s level of management control or influence over its primary
suppliers. Where remedy is not possible, the client will shift the
project’s primary supply chain over time to suppliers that can
demonstrate that they are complying with this Performance Standard.
No:
4.
During the project life-cycle, the client will consider ambient
conditions and apply technically and financially feasible resource
efficiency and pollution prevention principles and techniques that are
best suited to avoid, or where avoidance is not possible, minimize
adverse impacts on human health and the environment. The principles
and techniques applied during the project life-cycle will be tailored to
the hazards and risks associated with the nature of the project and
consistent with good international industry practice (GIIP), as reflected
in various internationally recognized sources, including the World
Bank Group Environmental, Health and Safety Guidelines (EHS
Guidelines).
5.
The client will refer to the EHS Guidelines or other internationally
recognized sources, as appropriate, when evaluating and selecting
resource efficiency and pollution prevention and control techniques for
the project. The EHS Guidelines contain the performance levels and
measures that are normally acceptable and applicable to projects.
When host country regulations differ from the levels and measures
presented in the EHS Guidelines, clients will be required to achieve
whichever is more stringent. If less stringent levels or measures than
those provided in the EHS Guidelines are appropriate in view of
specific project circumstances, the client will provide full and detailed
justification for any proposed alternatives through the environmental
and social risks and impacts identification and assessment process.
This justification must demonstrate that the choice for any alternate
performance levels is consistent with the objectives of this Performance
Standard.
Related PS
Requirements, EHS
Guidelines (General
Standards
and Safety Guidelines
PARTIALLY COMPLIANT
The Environmental Management System (EMS) developed by ELDORADO
is described in more detail in Performance Standard 1 (paragraph 5).
The forest and harvesting techniques used by ELDORADO are based on
other pulp and paper mills’ experience in Brazil and mainly in the region.
The documentation regarding the EMS does not mention any EHS
International Guideline.
ELDORADO should apply the PTEAS procedure to all lands prior to the
intervention (planting and harvesting). For the lands where intervention
(plantation) has already occurred and no PTEAS undertaken, ELDORADO
should conduct the PTEAS considering impacts already caused by the
activity described by this performance standard (PS3).
ELDORADO should also improve the EMS efficiency regarding the
following programs:
The analysis of environmental impacts related to the forest management was
performed at two levels:
1 – Waste Management Program
a) Analysis of the EMS Guidelines and Procedures:
2 – Hazardous Material Program
3 – Monitoring and Documentation Program
 ELDORADO performed a preliminary impact assessment (Poyry
Silviconsult) in order to evaluate the environmental impacts associated
with the forest activities. However, this study is not fully compliant with
risks and impacts identification process as required in PS 1;
 ELDORADO has developed an EMS that encompasses procedures and
measures to control and minimize the environmental impacts of it is
operations.;
 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 action
plan to mitigate economic, environmental and social impacts tailored for
each farm.
 ELDORADO established guidelines to prevent the use of areas with
native forests, legally protected areas (APP) and/or legal reserves. These
guidelines are being applied on farms visited by ERM.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
The issues of the EMS guidelines and procedures are related to:
 The elaboration and application of the PTEAS is still restricted to few
farms.
 It was not observed a systematic and comprehensive monitoring
documentation system.
b) Efficiency of the EMS procedures:
1 – Critical issues:
 Waste management: ERM observed issues related to the implementation
of the waste management program – see PS 3 Paragraph 12.
 Hazardous material management: ERM observed issues related to the
implementation of the waste management program – see PS 3 Paragraph
13.
2 – Non-critical issues:
 Water management: ERM did not observed issues related to the water
management program – see PS 3 Paragraph 9.
Resource Efficiency
6.
The client will implement technically and financially feasible and cost
effective measures for improving efficiency in its consumption of
energy, water, as well as other resources and material inputs, with a
focus on areas that are considered core business activities. Such
measures will integrate the principles of cleaner production into
product design and production processes with the objective of
conserving raw materials, energy, and water. Where benchmarking
data are available, the client will make a comparison to establish the
relative level of efficiency.
PS 3, paragraph 6
COMPLIANT
See PS3 Paragraphs 4 and 5.
PARTIALLY COMPLIANT
The company presented the calculation of carbon sequestration in relation to
the area planted with eucalyptus. The company did not provide documents
relating to inventory of Greenhouse Gases (GHG) as an energy balance of the
project.
The project includes the use of fossil fuel sources and will result in emission
of greenhouse gases.
The company should quantify GHG emissions, not only carbon
sequestration, but also emissions, as the first step in managing and
ultimately reducing emissions in a cost-effective manner, as required by
The company must perform a GHG emissions inventory (scope 1 for own
sources and scope 2 for energy consumption), considering current and
future activities. It is suggested to follow the IPCC (Intergovernmental Panel
on Climate Change) methodology.
PS 3, paragraph 9
NOT APPLICABLE
Reportedly, the activity is not a significant net consumer of water, or
contributes to depletion of water resources to the extent that third parties’
ability to access water is adversely affected. No evidence was provided in
order to check the statement.
Develop assessment of whether the project is a significant consumer of
water and the impacts of this consumption.
Greenhouse Gases
7.
In addition to the resource efficiency measures described above, the
client will consider alternatives and implement technically and
financially feasible and cost-effective options to reduce project-related
GHG emissions during the design and operation of the project. These
options may include, but are not limited to, alternative project
locations, 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 25,000
tonnes of CO2-equivalent annually, the client will quantify direct
emissions from the facilities owned or controlled within the physical
project boundary, as well as indirect emissions associated with the offsite production of energy used by the project. Quantification of GHG
emissions will be conducted by the client annually in accordance with
internationally recognized methodologies and good practice.
Water Consumption
9.
When the project is a potentially significant consumer of water, in
addition to applying the resource efficiency requirements of this
Performance Standard, the client shall adopt measures that avoid or
reduce water usage so that the project’s water consumption does not
have significant adverse impacts on others. These measures include,
but are not limited to, the use of additional technically feasible water
conservation measures within the client’s operations, the use of
alternative water supplies, water consumption offsets to reduce total
demand for water resources to within the available supply, and
evaluation of alternative project locations.
In terms of water management, it is worth to mention:
 The state environmental agency does not require special permit to use
water from surface or underground sources.
 There is low demand for water use on forest activities at the visited farms.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
ELDORADO prioritizes the forest plantation on rain season in order to
decrease 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 forest
plantation does not require constant maintenance; therefore, human
activities in those farms are not constant.
10.
11.
The client will avoid the release of pollutants or, when avoidance is not PS 3, paragraph 10 and
feasible, minimize and/or control the intensity and mass flow of their 11
release. This applies to the release of pollutants to air, water, and land General EHS Guidelines
due to routine, non-routine, and accidental circumstances with the
potential for local, regional, and transboundary impacts. Where
historical pollution such as land or ground water contamination exists,
the client will seek to determine whether it is responsible for mitigation
measures. If it is determined that the client is legally responsible, then
these liabilities will be resolved in accordance with national law, or
where this is silent, with GIIP.
To address potential adverse project impacts on existing ambient
conditions, the client will consider relevant factors, including, for
example (i) existing ambient conditions; (ii) the finite assimilative
capacity of the environment; (iii) existing and future land use; (iv) the
project’s proximity to areas of importance to biodiversity; and (v) the
potential for cumulative impacts with uncertain and/or irreversible
consequences. In addition to applying resource efficiency and
pollution control measures as required in this Performance Standard,
when the project has the potential to constitute a significant source of
emissions in an already degraded area, the client will consider
additional strategies and adopt measures that avoid or reduce negative
effects. These strategies include, but are not limited to, evaluation of
project location alternatives and emissions offsets.
COMPLIANT
During site visit, it was reported that there is a procedure for handling
possible contaminated soil with oil or other residues that might accidentally
leak from equipment maintenance on field. This procedure was confirmed by
maintenance staff during field inspection and consists on collecting the
contaminated soil, storing it in bags and requesting a third party company to
adequately collect it and dispose.
Relating to air pollution prevention, ELDORADO has provided the
following procedures:
 Determining the degree of black smoke emitted by stationary sources and
vehicles powered by diesel oil;
 Preventive and corrective maintenance of equipment, vehicles and
machinery;
 In relation to waste handling for pollution prevention see PS 3, paragraph
12.
 Refer to PS 3, paragraphs 13 – 17.
Wastes
12.
The client will avoid the generation of hazardous and non-hazardous
waste materials. Where waste generation cannot be avoided, the client
will reduce the generation of waste, and recover and reuse waste in a
manner that is safe for human health and the environment. Where
waste cannot be recovered or reused, the client will treat, destroy, or
dispose of it in an environmentally sound manner that includes the
appropriate control of emissions and residues resulting from the
handling and processing of the waste material. If the generated waste
is considered hazardous, the client will adopt GIIP alternatives for its
environmentally sound disposal while adhering to the limitations
applicable to its transboundary movement. When hazardous waste
disposal is conducted by third parties, the client will use contractors
that are reputable and legitimate enterprises licensed by the relevant
government regulatory agencies and obtain chain of custody
documentation to the final destination. The client should ascertain
whether licensed disposal sites are being operated to acceptable
standards and where they are, the client will use these sites. Where this
is not the case, clients should reduce waste sent to such sites and
consider alternative disposal options, including the possibility of
developing their own recovery or disposal facilities at the project site.
PS 3, paragraph 12
CONAMA Resolution
307/2002 establish
procedures for the
construction waste
management;
CONAMA Resolution
313/2002, regulates the
State and federal
industrial Waste
Management Plan;
CONAMA Resolution
348/2004 includes
asbestos as hazardous
wastes.
PARTIALLY COMPLIANT
Improve the Waste Management Program in order to accomplish the
following goals:
 Verify if the licensed disposal sites are being operated to acceptable
Compliant procedures:
standards.
 Sanitary waste from chemical bathrooms temporarily installed on the
 Develop a program to reduce waste sent to disposal sites or alternative
farms for field work is buried on ground along with organic waste.
disposal options, including the possibility of developing their own
 ERM was not able to evidence any hazardous waste stored
recovery or disposal facilities at the project site.
inappropriately. Currently there are 5 companies responsible for

Improve the efficiency of the waste management procedures in order to
collecting used oil, Class I and II waste (according NBR 10004), healthcare
avoid the problems identified in the site visits regarding the waste
waste, recyclable material, empty pesticide containers and clothes used to
handling and collection.
apply pesticides. These companies are responsible to transport to final
disposal in proper landfills the waste (Permits are listed in the document
list).
 Spreadsheet for waste permitting control has been provided during site
visits.
 A procedure for waste handling and also a Plan for Solid Waste
Management were provided.
 Information has been provided regarding Waste Transfer Permits issued
by State Environmental Agency that the site holds.
Brazilian Standard
ABNT 12235, establishes
requirements for the
hazardous waste storage
areas.
Non-compliant procedures:
IFC General EHS – Waste  Waste handling: during the site visits, it was observed that some types of
management
waste were not adequately handled in the farms. The major issue is
related to the aluminum disposable dishes provided to the workers as
IFC Integrated Steel Mill
part of their daily meal, which sometimes were disposed in an improper
EHS – Solid Waste
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
manner.
 Waste collection: it was reported that, in some cases, the general waste of
the farms was transported to the final waste disposal site by contractor’s
stuff, and therefore, not following the Waste Management guidelines.
 ELDORADO has not provided information on whether licensed disposal
sites are being operated to acceptable standards or a possible program to
reduce waste sent to such sites or alternative disposal options.
Hazardous Materials Management
13.
Hazardous materials are sometimes used as raw material or produced
as product by the project. The client will avoid or, when avoidance is
not possible, minimize and control the release of hazardous materials.
In this context, the production, transportation, handling, storage, and
use of hazardous materials for project activities should be assessed.
The client will consider less hazardous substitutes where hazardous
materials are intended to be used in manufacturing processes or other
operations. The client will avoid the manufacture, trade, and use of
chemicals and hazardous materials subject to international bans or
phase-outs due to their high toxicity to living organisms,
environmental persistence, potential for bioaccumulation, or potential
for depletion of the ozone layer.
PS 3, paragraph 13
PS 4, paragraph 7
IFC General EHS –
Hazardous Materials
Management;
EHS Guidelines for
Forest Harvesting
Operations
PARTIALLY COMPLIANT
Compliant procedures:
 During site visit ERM was not able to identify possible sources of
Polychlorinated Biphenyl (PCBs) in electrical equipment, asbestos
containing materials. However inside the offices there is use of air
conditioning that could be a potential source of ozone depleting
substances in refrigeration systems.
 Reportedly all transport of hazardous materials is held by licensed
companies.
 The application of herbicides (Gliphosate) is performed by trained
employees. It was also observed that all the EHS procedures are in place
during the application of this product, including the use of appropriate
personal protective equipments.
 The use of persistent organic pollutants is not allowed. The pesticides
used at the forestry activities were checked and are not listed in the
Stockholm convention, which entered into force on 17 May, 2004, with
subsequent amendments. See http://www.pops.int/ and PS 3 paragraph
14 to 17.
 Evidences show that ELDORADO and contractor’s personnel follow the
guidelines regarding the triple wash procedures of herbicides containers
Provide additional, detailed information on hazardous materials to be used
throughout the different project stages:
•
volumes;
•
characteristics/ MSDS;
•
handling and storage; and
•
chemicals storage locations.
ELDORADO must inform if the current plant manipulates or uses asbestos
containing materials, PCBs and ozone depleting substances, amounts and
measures to reduce the use. Maintenance area must have adequate
hazardous material storage, with secondary containment or drainage to
avoid leakages on soil and water bodies.
In addition, ELDORADO must improve the efficiency of the Hazardous
Material Management Program in order to fix the issues indicated as noncompliant procedures
Non-compliant procedures:
During the site visits at the farms, it was verified the following issues related
to the handling, storage and final destination of hazardous materials:
a) Storage of Chemical and Hazard Materials:
The chemical storage facilities (central warehouses) were implemented in
strategic farms in order to facilitate the distribution 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 chemical materials, used products, hazardous and non
hazardous waste. At the same location was observed a wet floor, probably
derived from rain water entering through the ventilation openings.
 The chemical inventory control system is not efficient. There are no
documents at these places informing the amount or type of stored
products. The inventory control is basically done by the contractor’s stuff
when the product is being used at the forest plantation sites
 The warehouse has no access restricted to qualified personnel. Anyone
can access and manipulate the products.
 Even though there is a central warehouse, it was observed chemical and
hazard products stored at inadequate places in other farms.
 According to evidence on site visit, hazardous products (paint thinner and
oil for example) from maintenance on cultivation of eucalyptus fields are
stored inadequately. The floor is not paved, there is no secondary
containment or drainage to avoid leakage directly on soil
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
b) Transport of Chemical and Hazard Materials from central warehouses to
the forest plantation sites
 The transport of hazardous and chemicals materials is performed by
contractor’s personnel. It was reported that the contractor’s personnel
does not hold the Emergency Preparedness and Response Plan during the
transportation of these products.
 ERM did not verify the transport operation of these products
c) Temporarily hazard waste disposal facilities
 It was not observed the use of adequate storage facilities to store
temporarily the used herbicides containers. There is no clear definition on
how or where to store these containers. In one farm, misinformation was
provided regarding the location of this facility.
d) Final hazard waste destination
 Reportedly all hazardous waste is not stored and immediately collected
by the respective contracted company for final disposal. In one farm, it
was verified that the hazard waste collection never happened, where it
was possible to count more than 200 used containers at the same place.
14.
15.
16.
17.




The client will, where appropriate, formulate and implement an
integrated pest management (IPM) and/or integrated vector
management (IVM) approach targeting economically significant
pest infestations and disease vectors of public health significance.
The client’s IPM and IVM program will integrate coordinated use
of pest and environmental information along with available pest
control methods, including cultural practices, biological, genetic,
and, as a last resort, chemical means to prevent economically
significant pest damage and/or disease transmission to humans
and animals.
When pest management activities include the use of chemical
pesticides, the client will select chemical pesticides that are low in
human toxicity, that are known to be effective against the target
species, and that have minimal effects on non-target species and
the environment. When the client selects chemical pesticides, the
selection will be based upon requirements that the pesticides be
packaged in safe containers, be clearly labelled for safe and proper
use, and that the pesticides have been manufactured by an entity
currently licensed by relevant regulatory agencies.
EHS Guidelines for
Forest Harvesting
Operations
COMPLIANT
None.
The main products used at the forestry activities are listed below. ERM
consulted the MSDS – material safety data sheet of the materials and also the
document “The WHO – World Health Organization Recommended
Classification of Pesticides by Hazard and Guidelines to Classification 2009”
to verify the classification of the substance. Table below also shows the
classification.
Product
Trop or
Roundup
Original
Active
ingredient
Gliphosate
Function
Control of
weed
WHO
Classification*
DL50
III, page 71
oral,
for rat,
>6000
mg/kg
source
MSDS
dermal,
for rat,
>2000
mg/kg
source
MSDS
The client will design its pesticide application regime to (i) avoid
damage to natural enemies of the target pest, and where
avoidance is not possible, minimize, and (ii) avoid the risks
associated 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 in
accordance with the Food and Agriculture Organization’s
International Code of Conduct on the Distribution and Use of
Pesticides or other GIIP.
Fordor
750WG
Isoxaflutol
Control of
weed
III
Evidence
700WG
Imidacloprido
Termite
control
II, page 78
The client will not purchase, store, use, manufacture, or trade in
products that fall in WHO Recommended Classification of
Pesticides by 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 appropriate controls on manufacture, procurement, or
distribution and/or use of these chemicals. These chemicals
should not be accessible to personnel without proper training,
equipment, and facilities to handle, store, apply, and dispose of
Atta Mex
e Mirex S
Sulfluramide
Ant control
II, page 76
dermal,
for rat,
>2000
mg/kg
source
MSDS
Fertiliser
(10-27-10)
-
Fertiliser
**
**
Fertiliser
(13-00-28)
-
Fertiliser
**
**
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
these products properly.
MAP
-
Fertiliser
**
**
Atumus
and
Acquafol
-
Water
conditioner
**
**
HB10,
Soilfix,
HyC
-
Polymer
**
**
Limestone
and
plaster
-
Soil
correction
**
**
* World Health Organization pesticide classification
Ia = Extremely hazardous; Ib = Highly hazardous; II = Moderately
hazardous; III = slightly hazardous; U = Unlikely to present acute hazard in
normal use; FM = Fumigant, not classified; O = Obsolete as pesticide, not
classified.
** Non toxic products.
According to the consulted information no chemical substance used in the
ELDORADO forestry activities are classified as extremely hazardous or
highly hazardous by the WHO.
However, Atta Mex/ Mirex and Evidence are classified as moderately
hazardous 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 a
third party company. Reportedly employees use proper PPEs and are trained
for handling pesticides. ERM did not observe during the visit the transport of
this material.
Evidence has been provided of the Application and Handling of Pesticides
Training (See document list)
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 4, paragraph 5
EHS Guidelines
Foresting Harvesting
Operations item 1.3
PARTIALLY COMPLIANT
Include workers providing transportation services on educational programs
related to STIs and prevention of fatalities and injuries.
5.
The client will evaluate the risks and impacts to the health and safety of
the Affected Communities during the project life-cycle and will
establish preventive and control measures consistent with good
international industry practice (GIIP), such as in the World Bank
Group Environmental, Health and Safety Guidelines (EHS Guidelines)
or other internationally recognized sources. The client will identify
risks and impacts and propose mitigation measures that are
commensurate with their nature and magnitude. These measures will
favor the avoidance of risks and impacts over minimization.
The increase of transport flow on the inhabitant areas are assessed and
community is informed about it. The PTEAS will also support the
identification of increase of transportation flow on public road.
Develop the transportation plan considering avoiding impacts on
community health and safety, as identified by PTEAS.
The plan for wood transportation is not developed and it should be
supported by the PTEAS carried out before harvesting.
There is a system to combat fire in place (fire brigade). Neighbors and local
government 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 of
water-borne and endemic disease (as leishmaniasis and dengue).
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
The assessment of public health as detailed on these performance standards
is not commonly requested on license process.
ELDORADO is involving in the following programs/action:

participating with the health surveillance system on a program to
combat leishmaniasis;

provision of information about Sexual Transmitted Illness (STIs) to
workers as part of the Program for Public Health and Safety;

support the Tres Lagoas municipality to monitor Dengue and to
define 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 workers
about alcoholism, smoking, besides, monitoring workers occupational health
The social diagnosis assessment undertaken for the 7 municipalities were the
main farms are located indicates as the main vulnerability the lack of
appropriate health public facilities. ELDORADO has met with public
authorities to discuss local facility, areas that must be improved and projects
that could be supported by ELDORADO. Minutes of these meetings were
reviewed by ERM.
Infrastructure and Equipment Design and Safety
6.
The client will design, construct, operate, and decommission the
structural elements or components of the project in accordance with
GIIP, taking into consideration safety risks to third parties or Affected
Communities. When new buildings and structures will be accessed by
members of the public, the client will consider incremental risks of the
public’s potential exposure to operational accidents and/or natural
hazards and be consistent with the principles of universal access.
Structural elements will be designed and constructed by competent
professionals, and certified or approved by competent authorities or
professionals. When structural elements or components, such as dams,
tailings dams, or ash ponds are situated in high-risk locations, and
their failure or malfunction may threaten the safety of communities,
the client will engage one or more external experts with relevant and
recognized experience in similar projects, separate from those
responsible for the design and construction, to conduct a review as
early as possible in project development and throughout the stages of
project design, construction, operation, and decommissioning. For
projects that operate moving equipment on public roads and other
forms of infrastructure, the client will seek to avoid the occurrence of
incidents and injuries to members of the public associated with the
operation of such equipment.
PS 4, paragraph 6
NOT APPLICABLE
PS 4, paragraph 7
14
IFC General EHS –
Hazardous Materials
Management;
EHS Guidelines for
Forest Harvesting
Operations
See PS 3, paragraphs 13 and 14
Hazardous Materials Management and Safety
7.
exposure to hazardous materials and substances that may be released
by the project. Where there is a potential for the public (including
workers and their families) to be exposed to hazards, particularly those
that may be life-threatening, the client will exercise special care to
avoid or minimize their exposure by modifying, substituting, or
eliminating the condition or material causing the potential hazards.
Where hazardous materials are part of existing project infrastructure or
components, the client will exercise special care when conducting
decommissioning activities in order to avoid exposure to the
None
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 4, paragraph 8
EHS Guidelines for
Forest Harvesting
Operations
Refer to PS 6, paragraphs 6 and 7
community. The client will exercise commercially reasonable efforts to
control the safety of deliveries of hazardous materials, and of
transportation and disposal of hazardous wastes, and will implement
measures to avoid or control community exposure to pesticides, in
accordance with the requirements of Performance Standard 3.
Ecosystem Services
8.
The project’s direct impacts on priority ecosystem services may result in
adverse health and safety risks and impacts to Affected Communities. With
respect to this Performance Standard, ecosystem services are limited to
provisioning and regulating services as defined in paragraph 2 of
Performance Standard 6. For example, land use changes or the loss of
natural buffer areas such as wetlands, mangroves, and upland forests that
mitigate the effects of natural hazards such as flooding, landslides, and fire,
may result in increased vulnerability and community safety-related risks
and impacts. The diminution or degradation of natural resources, such as
adverse impacts on the quality, quantity, and availability of freshwater,
may result in health-related risks and impacts. Where appropriate and
feasible, the client will identify those risks and potential impacts on priority
ecosystem services that may be exacerbated by climate change. Adverse
impacts should be avoided, and if these impacts are unavoidable, the client
will implement mitigation measures in accordance 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 with paragraphs 25–29 of Performance Standard 5.
Community Exposure to Disease
9.
PS 9, paragraph 9 and 10 Refer to PS4, paragraph 5.
exposure to water-borne, water-based, water-related, and vector-borne
diseases, and communicable diseases that could result from project
activities, taking into consideration differentiated exposure to and
higher sensitivity of vulnerable groups. Where specific diseases are
endemic in communities in the project area of influence, the client is
encouraged to explore opportunities during the project life-cycle to
improve environmental conditions that could help minimize their
incidence.
10.
The client will avoid or minimize transmission of communicable
diseases that may be associated with the influx of temporary or
permanent project labor.
PS 4, paragraph 10
PS 4, paragraph 11
General EHS Guidelines
EHS Guidelines for
Forest Harvesting
Operations
COMPLIANT
The company has provided copy of their Emergency Plan 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 on
emergency behavior in case of fire, there is telephone for emergency and
there are cars for fire combat available. Record of firefighting training was
presented for Três Lagoas unit. (See document list).
The emergency plan addresses on how information is disclosed to
affected communities, relevant government agencies or other relevant
parties.
One of the contractors (Ruah) reported not being aware of the Emergency
Procedure although he reported to know the general actions in case of
emergency.
11.
In addition to the emergency preparedness and response requirements
described in Performance Standard 1, the client will also assist and
collaborate with the Affected Communities, local government agencies,
and other relevant parties, in their preparations to respond effectively
to emergency situations, especially when their participation and
collaboration are necessary to respond to such emergency situations. If
local government agencies have little or no capacity to respond
effectively, the client will play an active role in preparing for and
responding to emergencies associated with the project. The client will
document its emergency preparedness and response activities,
resources, and responsibilities, and will disclose appropriate
information to Affected Communities, relevant government agencies,
or other relevant parties.
None.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PARTIALLY COMPLIANT
Ensure the grievance a procedure and Stakeholder Engagement Plan (PS1
Paragh 25) are designed to identify any concerns from local government,
Security Personnel
12.
When the client retains direct or contracted workers to provide security PS 4, paragraph 12
to safeguard its personnel and property, it will assess risks posed by its
security arrangements to those within and outside the project site. In
making such arrangements, the client will be guided by the principles
of 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 to
ensure 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 Affected
Communities; and require them to act within the applicable law. The
client will not sanction any use of force except when used for
preventive and defensive purposes in proportion to the nature and
extent of the threat. The client will provide a grievance mechanism for
Affected Communities to express concerns about the security
arrangements and acts of security personnel.
At most of the farms there are no security personnel but workers who
perform rounds to identify fires and infestations.
The procedure PO-SIL-008 defines qualification of workers to perform the
round, what is to be identified during the round and communication flow in
case of an event is identified.
Security personnel are provided at the accommodation by a third part
company named Apolo Segurança Privada, hired by Foco. Foco provided
evidence of Apolo certificate to operate, issued by the federal police, and the
certificate that authorizes one worker to provide security issued by a
certificated school.
Define procedures on the correct code of conduct and use of the force by
security personnel. This shall include measures to investigate and address
any complaints regarding potential human right abuses committed by those
providing security.
Monitor those providing security arrangement to identify compliance with
the above mentioned procedures.
At the farm Correntes there are security personnel hired by the previous
owner of the land (the company MMX). ERM interviewed the security
working and documentation was according to Brazilian legislation.
ELDORADO reported that they do not to monitor security arrangements.
13.
The client will assess and document risks arising from the project’s use PS 4, paragraph 13
of government security personnel deployed to provide security
services. The client will seek to ensure that security personnel will act
in a manner consistent with paragraph 12 above, and encourage the
relevant public authorities to disclose the security arrangements for the
client’s facilities to the public, subject to overriding security concerns.
NOT APPLICABLE
Security Personnel
14.
The client will consider and, where appropriate, investigate all
allegations of unlawful or abusive acts of security personnel, take
action (or urge appropriate parties to take action) to prevent
recurrence, and report unlawful and abusive acts to public authorities.
PS 4, paragraph 14
PARTYALLI COMPLIANT
There is grievance mechanism to workers in place that could receive
complaint about security personnel abuses. ELDORADO informed that all
grievances received are treated and investigated. If the abuse or inadequate
behavior is proved, the person providing security might be removed to
another position or dismissed.
ELDORADO has no procedure to investigate and treat cases of human right
abuses, if committed by those providing security personnel, neither to
communicate public authority about it.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PS 5, paragraph 8 to32
COMPLIANT
ELDORADO informed the farm acquired and leased are voluntary land
transactions. It was also reported that ELDORADO seeks land which
previous 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 identify
any restriction to the land transaction, which includes land documentation
and land and owner clearance certificate at federal justice, labour justice, etc.
None
General
Project Design
8.
The client will consider feasible alternative project designs to avoid or
minimize physical and/or economic displacement, while balancing
environmental, social, and financial costs and benefits, paying
particular attention to impacts on the poor and vulnerable.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
ELDORADO informed that visits are undertaken and in case occupiers are
identified, the transaction is not concluded.
Compensation and Benefits for Displaced Persons
9.
When displacement cannot be avoided, the client will offer displaced

communities and person’s compensation for loss of assets at full
replacement cost and other assistance to help them improve or restore
their standards of living or livelihoods, as provided in this Performance
Standard. Compensation standards will be transparent and applied
consistently to all communities and persons affected by the
displacement. 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 take
possession of acquired land and related assets only after compensation
has been made available and, where applicable, resettlement sites and
moving allowances have been provided to the displaced persons in
addition to compensation. The client will also provide opportunities to
displaced communities and persons to derive appropriate development
benefits from the project.
PS 5, paragraph 9
NOT APPLICABLE because no resettlement was carried out.
None
None
None
Community Engagement
10.
The client will engage with Affected Communities, including host
PS 5, paragraph 10
communities, through the process of stakeholder engagement
described in Performance Standard 1. Decision-making processes
related to resettlement and livelihood restoration should include
options and alternatives, where applicable. Disclosure of relevant
information and participation of Affected Communities and persons
will continue during the planning, implementation, monitoring, and
evaluation of compensation payments, livelihood restoration activities,
and resettlement to achieve outcomes that are consistent with the
objectives of this Performance Standard.16 Additional provisions apply
to consultations with Indigenous Peoples, in accordance with
Grievance Mechanism
11.
The client will establish a grievance mechanism consistent with
PS 5, paragraph 11
Performance Standard 1 as early as possible in the project development
phase. This will allow the client to receive and address specific
concerns about compensation and relocation raised by displaced
persons or members of host communities in a timely fashion, including
a recourse mechanism designed to resolve disputes in an impartial
manner.
12.
Where involuntary resettlement is unavoidable, either as a result of a
PS 5, paragraph 12 to 16
negotiated settlement or expropriation, a census will be carried out to
collect appropriate socio-economic baseline data to identify the persons
who will be displaced by the project, determine who will be eligible for
compensation and assistance, and discourage ineligible persons, such
as opportunistic settlers, from claiming benefits. In the absence of host
government procedures, the client will establish a cut-off date for
eligibility. Information regarding the cut-off date will be well
documented and disseminated throughout the project area.
13.
In cases where affected persons reject compensation offers that meet
the requirements of this Performance Standard and, as a result,
expropriation or other legal procedures are initiated, the client will
explore opportunities to collaborate with the responsible government
agency, and, if permitted by the agency, play an active role in
resettlement planning, implementation, and monitoring (see
paragraphs 30–32).
No:
14.
The client will establish procedures to monitor and evaluate the
implementation of a Resettlement Action Plan or Livelihood
Restoration Plan (see paragraphs 19 and 25) and take corrective action
as necessary. The extent of monitoring activities will be commensurate
with the project’s risks and impacts. For projects with significant
involuntary resettlement risks, the client will retain competent
resettlement professionals to provide advice on compliance with this
Performance Standard and to verify the client’s monitoring
information. Affected persons will be consulted during the monitoring
process.
Related PS
Requirements, EHS
Guidelines (General
Standards
None
None
15.
Implementation of a Resettlement Action Plan or Livelihood
Restoration Plan will be considered completed when the adverse
impacts of resettlement have been addressed in a manner that is
consistent with the relevant plan as well as the objectives of this
Performance Standard. It may be necessary for the client to commission
an external completion audit of the Resettlement Action Plan or
Livelihood Restoration Plan to assess whether the provisions have been
met, depending on the scale and/or complexity of physical and
economic displacement associated with a project. The completion audit
should be undertaken once all mitigation measures have been
substantially completed and once displaced persons are deemed to
have been provided adequate opportunity and assistance to
sustainably restore their livelihoods. The completion audit will be
undertaken by competent resettlement professionals once the agreed
monitoring period is concluded. The completion audit will include, at a
minimum, a review of the totality of mitigation measures implemented
by the Client, a comparison of implementation outcomes against
agreed objectives, and a conclusion as to whether the monitoring
process can be ended
16.
Where the exact nature or magnitude of the land acquisition or
restrictions on land use related to a project with potential to cause
physical and/or economic displacement is unknown due to the stage
of project development, the client will develop a Resettlement and/or
Livelihood Restoration Framework outlining general principles
compatible with this Performance Standard. Once the individual
project components are defined and the necessary information becomes
available, such a framework will be expanded into a specific
Resettlement Action Plan or Livelihood Restoration Plan and
procedures in accordance with paragraphs 19 and 25 below.
Displacement
17.
Displaced persons may be classified as persons (i) who have formal
legal rights to the land or assets they occupy or use; (ii) who do not
have formal legal rights to land or assets, but have a claim to land that
is recognized or recognizable under national law; or (iii) who have no
recognizable legal right or claim to the land or assets they occupy or
use. The census will establish the status of the displaced persons.
18.
Project-related land acquisition and/or restrictions on land use may
result in the physical displacement of people as well as their economic
displacement. Consequently, requirements of this Performance
Standard in respect of physical displacement and economic
displacement may apply simultaneously.
18
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
None
None
In the case of physical displacement, the client will develop a
Resettlement Action Plan that covers, at a minimum, the applicable
requirements of this Performance Standard regardless of the number of
people affected. This will include compensation at full replacement cost
for land and other assets lost. The Plan will be designed to mitigate the
negative impacts of displacement; identify development opportunities;
develop a resettlement budget and schedule; and establish the
entitlements of all categories of affected persons (including host
communities). Particular attention will be paid to the needs of the poor
and the vulnerable. The client will document all transactions to acquire
land rights, as well as compensation measures and relocation activities.
19.
20.
If people living in the project area are required to move to another
location, the client will (i) offer displaced persons choices among
feasible resettlement options, including adequate replacement housing
or cash compensation where appropriate; and (ii) provide relocation
assistance suited to the needs of each group of displaced persons. New
resettlement sites built for displaced persons must offer improved
living conditions. The displaced persons’ preferences with respect to
relocating in pre-existing communities and groups will be taken into
consideration. Existing social and cultural institutions of the displaced
persons 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 or
higher 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. Cash
compensation levels should be sufficient to replace the lost land and
other assets at full replacement cost in local markets.
22.
In the case of physically displaced persons under paragraph 17 (iii), the
client will offer them a choice of options for adequate housing with
security of tenure so that they can resettle legally without having to
face the risk of forced eviction. Where these displaced persons own and
occupy structures, the client will compensate them for the loss of assets
other than land, such as dwellings and other improvements to the land,
at full replacement cost, provided that these persons have been
occupying the project area prior to the cut-off date for eligibility. Based
on consultation with such displaced persons, the client will provide
relocation assistance sufficient for them to restore their standard of
living at an adequate alternative site.
23.
The client is not required to compensate or assist those who encroach
on the project area after the cut-off date for eligibility, provided the cutoff date has been clearly established and made public.
24.
Forced evictions will not be carried out except in accordance with law
and the requirements of this Performance Standard.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PARTIALLY COMPLIANT
The Inventory of Areas of High Conservation Value consulted the
community nearby the farms to identify common use of the biodiversity
areas. This study did not aim to identify economic displacement but it
identified that there aren’t areas of common use or essential to the
community on ELDORADO’s farms.
This study did not include the areas at 2 Irmãos do Buruti and Anastácio
municipalities
The PTEAS includes the identification of use of roads by neighbors, access to
water resources, closeness to neighbors, schools, churches, households, etc,
which could identify economic displacement. As reported above, this
procedure is dated December 2011 and it was not performed in farms in
which planting was carried out before this date.
Reportedly, no economic displacement has been carried out by ELDORADO.
Provide adequate training for social and communication experts to identify
economic displacement and to develop adequate measures to avoid or
mitigate it, according to this performance standard, including if the families
remaining at the leased land are to be economic impacted by the project.
25.
In the case of projects involving economic displacement only, the client PS 5, paragraph 25 to 29
will develop a Livelihood Restoration Plan to compensate affected
persons and/or communities and offer other assistance that meets the
objectives of this Performance Standard. The Livelihood Restoration
Plan will establish the entitlements of affected persons and/or
communities and will ensure that these are provided in a transparent,
consistent, and equitable manner. The mitigation of economic
displacement will be considered complete when affected persons or
communities have received compensation and other assistance
according to the requirements of the Livelihood Restoration Plan and
this Performance Standard, and are deemed to have been provided
with adequate opportunity to re-establish their livelihoods.
Carry out the PTEAS in all farms before intervention is made. For areas in
which intervention was made and no PTEAS was carried out, p.e those
located at Dois Irmaos do Buruti and Anastacio, ELDORADO must define
measures to identify economic displacement.
The item is rated partial because PTEAS was not undertaken in all farms yet.
26.
If land acquisition or restrictions on land use result in economic
displacement defined as loss of assets and/or means of livelihood,
regardless of whether or not the affected people are physically
displaced, the client will meet the requirements in paragraphs 27–29
below, as applicable.
27.
Economically displaced persons who face loss of assets or access to
assets will be compensated for such loss at full replacement cost.
 In cases where land acquisition or restrictions on land use affect
commercial structures, affected business owners will be
compensated for the cost of re-establishing commercial activities
elsewhere, for lost net income during the period of transition, and
for 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 which
are recognized or recognizable under national law (see paragraph
17 (i) and (ii)), replacement property (e.g., agricultural or
commercial sites) of equal or greater value will be provided, or,
where appropriate, cash compensation at full replacement cost.
 Economically displaced persons who are without legally
recognizable claims to land (see paragraph 17 (iii)) will be
compensated 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 or
assist opportunistic settlers who encroach on the project area after
the cut-off date for eligibility.
28.
In addition to compensation for lost assets, if any, as required under
paragraph 27, economically displaced persons whose livelihoods or
income levels are adversely affected will also be provided
opportunities to improve, or at least restore, their means of incomeearning capacity, production levels, and standards of living:
 For persons whose livelihoods are land-based, replacement land
that has a combination of productive potential, locational
advantages, and other factors at least equivalent to that being lost
should be offered as a matter of priority.
Refer to PS5 paragraph 25
None
No:


29.
Related PS
Requirements, EHS
Guidelines (General
Standards
NOT APPLICABLE
For persons whose livelihoods are natural resource-based and
where project-related restrictions on access envisaged in paragraph
5 apply, implementation of measures will be made to either allow
continued access to affected resources or provide access to
alternative resources with equivalent livelihood-earning potential
and accessibility. Where appropriate, benefits and compensation
associated with natural resource usage may be collective in nature
rather than directly oriented towards individuals or households.
If circumstances prevent the client from providing land or similar
resources as described above, alternative income earning
opportunities may be provided, such as credit facilities, training,
cash, or employment opportunities. Cash compensation alone,
however, is frequently insufficient to restore livelihoods.
Transitional support should be provided as necessary to all
economically displaced persons, based on a reasonable estimate of the
time required to restore their income-earning capacity, production
levels, and standards of living.
Private Sector Responsibilities Under Government-Managed Resettlement
30.
Where land acquisition and resettlement are the responsibility of the
outcomes that are consistent with this Performance Standard. In
active role during resettlement planning, implementation, and
monitoring, as described below.
31.
In the case of acquisition of land rights or access to land through
compulsory means or negotiated settlements involving physical
displacement, the client will identify and describe government
resettlement measures. If these measures do not meet the relevant
requirements of this Performance Standard, the client will prepare a
Supplemental Resettlement Plan that, together with the documents
relevant requirements of this Performance Standard (the General
Requirements and requirements for Physical Displacement and
Economic Displacement above). The client will need to include in its
Supplemental Resettlement Plan, at a minimum (i) identification of
affected people and impacts; (ii) a description of regulated activities,
including the entitlements of displaced persons provided under
applicable national laws and regulations; (iii) the supplemental
measures to achieve the requirements of this Performance Standard as
described in paragraphs 19–29 in a way that is permitted by the
responsible agency and implementation time schedule; and (iv) the
financial and implementation responsibilities of the client in the
execution of its Supplemental Resettlement Plan.
32.
will identify and describe the measures that the responsible
government agency plans to use to compensate Affected Communities
and persons. If these measures do not meet the relevant requirements
of this Performance Standard, the client will develop an Environmental
and Social Action Plan to complement government action. This may
include additional compensation for lost assets, and additional efforts
to restore lost livelihoods where applicable.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
General
6.
7.
The risks and impacts identification process as set out in Performance
Standard 1 should consider direct and indirect project-related impacts
on biodiversity and ecosystem services and identify any significant
residual impacts. This process will consider relevant threats to
biodiversity and ecosystem services, especially focusing on habitat loss,
degradation and fragmentation, invasive alien species,
overexploitation, hydrological changes, nutrient loading, and
pollution. It will also take into account the differing values attached to
biodiversity and ecosystem services by Affected Communities and,
where appropriate, other stakeholders. Where paragraphs 13–19 are
applicable, the client should consider project-related impacts across the
potentially affected landscape or seascape.
PS 6, paragraphs 6 and 7 PARTIALLY COMPLIANT
EHS Guidelines for
Forest Harvesting
ELDORADO has performed several studies that addresses impacts on
Operations
biodiversity, such as:
ELDORADO should ensure that studies to be undertaken in High
Conservation Value Areas include quantitative and representative sampling
of animal and vegetation communities, and make integrated assessment of
all components of the biota (analyzing the communities) and then integrate
the physical and biotic aspects. This study should also evaluate impacts due
to change of use and isolation of the remaining naturals inside the
cultivation of eucalyptus; and the restriction of movement of animals from
the Cerrado biome to the forest plantation.
 General environmental aspects and impacts have been assessed and are
documented in a report provided by ELDORADO entitled Environmental
Impacts (Impactos Ambientais). This assessment was developed by Poyry
Silviconsult in order to evaluate the impacts associated with the forest
The risks and impacts identification studies should include the scoping for
activities.
ecosystems services, at least in a qualitative way.
 A document named Forest Management Plan has been provided and it
includes monitoring activities in order to check if the impacts are being
mitigated and minimized.
 Two studies performed by “Casa da Floresta” on January of 2012 to
identify the areas with high conservation value inside its properties. These
studies are: “Selection of areas of high conservation value and planning of
environmental monitoring”, which identifies and classifies areas of High
Conservation 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-cultural
importance and / or essential social functions in the regions of work
development of the Eldorado Brazil, Mato Grosso do Sul”.
 A third study is being carried out aiming to perform a biodiversity
inventory in the areas identified as high conservation value and perform
fauna and flora monitoring.
 A study called PTEAS – Economic, Environmental and Social Technical
Project (Projeto Técnico Econômico, Ambiental e Social) is an internal
procedure that evaluates the economic, environmental and social aspects
of the land before major interferences (cultivation or harvesting). This
study was performed in some farms and it will be applied to all farms that
will have activities, such as planting or harvesting. .
As a matter of priority, the client should seek to avoid impacts on
biodiversity and ecosystem services. When avoidance of impacts is not
possible, measures to minimize impacts and restore biodiversity and
ecosystem services should be implemented. Given the complexity in
predicting project impacts on biodiversity and ecosystem services over
the long term, the client should adopt a practice of adaptive
management in which the implementation of mitigation and
management measures are responsive to changing conditions and the
results of monitoring throughout the project’s lifecycle.
The available environmental studies do not include quantitative and
representative sampling of animal and vegetation communities, neither
make integrated assessment of all components of the biota (analyzing the
communities) and then integrate the physical and biotic aspects. Also, it
was not reported impacts due to change of use and isolation of the
remaining naturals inside the cultivation of eucalyptus; and the restriction
of 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 retain
competent professionals to assist in conducting the risks and impacts
identification process. Where paragraphs 16–19 are applicable, the
client should retain external experts with appropriate regional
experience to assist in the development of a mitigation hierarchy that
complies with this Performance Standard and to verify the
implementation of those measures.
See PS6, paragraphs 13- See PS6, paragraphs 13-15
15
EHS Guidelines for
Forest Harvesting
Operations
If ELDORADO decides to plant eucalyptus in the Pantanal biome, it should
be checked with the environmental agency if biodiversity offsets are
required.
9.
Habitat is defined as a terrestrial, freshwater, or marine geographical
unit or airway that supports assemblages of living organisms and their
interactions with the non-living environment. For the purposes of
implementation of this Performance Standard, habitats are divided into
modified, natural, and critical. Critical habitats are a subset of modified
COMPLIANT
As mentioned in PS 6 Paragraph 6 to 7, ELDORADO has land use
management guidelines prioritize the use of pasture lands and avoid the use
of areas with native forests or legally protected areas. In addition, forestry is
No:
10.
For the protection and conservation of biodiversity, the mitigation
hierarchy includes biodiversity offsets, which may be considered only
after appropriate avoidance, minimization, and restoration measures
have been applied. A biodiversity offset should be designed and
implemented to achieve measurable conservation outcomes that can
reasonably be expected to result in no net loss and preferably a net gain
of biodiversity; however, a net gain is required in critical habitats. The
design of a biodiversity offset must adhere to the “like-for-like or
better” principle and must be carried out in alignment with best
available information and current practices. When a client is
considering the development of an offset as part of the mitigation
strategy, external experts with knowledge in offset design and
implementation must be involved.
Related PS
Requirements, EHS
Guidelines (General
Standards
or natural habitats.
not subjected to environmental licensing process in the State of Mato Grosso
do Sul inside the Cerrado Biome. These conditions results in a situation that
ELDORADO is not legally obligated to perform biodiversity offsets in the
active forest plantations.
ELDORADO has one farm located in the Pantanal biome. Based on
ELDORADO´s information and also satellite images from Google Earth dated
from 2010, there is no evidences that there are forestry activities inside the
Mutum Piuva Farm. ELDORADO has informed that there is no intention to
develop forestry in this farm; however, if it occurs, this development must be
preceded by an environmental licensing process.
Modified Habitat
11.
Modified habitats are areas that may contain a large proportion of
plant and/or animal species of non-native origin, and/or where
12
human activity has substantially modified an area’s primary ecological Forestry Code art. 20
functions and species composition. Modified habitats may include
areas managed for agriculture, forest plantations, reclaimed coastal
zones, and reclaimed wetlands.
12.
This Performance Standard applies to those areas of modified habitat
that include significant biodiversity value, as determined by the risks
and impacts identification process required in Performance Standard 1.
The client should minimize impacts on such biodiversity and
implement mitigation measures as appropriate.
COMPLIANT
Land use management:
 The land use conversion inside the ELDORADO’s properties was
reportedly to be mostly from pasture to forest plantation. ERM did not
find evidences during the site visits that ELDORADO is converting native
forests into forest plantation.
 ELDORADO has set clear guidelines to not use Protected Permanent
Areas (PPA) or Legal Reserve areas to develop forestry activities.
 ERM observed the implementation appropriate techniques for erosion
control (e.g. stacking of brush and slashes).
None
The management of the modified habitats (forest plantation) is presented at
PS 3 paragraphs 4 and 5.
Natural Habitat
13.
Natural habitats are areas composed of viable assemblages of plant
and/or animal species of largely native origin, and/or where human
activity has not essentially modified an area’s primary ecological
functions and species composition.
14.
The client will not significantly convert or degrade natural habitats,
unless all of the following are demonstrated:
development of the project on modified habitat;
 Consultation has established the views of stakeholders, including
Affected Communities, with respect to the extent of conversion and
degradation; and
 Any conversion or degradation is mitigated according to the
mitigation hierarchy.
15.
In areas of natural habitat, mitigation measures will be designed to
achieve no net loss of biodiversity where feasible. Appropriate actions
include:
 Avoiding impacts on biodiversity through the identification and
protection of set-asides;
 Implementing measures to minimize habitat fragmentation, such as
biological corridors;
 Restoring habitats during operations and/or after operations; and
 Implementing biodiversity offsets.
PS 6, paragraphs 8, 13,
14 and 15
PARTIALLY COMPLIANT
According to site visit and information provided by ELDORADO, legally
protected areas (Permanent preservation areas and Legal Reserves) as well as
endemic or endangered species are maintained and preserved inside the
visited properties.
There are three main actions that ELDORADO could take in order to
improve the management of natural resources:
PARTIALLY COMPLIANT
After the conclusion of the third study ELDORADO should consolidate the
improvement actions to be performed in these areas in a Biodiversity Action
1 – Try, when possible, to connect the Legal Reserves with Protected
Permanent Areas (PPAs) in order to enhance the ecological function of these
areas, provide habitat corridors and promote the conservation of rare,
The land use management guidelines (PS6 paragraphs 6 and 7) are being also threatened or endangered species.
applied to leased lands, partnership agreements and wood suppliers to
guarantee that natural habits are not being converted to forest plantation in
2 – Implement a Native Forest Management System in isolated Legal
third-party farms. This requirement is imposed by contract.
Reserves in order to enhance their ecological function when other
alternatives are not possible (e.g. connection with PPAs)
ERM observed that some of the legal reserve areas are isolated and
surrounded by forest plantation or are not connected with permanent
3 – Extend the PTEAS to cover every major intervention inside
protected areas (PPA) around the riparian zones. This isolation may interfere ELDORADO’s properties.
with the ecological function of these areas. However, this land configuration
was mostly inherited from previous ownership.
Critical Habitat
16.
Critical habitats are areas with high biodiversity value, including (i)
habitat of significant importance to Critically Endangered and/or
PS 6, paragraphs 8, 16,
No:
Endangered species; (ii) habitat of significant importance to endemic
and/or restricted-range species; (iii) habitat supporting globally
significant concentrations of migratory species and/or congregatory
species; (iv) highly threatened and/or unique ecosystems; and/or (v)
areas associated with key evolutionary processes.
17.
Related PS
Requirements, EHS
Guidelines (General
Standards
17, 18 and 19
In areas of critical habitat, the client will not implement any project
activities unless all of the following are demonstrated:
development of the project on modified or natural habitats that are
not critical;
 The project does not lead to measurable adverse impacts on those
biodiversity values for which the critical habitat was designated,
and on the ecological processes supporting those biodiversity
values;


ELDORADO presented two studies performed by “Casa da Floresta” on
January of 2012 to identify the areas with high conservation value inside its
properties. These studies are:
 “Selection of areas of high conservation value and planning of
environmental monitoring”. This study identifies and classifies areas of
High 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-cultural
importance and / or essential social functions in the regions of work
development of the Eldorado Brazil, Mato Grosso do Sul”.
A third study is being carried out aiming to perform a biodiversity inventory
in the areas identified as high conservation value and perform fauna and
flora monitoring.
Plan, in order to guarantee net gains of biodiversity values.
COMPLIANT
A 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 done
by the Environmental Agency. It means that there is not yet any instruction
or regulation on what type of use is allowed inside the EPA. Therefore, due
to the small overlay between these areas and the lack of proper zoning, it
does not configure a land use conflict.
As described in PS 6 paragraphs 13 to 15, The land use management
guidelines (PS6 paragraphs 6 and 7) are being also applied to leased lands,
partnership agreements and wood suppliers to guarantee legally protected
areas are being adequately maintained and preserved.
Reportedly 13% of all legal reserves are submitted and recognized by the
environmental agency, 53% has been submitted to the environmental agency
for approval and 34% has signed term of commitment for proof of legal
reserve within two years.
ELDORADO is not actively managing the lands to bring the PPA and the
Legal reserve back into their natural state, based on a report that concludes
that in Cerrado biome is better to leave them for natural reforestation.
In addition, ELDORADO should implement or enhance the following
procedures:
The project does not lead to a net reduction in the global and/or
national/regional population of any Critically Endangered or
Endangered species over a reasonable period of time; and
A robust, appropriately designed, and long-term biodiversity
monitoring and evaluation program is integrated into the client’s
management program.
18.
In such cases where a client is able to meet the requirements defined in
paragraph 17, the project’s mitigation strategy will be described in a
Biodiversity Action Plan and will be designed to achieve net gains of
those biodiversity values for which the critical habitat was designated.
19.
In instances where biodiversity offsets are proposed as part of the
mitigation strategy, the client must demonstrate through an assessment
that the project’s significant residual impacts on biodiversity will be
adequately mitigated to meet the requirements of paragraph 17.
Legally Protected and Internationally Recognized Areas
20.
In circumstances where a proposed project is located within a legally
protected area or an internationally recognized area, the client will
meet the requirements of paragraphs 13 through 19 of this Performance
Standard, as applicable. In addition, the client will:
 Demonstrate that the proposed development in such areas is legally
permitted;
 Act in a manner consistent with any government recognized
management plans for such areas;
 Consult protected area sponsors and managers, Affected
Communities, Indigenous Peoples and other stakeholders on the
proposed project, as appropriate; and
enhance the conservation aims and effective management of the
area.
PS 6, paragraph 20
September 15th, 1965
and amendments (Forest
Code)
amendments
Conama Resolution nº
369, March 28th, 2006
April 27th,1981
Federal Decree nº 99.274,
June 6th, 1990
• Establish monitoring and audit system to guarantee that legal reserves
and PPAs are being protected. This should be performed periodically.
• Implement a follow up system in order to check if the use of third-party
farms and wood suppliers are in compliance with the ELDORADO land use
management guidelines and applicable environmental legislations (e.g.
Forest Code). It includes the status of ongoing requests for legal reserves
approval.
Natural regeneration of the bioma Cerrado can occur once there is a near
sources of propagules (other Cerrado areas surrounding) and since the
operator favors the natural regeneration it should ensure disturbing factors
(eg fire, opening trails, movement of domesticated animals like cattle and
horses) are minimized or eliminated.
ELDORADO should monitor if natural regeneration occurs, and prepare a
recovery plan, if necessary.
Finally, ELDORADO must follow the development of zoning regulation
related to the Piraputanga Park Road, which may affect how the land is used
in two of their properties.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
Invasive Alien Species
21.
22.
23.
Intentional or accidental introduction of alien, or non-native, species of
flora and fauna into areas where they are not normally found can be a
significant threat to biodiversity, since some alien species can become
invasive, spreading rapidly and out-competing native species.
and 23
March 24th, 2005
Federal Decree nº 5591,
The client will not intentionally introduce any new alien species (not
currently established in the country or region of the project) unless this November, 22nd, 2005
is carried out in accordance with the existing regulatory framework for EHS Guidelines for
such introduction. Notwithstanding the above, the client will not
Forest Harvesting
deliberately introduce any alien species with a high risk of invasive
Operations
behavior regardless of whether such introductions are permitted under
the existing regulatory framework. All introductions of alien species
will be subject to a risk assessment (as part of the client’s
environmental and social risks and impacts identification process) to
determine the potential for invasive behavior. The client will
implement measures to avoid the potential for accidental or
unintended introductions including the transportation of substrates
and vectors (such as soil, ballast, and plant materials) that may harbor
alien species.
COMPLIANT
ERM was informed during site visit that eucalyptus to be cultivated in leased
or owned lands are cloned. Reportedly, these types of cloning are commercial
types, registered and not GMO – genetically modified organism. As reported
the eucalyptus species used for forestry do not spread into surrounded areas.
Procedures and Forest Management Plan do show that preservation and
legally protected areas are being preserved and maintained and during site
visit it was not noticed the spread of eucalyptus in other areas besides the
cultivation farms.
Where alien species are already established in the country or region of
the proposed project, the client will exercise diligence in not spreading
them into areas in which they have not already been established. As
practicable, the client should take measures to eradicate such species
from the natural habitats over which they have management control.
Management of Ecosystem Services
24.
Where a project is likely to adversely impact ecosystem services, as
determined by the risks and impacts identification process, the client
will conduct a systematic review to identify priority ecosystem
services. Priority ecosystem services are two-fold: (i) those services on
which 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 for
its operations (e.g., water). When Affected Communities are likely to
be impacted, they should participate in the determination of priority
ecosystem services in accordance with the stakeholder engagement
process as defined in Performance Standard 1.
25.
With respect to impacts on priority ecosystem services of relevance to
Affected Communities and where the client has direct management
control or significant influence over such ecosystem services, adverse
impacts should be avoided. If these impacts are unavoidable, the client
will minimize them and implement mitigation measures that aim to
maintain the value and functionality of priority services. With respect
to impacts on priority ecosystem services on which the project
depends, clients should minimize impacts on ecosystem services and
implement measures that increase resource efficiency of their
operations, as described in Performance Standard 3. Additional
provisions for ecosystem services are included in Performance
Standards 4, 5, 7, and 8.
25
EHS Guidelines for
Forest Harvesting
Operations
Considerations regarding the analysis of impacts on ecosystem services are
presented on PS 6 paragraphs 6 and 7.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
Sustainable Management of Living Natural Resources
26.
Clients who are engaged in the primary production of living natural
resources, including natural and plantation forestry, agriculture,
animal husbandry, aquaculture, and fisheries, will be subject to the
requirements of paragraphs 26 through 30, in addition to the rest of
this Performance Standard. Where feasible, the client will locate landbased agribusiness and forestry projects on unforested land or land
already converted. Clients who are engaged in such industries will
manage living natural resources in a sustainable manner, through the
application of industry-specific good management practices and
available technologies. Where such primary production practices are
codified in globally, regionally, or nationally recognized standards, the
client will implement sustainable management practices to one or more
relevant and credible standards as demonstrated by independent
verification or certification.
27.
Credible globally, regionally, or nationally recognized standards for
sustainable management of living natural resources are those which (i)
are objective and achievable; (ii) are founded on a multi-stakeholder
consultative process; (iii) encourage step-wise and continual
improvements; and (iv) provide for independent verification or
certification through appropriate accredited bodies for such standards.
28.
Where relevant and credible standard(s) exist, but the client has not yet
obtained independent verification or certification to such standard(s),
the client will conduct a pre-assessment of its conformity to the
applicable standard(s) and take actions to achieve such verification or
certification over an appropriate period of time.
29.
In the absence of a relevant and credible global, regional, or national
standard for the particular living natural resource in the country
concerned, the client will:
 Commit to applying good international industry operating
principles, management practices, and technologies; and
 Actively engage and support the development of a national
standard, where relevant, including studies that contribute to the
definition and demonstration of sustainable practices.
COMPLIANT
Reportedly the company is starting the process to have a FSC (Forest
Stewardship Council) certification. This process requires an assessment of
potential impacts. The company intends to certify the forest management and
the wood custody chain in parts.
Eldorado already started to prepare the forest management certification; they
realized trainings, formed working groups, elaborated and executed an
action plan, hired the certification company and received their technical visit.
The pre-certification audit to the wood process is planned to April/2012 and
the certification audit to August/2012. After that, the company will start the
process to certify the custody chain. This second certification process goes
from September/2012 to November/2012, when the custody chain
certification audit is planned to occur. For more information regarding the
certification process refer to chapter 3, item 3.5 of the report.
Supply Chain
30.
Where a client is purchasing primary production (especially but not
exclusively food and fiber commodities) that is known to be produced
in regions where there is a risk of significant conversion of natural
and/or critical habitats, systems and verification practices will be
adopted as part of the client’s ESMS to evaluate its primary
suppliers.21 The systems and verification practices will (i) identify
where 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 that
they are not contributing to significant conversion of natural and/or
critical habitats (this may be demonstrated by delivery of certified
product, or progress towards verification or certification under a
credible scheme in certain commodities and/or locations); and (iv)
where possible, require actions to shift the client’s primary supply
chain over time to suppliers that can demonstrate that they are not
significantly adversely impacting these areas. The ability of the client to
fully address these risks will depend upon the client’s level of
management control or influence over its primary suppliers.
COMPLIANT
None
According to information provided during site visits and documentation of
wood supplier, the company has control over the supply chain and also gives
support, whenever necessary, in order to provide documentation to testify
compliance with legal standards.
Reportedly, some suppliers, such as DURAFLOR, that will be used by
ELDORADO have FSC certification.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
PARTIALLY COMPLIANT
Archeological survey has been conducted in December 2011, and identified
that there was no indigenous groups or traditional people affected by
ELDORADO’s operation. The study was undertaken on 7 municipalities
were 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 of
Brasilândia names Ofayé-Xavante, municipality in which ELDORADO does
not operate. ELDORADO reported that this indigenous land is 96 km away
from ELDORADO industrial site and 92 km away from farms operated by
ELDORADO 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. The
study was undertaken by the previous land owner and identified 7
indigenous communities in the region, none of them at ELDORADO’s land.
The study lacks to identify impacts of the operation on indigenous and
traditional people.
Identify the influence of the operation at Dois Irmãos do Buruti and
Anastácio municipalities over indigenous or traditional people at PTEAS.
General
Avoidance of Adverse Impacts
8.
The client will identify, through an environmental and social risks and PS7, paragraph 8
impacts assessment process, all communities of Indigenous Peoples
within the project area of influence who may be affected by the project,
as well as the nature and degree of the expected direct and indirect
economic, social, cultural (including cultural heritage), and
environmental impacts on them.
In case impact on indigenous or traditional people is identified, ELDORADO
must develop an Action Plan to minimize, restore, and/or compensate for
these impacts in a culturally appropriate manner commensurate with the
nature and scale of such impacts and the vulnerability of the Affected
Communities of Indigenous Peoples, in compliance with this performance
standard and the Brazilian legislation.
Include impacted indigenous people’s representatives, if applicable, on the
Stakeholder 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 in
indigenous land.
Jatiúca Farm is the closest farm to an indigenous land, is it is located 22 km
away from it.
The lands have eucalyptus ready to be harvested and recently planted,
maintenance is currently being performed. ELDORADO reported that
impact on indigenous and traditional people will be identified through
PTEAS that will be carried out before harvesting (between June to December
2012).
ERM visited and interviewed workers, and it was not identified indigenous
work.
9.
Adverse impacts on Affected Communities of Indigenous Peoples
PS7, paragraph 9
should be avoided where possible. Where alternatives have been
explored and adverse impacts are unavoidable, the client will
minimize, restore, and/or compensate for these impacts in a culturally
appropriate manner commensurate with the nature and scale of such
impacts and the vulnerability of the Affected Communities of
Indigenous Peoples. The client’s proposed actions will be developed
with the ICP of the Affected Communities of Indigenous Peoples and
contained in a time-bound plan, such as an Indigenous Peoples Plan,
or a broader community development plan with separate components
for Indigenous Peoples.
10.
The client will undertake an engagement process with the Affected
PS7, paragraph 10 to 12
Communities of Indigenous Peoples as required in Performance
Standard 1. This engagement process includes stakeholder analysis
and engagement planning, disclosure of information, consultation, and
participation, in a culturally appropriate manner. In addition, this
process will:
No:


Related PS
Requirements, EHS
Guidelines (General
Standards
Involve Indigenous Peoples’ representative bodies and
organizations (e.g., councils of elders or village councils), as well as
members of the Affected Communities of Indigenous Peoples; and
Provide sufficient time for Indigenous Peoples’ decision-making
processes.
11.
Affected Communities of Indigenous Peoples may be particularly
vulnerable to the loss of, alienation from or exploitation of their land
and access to natural and cultural resources. In recognition of this
vulnerability, in addition to the General Requirements of this
Performance Standard, the client will obtain the FPIC of the Affected
Communities of Indigenous Peoples in the circumstances described in
paragraphs 13–17 of this Performance Standard. FPIC applies to
project design, implementation, and expected outcomes related to
impacts affecting the communities of Indigenous Peoples. When any of
these circumstances apply, the client will engage external experts to
assist in the identification of the project risks and impacts.
12.
There is no universally accepted definition of FPIC. For the purposes
of Performance Standards 1, 7 and 8, “FPIC” has the meaning
described in this paragraph. FPIC builds on and expands the process
of ICP described in Performance Standard 1 and will be established
through good faith negotiation between the client and the Affected
Communities of Indigenous Peoples. The client will document: (i) the
mutually accepted process between the client and Affected
Communities of Indigenous Peoples, and (ii) evidence of agreement
between the parties as the outcome of the negotiations. FPIC does not
necessarily require unanimity and may be achieved even when
individuals or groups within the community explicitly disagree.
13.
Indigenous Peoples are often closely tied to their lands and related
natural resources. Frequently, these lands are traditionally owned or
under customary use. While Indigenous Peoples may not possess legal
title 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 and
community, can often be substantiated and documented.
14.
If the client proposes to locate a project on, or commercially develop
natural resources on lands traditionally owned by, or under the
customary use of, Indigenous Peoples, and adverse impacts can be
expected, the client will take the following steps:
 Document efforts to avoid and otherwise minimize the area of land
proposed for the project;
 Document efforts to avoid and otherwise minimize impacts on
natural resources and natural areas of importance to Indigenous
People;
 Identify and review all property interests and traditional resource
uses prior to purchasing or leasing land;
 Assess and document the Affected Communities of Indigenous
Peoples’ resource use without prejudicing any Indigenous Peoples’
land claim. The assessment of land and natural resource use should
be gender inclusive and specifically consider women’s role in the
management and use of these resources;
 Ensure that Affected Communities of Indigenous Peoples are
informed of their land rights under national law, including any
national law recognizing customary use rights; and
No:
Related PS
Requirements, EHS
Guidelines (General
Standards

Offer Affected Communities of Indigenous Peoples compensation
and due process in the case of commercial development of their
land and natural resources, together with culturally appropriate
sustainable development opportunities, including:
 Providing land-based compensation or compensation-in-kind
in lieu of cash compensation where feasible.
 Ensuring continued access to natural resources, identifying the
equivalent replacement resources, or, as a last option,
providing compensation and identifying alternative livelihoods
if project development results in the loss of access to and the
loss of natural resources independent of project land
acquisition.
 Ensuring fair and equitable sharing of benefits associated with
project usage of the resources where the client intends to utilize
natural resources that are central to the identity and livelihood
of Affected Communities of Indigenous People and their usage
thereof exacerbates livelihood risk.
 Providing Affected Communities of Indigenous Peoples with
access, usage, and transit on land it is developing subject to
Relocation of Indigenous Peoples from Lands and Natural Resources Subject to Traditional Ownership or Under Customary Use
15.
The client will consider feasible alternative project designs to avoid the PS7, paragraph 15
relocation of Indigenous Peoples from communally held lands and
natural resources subject to traditional ownership or under customary
use. If such relocation is unavoidable the client will not proceed with
the project unless FPIC has been obtained as described above. Any
relocation of Indigenous Peoples will be consistent with the
requirements of Performance Standard 5. Where feasible, the relocated
Indigenous Peoples should be able to return to their traditional or
customary lands, should the cause of their relocation cease to exist.
NOT APPLICABLE

As reported on PS7 paragraph 8, ELDORADO’s land are not located at
indigenous land, therefore no resettlement was undertaken.
16.
Where a project may significantly impact on critical cultural heritage
PS7, paragraph 16 and
that is essential to the identity and/or cultural, ceremonial, or spiritual 17
aspects of Indigenous Peoples lives, priority will be given to the
avoidance of such impacts. Where significant project impacts on
critical cultural heritage are unavoidable, the client will obtain the
FPIC of the Affected Communities of Indigenous Peoples.
17.
Where a project proposes to use the cultural heritage including
knowledge, innovations, or practices of Indigenous Peoples for
commercial purposes, the client will inform the Affected Communities
of Indigenous Peoples of (i) their rights under national law; (ii) the
scope and nature of the proposed commercial development; (iii) the
potential consequences of such development; and (iv) obtain their
FPIC. The client will also ensure fair and equitable sharing of benefits
from commercialization of such knowledge, innovation, or practice,
consistent with the customs and traditions of the Indigenous Peoples.
18.
The client and the Affected Communities of Indigenous Peoples will
identify mitigation measures in alignment with the mitigation
hierarchy described in Performance Standard 1 as well as
opportunities for culturally appropriate and sustainable development
benefits. The client will ensure the timely and equitable delivery of
agreed measures to the Affected Communities of Indigenous Peoples.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
19.
The determination, delivery, and distribution of compensation and
other benefit sharing measures to the Affected Communities of
Indigenous Peoples will take account of the laws, institutions, and
customs of these communities as well as their level of interaction with
mainstream society. Eligibility for compensation can either be
individually or collectively-based, or be a combination of both. Where
compensation occurs on a collective basis, mechanisms that promote
the effective delivery and distribution of compensation to all eligible
members 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 Communities
of Indigenous Peoples will determine how these communities should
benefit from the project. Identified opportunities should aim to
address the goals and preferences of the Indigenous Peoples including
improving their standard of living and livelihoods in a culturally
appropriate manner, and to foster the long-term sustainability of the
natural resources on which they depend.
21.
Where the government has a defined role in the management of
Indigenous Peoples issues in relation to the project, the client will
collaborate with the responsible government agency, to the extent
feasible and permitted by the agency, to achieve outcomes that are
consistent with the objectives of this Performance Standard. In
active role during planning, implementation, and monitoring of
activities to the extent permitted by the agency.
22.
The client will prepare a plan that, together with the documents
relevant requirements of this Performance Standard. The client may
need to include (i) the plan, implementation, and documentation of the
process of ICP and engagement and FPIC where relevant; (ii) a
description of the government-provided entitlements of affected
Indigenous Peoples; (iii) the measures proposed to bridge any gaps
between such entitlements, and the requirements of this Performance
Standard; and (iv) the financial and implementation responsibilities of
the government agency and/or the client.
PS7, paragraph 21 and
22
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
COMPLIANT
Archeological survey has been conducted in December 2011. The study has
revealed a set of 10 archaeological sites and related chipped lithic remains.
Both the inclusion of topographic sites on average slope, and the
characteristics of the lithic material allow characterizing these locations as
campsites for hunter-gatherers to prehistoric hunting activities, fishing and
gathering. This study has been submitted to the Institute for National
Historical and Artistic Heritage (IPHAN – Instituto do Patrimônio Histórico e
Artístico Nacional) and waits for the issuance of technical opinion.
Identify impact of ELDORADO’s operation on cultural heritage.
6.
In addition to complying with applicable law on the protection of

PS 8, paragraph 6
cultural heritage, including national law implementing the host
and 8
country’s obligations under the Convention Concerning the Protection Standard IPHAN
of the World Cultural and Natural Heritage, the client will identify
230/02
and protect cultural heritage by ensuring that internationally
recognized practices for the protection, field-based study, and
documentation of cultural heritage are implemented.
Monitor the archeological sites identified by the studies, and follow it
recommendation:

Develop a monitoring program in 7 archeological sites,

Develop a program of archeological prospection in 1 site,
Public disclosure information about archeological heritage
identified.

For the municipalities of Anastacio and Dois irmãos do Buruti, a social
territorial diagnosis was undertaken and identified archeological heritage
around 2 farms (Correntes e Jatiúca). This study was undertaken by the
lands previous owner (company MMX) and it identified 8 archeological sites
in the region where the lands are located, 1 one of them inside the farm
Correntes that belongs to ELDORADO. As a result, the report suggests the
development of a monitoring program in 7 archeological sites, a program of
archeological prospection in 1 site, and the disclosure of the information, as
defined by Standard IPHAN 7/88.
7.
Where the risk and identification process determines that there is a
PS 8, paragraph 7
chance of impacts to cultural heritage, the client will retain competent
professionals to assist in the identification and protection of cultural
heritage. The removal of nonreplicable cultural heritage is subject to the
additional requirements of paragraph 10 below. In the case of critical
cultural heritage, the requirements of paragraphs 13–15 will apply.
COMPLIANT
Within the archaeological study, developed by external professionals, an
impact assessment of the archaeological sites has been conducted in the
areas of reforestation of ELDORADO considered to have direct impact. In
all sites the impacts were considered negative, direct, temporary and
irreversible. Recommendations defined by this study shall be implemented
by ELDORADO.
Chance Find Procedures
8.
The client is responsible for siting and designing a project to avoid
See PS 8, paragraph 6
significant adverse impacts to cultural heritage. The environmental and
social risks and impacts identification process should determine
whether the proposed location of a project is in areas where cultural
heritage is expected to be found, either during construction or
operations. In such cases, as part of the client’s ESMS, the client will
develop provisions for managing chance finds through a chance find
procedure which will be applied in the event that cultural heritage is
subsequently discovered. The client will not disturb any chance find
further until an assessment by competent professionals is made and
actions consistent with the requirements of this Performance Standard
are identified.
No:
Related PS
Requirements, EHS
Guidelines (General
Standards
Consultation
9.
Where a project may affect cultural heritage, the client will consult with PS 8, paragraph 9
Affected Communities within the host country that use, or have used
within living memory, the cultural heritage for long-standing cultural
purposes. The client will consult with the Affected Communities to
identify cultural heritage of importance, and to incorporate into the
client’s decision-making process the views of the Affected
Communities on such cultural heritage. Consultation will also involve
the relevant national or local regulatory agencies that are entrusted
with the protection of cultural heritage.
PARTIALLY COMPLIANT
Study has been submitted to the Institute for National Historical and Artistic
Heritage (IPHAN – Instituto do Patrimônio Histórico e Artístico Nacional).
However it does not involve consultations with affected communities for the
identification purpose of the restoration of historical occupation of the
cultural heritage.
The Inventory of Areas of High Conservation Value consulted the community
nearby the farms to identify common use of the biodiversity areas. It
identified that there are not areas of common use or essential to the
community on ELDORADO’s farms.
This study did not include the areas at 2 Irmãos do Buruti and Anastácio
municipalities
Consultation is an important means of identifying it, documenting its
presence and significance, assessing potential impacts, and exploring
mitigation options. Requirements on the community engagement of Affected
Communities can be found in paragraphs 25 through 33 of Performance
Standard 1.
It was also reported that a public hearing will be carried out for the purpose
of forest certification.
Conduct the public hearing.
Identify important areas of common use or essential to the community on
ELDORADO’s farms located at Dois Irmãos do Buruti and Anastacio
municipalities.
Community Access
10.
Where the client’s project site contains cultural heritage or prevents
PS 8, paragraph 10
access to previously accessible cultural heritage sites being used by, or
that have been used by, Affected Communities within living memory
for long-standing cultural purposes, the client will, based on
consultations under paragraph 9, allow continued access to the cultural
site or will provide an alternative access route, subject to overriding
health, safety, and security considerations.
NOT APPLICABLE
According information from archeological survey presented to IPHAN (See
Annex A) the site does not prevent access to cultural heritages or previously
cultural heritage sites. Therefore this requirement is not applicable.
Removal of Replicable Cultural Heritage
11.
Where the client has encountered tangible cultural heritage that is
PS 8, paragraph 11
replicable and not critical, the client will apply mitigation measures that
favor avoidance. Where avoidance is not feasible, the client will apply a
mitigation hierarchy as follows:
 Minimize adverse impacts and implement restoration measures, in
situ, that ensure maintenance of the value and functionality of the
cultural heritage, including maintaining or restoring any ecosystem
processes needed to support it;
 Where restoration in situ is not possible, restore the functionality of
the cultural heritage, in a different location, including the ecosystem
processes needed to support it;
 The permanent removal of historical and archaeological artefacts
and structures is carried out according to the principles of
paragraphs 6 and 7 above; and
 Only where minimization of adverse impacts and restoration to
ensure maintenance of the value and functionality of the cultural
heritage are demonstrably not feasible, and where the Affected
Communities are using the tangible cultural heritage for longstanding cultural purposes, compensate for loss of that tangible
cultural heritage.
COMPLIANT
Within the archaeological study, mitigation measures, related to impacts
identified, 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
of an archaeological monitoring program. The measures suggested to be
taken immediately after the implementation of the project were: the
publication of illustrated book for the general public to the socialization of
knowledge 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 the
communities surrounding the project.
It was recommended by the archaeological survey that the following actions
be performed:
- Archaeological survey project in 10 sites located in view of scientific
relevance and susceptibility of the sites to erosion in the area of
reforestation;
- Monitoring the implementation of the project to avoid impacts on local
archaeological heritage in the area indirectly impacted by the change in soil
structure;
-Continue activities related to heritage education in the communities
surrounding the project, based on publication of a scientific communication
book about the archaeological site.
ERM recommends to expand the area of study, since there will be purchase
of wood, and partnership contracts to plant eucalyptus in other areas
beyond the areas owned by ELDORADO. Therefore these areas could
present cultural heritage that was not identified due to the limited area
previously defined in the study present to IPHAN.
No:
Related PS
Requirements, EHS
Guidelines (General and
Forest) and Legal
Standards
Removal of Non-Replicable Cultural Heritage
12.
Most cultural heritage is best protected by preservation in its place,
since removal is likely to result in irreparable damage or destruction of
the cultural heritage. The client will not remove any nonreplicable
cultural heritage, unless all of the following conditions are met:
 There are no technically or financially feasible alternatives to
removal;
 The overall benefits of the project conclusively outweigh the
anticipated cultural heritage loss from removal; and
 Any removal of cultural heritage is conducted using the best
available technique.
PS 8, paragraph 12
NOT APPLICABLE
Refer to PS 8, paragraph 11.
According information from archaeological survey presented to IPHAN, the
sites do not present non-replicable cultural heritage.
and 15
NOT APPLICABLE
According information from archeological survey presented to IPHAN
(Refer to Annex A) there is no critical cultural heritage and the project is not
inserted in legally cultural protected areas. Therefore, these requirements
are not applicable.
13.
Critical cultural heritage consists of one or both of the following types
of cultural heritage: (i) the internationally recognized heritage of
communities who use, or have used within living memory the cultural
heritage for long-standing cultural purposes; or (ii) legally protected
cultural heritage areas, including those proposed by host governments
for such designation.
14.
The client should not remove, significantly alter, or damage critical
cultural heritage. In exceptional circumstances when impacts on critical
cultural heritage are unavoidable, the client will use a process of
Informed Consultation and Participation (ICP) of the Affected
Communities as described in Performance Standard 1 and which uses a
good faith negotiation process that results in a documented outcome.
The client will retain external experts to assist in the assessment and
protection of critical cultural heritage.
15.
Legally protected cultural heritage areas are important for the
protection and conservation of cultural heritage, and additional
measures are needed for any projects that would be permitted under
the applicable national law in these areas. In circumstances where a
proposed project is located within a legally protected area or a legally
defined buffer zone, the client, in addition to the requirements for
critical cultural heritage cited in paragraph 14 above, will meet the
following requirements:
 Comply with defined national or local cultural heritage regulations
or the protected area management plans;
 Consult the protected area sponsors and managers, local
communities and other key stakeholders on the proposed project;
and
enhance the conservation aims of the protected area.
Project’s Use of Cultural Heritage
16.
Where a project proposes to use the cultural heritage, including
PS 8, paragraph 16
knowledge, innovations, or practices of local communities for
commercial purposes, the client will inform these communities of (i)
their rights under national law; (ii) the scope and nature of the
proposed commercial development; and (iii) the potential consequences
of such development. The client will not proceed with such
commercialization unless it (i) enters into a process of ICP as described
in Performance Standard 1 and which uses a good faith negotiation
process that results in a documented outcome and (ii) provides for fair
and equitable sharing of benefits from commercialization of such
knowledge, innovation, or practice, consistent with their customs and
traditions.
NOT APPLICABLE
The scope and nature of the proposed project does not involve the use of
cultural heritage, therefore this requirement is not applicable.
Annex E
Gap Analysis Table –
Logistics project
Review against IFC Performance Standard 1 (Environmental and Social Management and Evaluation Systems)
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports,
Harbors and
Terminals) and
Legal Standards
Environmental and Social
Assessment and Management
System
Paragraphs 5 – 6 and 13 The Simplified Environmental Report – RAS for the intermodal terminal in Aparecida do Taboadoto 16
MS was developed by a third party company providing environmental and social impact
assessment. Also, an Environmental Basic Plan- PBA was presented with environmental programs
foreseen for the same multimodal terminal in order to describe mitigation and performance
improvement measures and actions that address the identified environmental and social risks and
impacts of the project.
ALL – America Latina Logística, will be responsible for the transport from Aparecida do Taboado
until the Port of Santos, and a railway brunch will have to be built. All the licensing process for this
railway brunch will be conducted and managed by ELDORADO.
Regarding the company EGTM Navegação (Torque) hired by Eldorado Brazil to work in logistics
waterways of cellulose, it was reported that the Service Agreement signed by the parties on
December 22, 2011, has an item referring that EGTM Navegação (Torque) agrees to observe and
comply with environmental legislation, being responsible for fines and notices of violation of
activities directly related to the transportation of cellulose, as well as for obtaining and maintaining
any 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 product
from 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 fines
and notices of violation of activities directly related to the transport of cellulose. It was reported that
MRS will also be responsible for the construction of a new railway branch in Santos in order to
unload the products in the area leased from Hipercon as well as for obtaining and maintaining any
permits 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.
ELDORADO should consider the risk of being co-responsible by third parties’ actions or omissions by
knowingly 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 to
social 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 Stakeholder
Engagement; and
(iv) Dissemination of information on the Action Plan through internal reports for management of the
organization and external stakeholders, including affected communities.
Identification of Risks and
Impacts
PS 1, paragraphs 7 to
12
The Simplified Environmental Report – RAS for the multimodal terminal in Aparecida do TaboadoMS was developed by a third party company, comprising environmental and social impact
assessment. The report does not cover risks and impacts for all phases of the project including
deactivation of the terminal. It should also consider the emissions of greenhouse gases and potential
transboundary 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 assessment
considering risks of the modals and Net Present Value was performed. Reportedly, less impacts on
the transport system was considered.
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 and
potential 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 of
the 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 likely
to be affected by such risks and impacts. It should also include the emissions of greenhouse gases, the
relevant risks associated with climate change, adaptation opportunities, and potential transboundary
effects, 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 the
incremental impact of the project when added to other existing, planned and reasonably predictable
future projects and developments. For example it could be assessed cumulative impacts related
expansion of the existing terminal in Pederneiras since it already has operations. There should be
pointed out the other existing facilities and which will be the cumulative impacts of the inclusion of
ELDORADO’s entrepreneurship.
Organizational Capacity and
Competency
19
Specific personnel have been assigned for development of RAS of the multimodal terminal in
Aparecida do Taboado-MS. PBA shows responsibilities for implementation of environmental and
social programs regarding this multimodal terminal.
However, no information has been provided regarding roles and responsibilities for the other
logistic areas within the environmental and social aspects of the project.
The company should establish, maintain, and strengthen, as applicable, an organizational structure
that defines roles, responsibilities and authority to implement the Environmental and Social
Management System (ESMS).
Develop training program to support the designated personnel to carry out their role in the ESMS. The
training program shall ensure consistence with ELDORADO’s policies and procedures. The training
can be formal, informal (on-the-job), one-time, periodic, etc., as convenient to the company; however,
training registers should be kept.
ELDORADO should establish a formal environmental and social policy with specific performance
objectives for the project and that must be disclosed to all employees and contractors involved in the
various phases of the project.
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports,
Harbors and
Terminals) and
Legal Standards
Emergency Preparedness and
Response
PS 1, paragraphs 20, 21 ELDORADO has not yet developed an emergency preparedness and response plan for the logistics The Company should keep detailed information about the storage and transportation of hazardous
project.
materials in its area and terminals leased to fulfill the oversight role, in order to ensure compliance
PS4, paragraph 11
with relevant legislation and develop an accurate and feasible emergency preparedness and response
plan.
Particularly in the port of Santos, the company must align its Emergency Control Plan (PCE) with the
Emergency Control Plan (PCE) from CODESP. In addition, ELDORADO’s PCE must be compatible
with the PCEs from all port facilities and CODESP’s in a Mutual Aid Plan (PAM) feasible for the entire
port 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 governmental
authorities with responsibility on emergency situations, e.g, local police, hospitals, fire department,
etc. in all multimodal terminal ports (Aparecida do Taboado, Pederneiras and Santos).
24
ELDORADO has not yet developed procedures to monitor and measure the effectiveness of the
management programs.
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 for
further recommendations).
Identify any potential group that may be differentially or disproportionately affected by the project
and implement differentiated measures so that adverse impacts do not fall disproportionately on them
and they are not disadvantaged in sharing development benefits and opportunities. If no group is
identified as vulnerable or differentially affected, prepare a formal document (a brief statement to this
fact is sufficient) to justify so.
33
The logistic process is composed by road, waterway, railway and port. Railway and waterway will
be operated by contractors that already own the lines (ALL, MRS and Torque). ELDORADO will
have the concession to operate at the port of Santos, which is managed by CODESP. ELDORADO
will have operational control on road transport.
Thus, ELDORADO should be in charge to engage communities affected by road transportation and
the terminals at Aparecida do Taboado and Pederneiras. Stakeholder engagement process at Santos
should be conducted considering the process already undertaken by CODESP.
A RAS was undertaken for environmental licensing purpose of the operation at Aparecida do
Taboado. 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 economic
diagnostic 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 the
stakeholders once logistic operations are implemented.
It is recommended that ELDORADO checks the engagement process undertaken by ALL, MRS and
CODESP, in order to identify measures that are applicable to its logistics’ project or that could be
undertaken jointly, if applicable.
ELDORADO should include stakeholders related to the logistic operations on the currently
stakeholders initiatives, systemizing the process as recommended on PS1 paragraph 26 and 27 for
Industrial and Forest operation, as described below:
Systematize the stakeholders identification and contact information, to enable evaluation and
classification 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 are
disadvantaged or vulnerable;
 Stakeholders who may be able to influence the outcome of the project because of their knowledge
about the affected communities or political influence over them;
 Legitimate stakeholders representatives, including elected officials, non-elected community
leaders, leader of informal or traditional community institutions, and elders within the affected
community;
 Stakeholders not directly affected by the project but may have the ability to influence or alter the
relationship of the client with the affected community.
If the complete impact and risk identification process that needs to be completed defines that the
community will be affected by ELDORADO, Stakeholder Engagement Plan is required. This should
include:
 engagement principles;
 objective and criteria;
 risks and impacts;
 identification, characterization and priority of stakeholders, focusing on those directly affected by
the project and vulnerable groups;
 how interaction should be formalized;
 consultation frequency;
 grievance mechanism (refer to PS1, paragraph 35);
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports,
Harbors and
Terminals) and
Legal Standards
33
 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 to
affected community.
Information about risks and impacts identified and mitigation measures shall be periodically
disclosed to affected community, at least annually, as long the specific items in the management
programs. ELDORADO may consider preparing a sustainability report on the financial,
environmental and social aspects as a way to communicate and disclose relevant information to
stakeholders.
External Communications and PS 1, paragraphs 34
Grievance Mechanisms
and 35
Reportedly, no grievance mechanism for logistic operations has been developed yet.
It is recommended to expand the grievance mechanism currently in place for industrial and forest
operations 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 by
ELDORADO;

it shall be culturally appropriate, readily accessible to all workers;

it must be defined roles and responsibilities for receiving the grievance and communication
flow;

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 to
security personnel abuses and others.
Ongoing Reporting to
Affected Communities
For licensing purpose, public hearings are not planned or being considered by the company.
Reportedly, no ongoing reporting to stakeholders is planned.
Refer to engagement process, paragraph 25 to 33 above.
PS 1, paragraph 36
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports
Harbors and
Terminals) and
Legal Standards
Working Conditions and
Management of Worker
Relationship and Protecting
the Work Force
22
Federal Decree
5.598/05 - Regulates
the employment of
measures.
Federal Decree
3.597/00 Promulgate
the 182 ILO
Convention and 190
ILO, Recommendation
and immediate action
to eliminate them,
convened in Geneva,
June 17 1999.
Federal Decree
4.134/02 Promulgate
the 138 ILO
Convention and 146
ILO, Recommendation
on minimum age for
admission to
employment.
Decree 6.481/2008 Regulates Articles 3
and 4 of the ILO
Convention 182
and immediate action
to eliminate them,
convened in Geneva,
June 17 1999.
Recommendations for further actions are based on the recommendations described for the employees
working conditions for the industrial operation, detailed below:
1. Develop a Human Resource Policy, procedures or ethical code appropriate to the ELDORADO, to be
applied for workers, contracted workers and supply chain workers. That covers:
 Working conditions: e.g physical environmental, health and safety precautions, treatment of
workers, disciplinary practices, respect to workers’ personal dignity (such as refraining from
physical 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 to
public disclosure it.
2. Take measures to prevent any harassment, including sexual harassment or psychological
mistreatment 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 the
company’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 alternatives
to retrenchment, as detailed on PS2, paragraph 15 for industrial operation.
Most of the logistics operations shall be conducted by third part contractors, as previously
described.
Reportedly, contractor’s workers and employees shall be hired locally, for which no migrant work
will be required.
At this moment, ELDORADO’s employees working for logistics operations are performing
administrative 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 working
conditions.
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 of
ELDORADO, reference 0152083).
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports
Harbors and
Terminals) and
Legal Standards
Occupational Health and
Safety
PS2, Paragraph 23
Brazilian Regulatory
Norms (NRs) related to
Health & Safety..
IFC General
and Safety (EHS)
Guidelines
IFC Environmental,
Health and Safety
Guidelines – Ports,
Harbors and Terminals
The logistics operations will comprise road, waterway, railway and port. Railway and waterway
operations will be conducted by contractors that already operate the existing lines (ALL, MRS and
Torque). ELDORADO will have the concession to operate at the port of Santos, which is managed
by 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 a
grains terminal at the area (EGTM Navegação – Torque).
The operations of the port terminals will be conducted by a hired third party company. According
to information provided, ELDORADO is currently in process of hiring the company which will
operate the port terminals (bidding process). The request for proposal includes, among other
clauses, 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.
In the construction and operation stages, ELDORADO shall guarantee that the companies
responsible for construction and operation are compliant with the Brazilian Health & Safety
requirements and IFC General Environmental, Health and Safety (EHS) Guidelines and the IFC
Environmental, Health and Safety Guidelines – Ports, Harbors and Terminals, including, among
others, the following main programs:

Occupational Risks Prevention Program (PPRA) as required by Brazilian standard NR-09, for the
industrial operations;

Workplace Environmental Conditions Program (PCMAT), as required by Brazilian standard NR
Medical Surveillance and Occupational Health Program as required by Brazilian standard NR07;

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.
Workers Engaged by Third
Parties and Supply chain
29
As previously described, most of the logistics operations shall be conducted by third part
contractors:
 Transport of cellulose through river to Pederneiras will be carried out by the company named
Torque;
 Transport of cellulose by road from Tres lagoas to Aparecida do Taboado will be carried out by
a third part company, not selected yet;
 Railyway transportation from Pederneiras to Santos will be carried out by MRS, while from
Aparecida 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 and
Torque, according to each modal; and
 Temporary transport of the cellulose from the railway to the Port of Santos’ terminal will be
carried 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 the
required warehousing space for pulp storage. At Santos, two internal railway branches will be
constructed 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 no
part shall employ slavery like and/or child labor.
Refer to PS2, paragraph 7 to 22, that recommends aspects to be covered by the Human Rights Policy
or 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 34
and 35
Take measures to guarantee that terminal expansion and railway branch are complying with labour
rights and other issues addressed by these performance standards (freedom of association and
collective bargain, non-discrimination in employment relationship, harassment, child and forced
labour). 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 code
of 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 child
or forced labour.
Identify categories of significant suppliers and contractors in the primary supply chain in high risk of
child labour and forced labor or other abuses to labour rights. Define measures to monitor significant
suppliers and contractors on employment of child labour and forced labour or to employ abuses
practices 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 the
Environmental and Social Management System.
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports,
Harbors and
Terminals) and
Legal Standards
Resource Efficiency
Federal Ordinance
2914/2011, which
establishes the
drinking water
standards in Brazil.
ELDORADO’s logistics operation is still in the detailing study stage.
However, the process envisioned by ELDORADO will apply techniques to improve efficiency of
the pulp transport, such as the partial transport through water way (Paraná-Tietê hydro-way) and
railway. The process is designed to minimize the transport by trucks, thus allowing the reduction of
fossil fuel use.
When fully operational, the use of automated pulp loading and unloading will also minimize the
use of fossil fuel.
ELDORADO has not yet estimated the carbon dioxide emission equivalents for the project. As
informed, this estimate is currently being developed, in spite of not being required by the Brazilian
regulations.
The logistics operations are not associated with high water consumption. The main water use will
be associated with human consumption. According to information provided by ELDORADO, no
maintenance 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 complying
with the drinking water standards established by Brazilian regulations. However, ELDORADO is
responsible 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 be
responsibility of EGTM – Torque and in Aparecida do Taboado of ELDORADO.
When estimating the emission of carbon dioxide equivalents for the project, ELDORADO should
include the emissions associated with the pulp transport.
ELDORADO shall guarantee that no water contamination occurs inside its installations in Santos. In
Aparecida do Taboado and Pederneiras, ELDORADO shall guarantee that the third party companies
distribute 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 water
abstraction permit.
PS 3, paragraphs 10
and 11
IFC General
and Safety (EHS)
Guidelines
IFC Environmental,
Health and Safety
Guidelines – Ports
Harbors and Terminals
Federal IBAMA
Ordinance 85/1996,
which establishes that
all company provided
with a fleet for material
or people
transportation must
internal program for
the fleet black smoke
emission and
maintenance control.
Reportedly, the installation of the terminals by ELDORADO will not include construction and
maintenance dredging. Therefore, no dredging planning, execution or disposal of dredged material
is applicable.
Air emissions associated with the logistics operations will be restricted to the burning of fossil fuel
in vehicles. Reportedly, no other sources will be present on the terminals such as combustion
sources (boilers, kilns) or handling of hazardous materials that could be associated with VOC
emissions. In addition, ELDORADO operations will not be associated with fugitive emissions.
As reported, no maintenance activities will be conducted in the terminals operated by ELDORADO
or delegated to third party companies in Santos and Pederneiras. A maintenance workshop will be
reportedly be constructed in Aparecida do Taboado. Sanitary effluents will be generated in all
terminals. In Santos, CODESP is responsible for wastewater collection and treatment. ELDORADO
will reportedly not receive wastewater from ships, given that there are international regulations
governing this issue (Marpol).
In the other terminals, no details are available yet. Sanitary wastewater treatment, if required, will
be responsibility of EGTM-Torque in Pederneiras and ELDORADO in Aparecida do Taboado. As
for maintenance effluent, ERM was informed that an oil/water separator will be installed in
Aparecida do Taboado.
According to information provided by ELDORADO, no hazardous materials will be handled in the
terminals. In the construction stage, in Santos, the demolition will generate asbestos-containing
wastes, which are present in the form of roof-tiles in Warehouse XVIII, that will be demolished.
ELDORADO shall guarantee that the vehicles used inside the terminals are well tuned, by
monitoring black smoke emissions, according to applicable regulation. An internal maintenance plan
shall be developed.
ELDORADO will not have interference in the barges, railway and ships emissions. However, where
feasible, ELDORADO should require operators to follow national and international regulations (in
the case of ships).
As good management practice, ELDORADO should monitor the wastewater treatment and disposal
at Aparecida do Taboado and follow up with third party company at Pederneiras Terminals.
ELDORADO should develop a procedure for asbestos-containing materials (ACM) handling or
require the company hired for the demolition, if this is the case, to have a procedure in place, and
guarantee that employees are properly trained to handle ACM.
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports,
Harbors and
Terminals) and
Legal Standards
Federal CONAMA
criteria and soil quality
oriented values and
guidance for the
management of
contaminated areas.
CONAMA Resolution
430/2011, which
establishes the national
effluent discharge
standards.
State Deliberation
CECA/MS 03/1997,
standards in the State
of Mato Grosso do Sul.
As 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 the
visit to the Terminal Elmar in Santos, no potential for soil/groundwater contamination was
observed by ERM.
The São Paulo State Environmental Agency (CETESB) issued a statewide Contaminated Areas
Report that includes the contaminated Sites in the State of Sao Paulo that are registered with the
Agency. CETESB began developing this report in May 2002 and it includes only those sites where
companies have voluntarily disclosed information regarding soil/groundwater contamination. In
general, this report is updated once a year and was last updated in November, 2010. The report
does not contain details regarding contaminated areas, such as results of investigation analyses,
ERM considers that ELDORADO should request Hipercon Terminais to assess contamination in its
dates of investigation, remediation, sizes of the areas affected by contamination, etc. It only gives
area
to establish the baseline conditions, given that migration of contaminants from surrounding
information on the main contaminants and status of the Sites in terms of investigation/remediation
areas cannot be totally ruled out.
efforts.
The area located out of the organized port of Santos, operated by Hipercon Terminais, with which
ELDORADO will sign a service provision contract, is not listed in CETESB’s website as a
contaminated area. However, it is surrounded by bulk liquid terminals, which are listed as
contaminated areas (Stolthaven Santos, Ultragaz, Tequimar, etc.). ERM understands that the
operations with ELDORADO’s finished product (bleached kraft pulp) at that area will not represent
an additional potential for soil/groundwater contamination in the area. Additionally, according to
information provided by ELDORADO, Hipercon Terminais operations at the area are mostly related
to receipt and shipment of sugar. However, regardless of the product handled on behalf of
ELDORADO being a non-contaminating material, ELDORADO could be deemed co-responsible if
a contamination at the area is detected.
Wastes
PS3, paragraph 12
Brazilian Standard
NBR 10004, which
classifies the wastes
into three categories:
Class I (hazardous),
Class IIA (nonhazardous, non-inert)
and Class IIB (inerts).
Federal CONAMA
which establishes
guidelines for
collection and disposal
of spent lubricating
oils.
Federal CONAMA
which establishes
criteria for treatment
and disposal of clinical
wastes.
Reportedly, ELDORADO will not receive wastes from ships, given that there are specialized
ELDORADO shall guarantee that wastes generated both during the construction stage and operation
companies designated by CODESP to conduct this activity and give proper final disposal to the
stage will be given adequate final disposal, according to applicable regulations, at licensed facilities.
wastes.
In Santos, according to documents reviewed and information provided by ELDORADO, CODESP
is 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, CODESP
holds the required waste transfer permits for hazardous wastes generated in the port are, including
asbestos-containing wastes.
During the demolition/construction stage, potentially asbestos-containing wastes will be generated
by the removal of fiber-cement (Transite type) roof tiles in Warehouse XVIII. The final disposal to be
given will be determined by CODESP, which holds a waste transfer permit for asbestos-containing
wastes issued by the State Environmental Agency (CETESB). The final disposal given by CODESP is
compliant with the applicable regulations. ELDORADO will be financially responsible to dispose of
this waste. Other wastes, if generated, will have to be disposed of according to the applicable
regulations.
Regarding the Aparecida do Taboado and Pederneiras Terminals, no information on wastes
generation is available.
In Aparecida do Taboado, ELDORADO will be responsible for the disposal of the construction
wastes, during the construction stages. In the operation stage, ALL will be responsible for the
wastes disposal.
In Pederneiras, EGTM-Torque will be responsible for the wastes disposal, both during the
construction and the operation stages.
Related PS
Current Status
Requirements, EHS
Guidelines
(General, Ports,
Harbors and
Terminals) and
Legal Standards
Wastes
CONAMA Resolution
307/2002, which
establishes the
standards to manage
civil construction
wastes and classifies
the wastes according to
its origin.
CONAMA Resolution
348/2004, modified the
CONAMA Resolution
307/2002, and
included asbestos in
the hazardous wastes
category.
CONAMA Resolution
05/93 – establishes the
obligation to develop a
Plan for Solid Waste
Management in port
projects.
Federal Law nº
12.305/2010 National
Waste Policy regulated
by Federal Decree No.
7404/2010.
Hazardous Materials
Management
Reportedly no hazardous materials will be handled in the terminals, except for the Aparecida do
PS3, paragraph 13
Taboado terminal, where, a maintenance workshop will be operated. No details on the operations
Interministerial
to be conducted in the terminal are available.
Ordinance 124/80,
which gives directives
for the storage of
potentially polluting
materials.
Federal Regulatory
standard NR-20, which
addresses the storage
of flammable
materials.
NBR 17505, which
gives directions for the
storage of petroleum
and petroleum
products.
ELDORADO shall guarantee that hazardous materials to be used in Aparecida do Taboado will be
handled and stored according to applicable regulations.
PS 3, paragraphs 14,
15, 16 and 17
Not applicable.
No use of pesticides is estimated for the logistics project.
Community Health and
Safety
Security Personnel
Related PS Requirements,
EHS Guidelines (General,
Ports, Harbors and
Terminals) and Legal
Standards
PS4, paragraphs 5 to 11
EHS Guidelines Paper and
Pulp item 1.3
Current Status
Considering the size of the logistics projects , that no inflow of workers is planned and that most
of the activities will be performed by contractors that already operate in the area (waterway, rail
way and port), ELDORADO should be in charge to identify risks and impacts to community
health for the road transportation, the railway branch (construction and operation at Aparecida
do Taboada, Pederneiras and Santos) and terminal expansion (at Pederneiras and Santos)
Reportedly, communities impacted by the road transportation are included on the EIA and the
area impacted by industrial operation. Recommendation for the communities impacted by the
industrial operation is described on the PS4 for industrial operation (Refer to ERM Report,
Environmental and Social Assessment of Industry and Forest Projects of ELDORADO, reference
0152083).
Verify the process to identify health and safety risk and impact undertaken by ALL, MRS and
CODESP, checking upon measures that are applicable to ELDORADO or that could be
undertaken jointly, if applicable
Identify risks and impacts to community health and safety due to the road construction and
operation (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 transmitted
illness STIs and prevention of fatalities and injuries.
Provide workers performing activities at the port of Santos educational programs related to STIs.
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 in
charge of the area inside the organized Port called Terminal Elmar and 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 provide training to security personnel, neither there is a systemic
procedure to verify if those providing security are not involved in past abuses.
Verify documentation of those providing security personnel to guarantee that all workers and
companies are authorized to perform the activity, following the verification done for industrial
and 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 security
arrangements.
Define procedure about correct conduct and use of the force by security personnel. This shall
include measures to investigate and treat denounce of human right abuse committed by those
provide security.
Monitor those who provide security arrangement to identify compliance with the above
mentioned procedure.
Related PS
Requirements, EHS
Ports, Harbors and
Standards
General Requirements and PS5, paragraphs 8 to 39
Displacement
Current Status
At 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 operated
by EGTM Torque that already owns the land to operate waterway terminals. Reportedly, no
resettlement will be carried out.
Acquisition of other lands is not planned, as informed by ELDORADO.
Not applicable.
Requirements of IFC PS
6
Related PS
Requirements, EHS
Ports, Harbors and
Standards
Current Status
General
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 consider
direct and indirect project-related impacts on biodiversity and ecosystem services and identify any
significant residual impacts.
Make an integrated assessment of all components of the biota (analyzing the communities) and later
incorporate aspects of both the physical and biotic environment. Example: identify and characterize the
natural remnants of the project’s area of influence and perform a landscape analysis.
Protection and
Conservation of
Biodiversity
ELDORADO has provided a document called Technical Project for Inexistent Legal Reserve
Regularization for Boa Esperança farm in Aparecida do Taboado-MS. The report presents
environmental diagnosis of the area and the proposal to conduct recovery through natural
regeneration, improving protection measures and soil conservation, physical isolation of the
legal reserve area with the opening of clearings in the surroundings; protect the area from
hunting and predatory fishing. It was also provided the request to the state environmental
agency (IMASUL) regarding the term of commitment for recovery of the legal reserve and the
term of commitment as owner of the land submitted in November 2011.
Along with the Simplified Environmental Report – RAS of Aparecida do Taboado it was
presented the identification of Protect Areas of Cerrado and Mata Atlântica Biomes (with high
priority of conservation) inside the area of influence of the project.
Reportedly, the multimodal Terminal in Pederneiras will be managed by a third party
company which will be responsible to comply with all items related to permitting, and other
environmental legislation issues. Refer to PS1, paragraphs 5-6.
For the areas of the port terminal in Santos, the warehouses are inside already occupied areas
and therefore this item is not applicable.
With regards to Aparecida do Taboado, ELDORADO should:

Evaluate the possibility of creating a non-isolated legal reserve, trying to connect it to other
natural remnants.

Evaluate the effectiveness of the “natural regeneration” process. Depending on the characteristics
of the secondary vegetation, additional efforts should be taken to guarantee a proper recovery of
the natural vegetation.
ELDORADO should ensure the same requirements above for the third party company responsible for
operating and managing Pederneiras terminal.
Management of
Ecosystem Services
Since the logistic activities will not cause significant impacts on ecosystem services (the
selected areas do not preserve their original characteristics and are highly degraded), therefore
this requirement is not applicable.
Not applicable.
Sustainable Management
of Living Natural
Resources
Not applicable. The logistics projects is not engaged in the primary production of living
natural resources, including natural and plantation forestry, agriculture, animal husbandry,
aquaculture, and fisheries.
Not applicable.
Supply Chain
PS 6, paragraph 30
Not applicable. The client is not purchasing primary production (especially but not exclusively
food and fiber commodities) that is known to be produced in regions where there is a risk of
significant conversion of natural and/or critical habitats.
Not applicable.
September 15th, 1965 and
alterations – Establishes the
new forest code
alterations- Provides for the
National Environmental
Policy
Conama Resolution nº 369,
March 28th, 2006 - Provides
for the exceptional cases,
public utility or social
interest low environmental
impact, which enable
intervention or suppression
of vegetation in Permanent
Preservation Area-APP.
Federal Law nº 6.902, April
27th,1981- Provides for the
creation of Ecological
Stations, Environmental
Protection Areas and other
measures.
Related PS
Requirements, EHS
Ports, Harbors and
Standards
Current Status
General, Circumstances
Requiring Free, Prior, and
Informed Consent,
Mitigation and
Development Benefits,
Private Sector
Responsibilities Where
Government is
Responsible for Managing
Indigenous Peoples Issues
For Aparecida do Taboado terminal, a RAS was undertaken. Reportedly, to start the RAS
process, 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. This
information 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 are
located at this municipality or are near by the Tietê river.
Not applicable.
This PS is not applicable to the port of Santos due to the activities already develop ed at the
site. In addition, port of Santos is located within the municipality of Santos, an urban area.
Requirements of IFC PS 8 Related PS
Requirements, EHS
Ports, Harbors and
Standards
Protection of Cultural
Heritage in Project Design
Decree Law nº 25/1937 and Execution
Organizes the protection
of historical and artistic
heritage.
No evidence has been provided regarding protection of cultural heritage.
If archaeological and cultural remains are found during construction , the works must be stopped and
an expert in the field should be called for inspection. It requires training of workers so they can identify
these remains during construction. This is valid for Aparecida do Taboado and Pederneiras Terminal.
ELDORADO should identify and protect cultural heritage by ensuring that internationally recognized
practices 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 of
importance, and to incorporate into the client’s decision-making process the views of the Affected
Communities on such cultural heritage. This is valid for Aparecida do Taboado and Pederneiras
Terminal.
Law nº 3.924/1961
Provides for the
archaeological and
prehistoric sites.
As for the Port Terminal in Santos, studies should have already been performed by IPHAN since the
areas is already occupied for a long period of time. It is recommended to check this information with
the institute.
Project’s Use of Cultural
Heritage
PS 8, paragraph 16
Not applicable. The project does not proposes to use the cultural heritage, including
knowledge, innovations, or practices of local communities for commercial purposes.
Not applicable.
Annex F
Photolog
Selected Photographs (Date 2012): ELDORADO
01 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 at
Taruana Farm.
03 Resting and lunch area at Taruana Farm.
06 Interview with rural worker (contractor).
10 Mechanized Planting at Barraca Farm.
07 Bus used to transport rural workers at
Taruana Farm.
08 Workers from Taruana Farm having lunch.
11 Semi-mechanized irrigation at Barraca
Farm.
09 House from a landless movement
participant, near to Correntes I and II Farms.
12 Semi-mechanized irrigation at Barraca
Farm.
13 Accomodation Inocencia.
16 Accomodation Agua Clara.
14 Worker being interviewed at Accomodation
17 Accomodation Agua Clara.
Inocencia.
15 Room at Accomodation Inocencia.
18 Accomodation Agua Clara II.
22 Training Center at Santa Maria Farm.
19 Room without window at Accommodation
Agua Clara II.
20 Manual planting at Barra Mansa Farm.
21 Training Center at Santa Maria Farm.

Environmental and Social Assessment According to the IFC

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