Environmental and Social Action Plan for Developer Alibunar Windfarm A d.o.o. for the Alibunar A Wind Project in the Alibunar Municipality, Autonomous Province of ,

View from Seleuš

Future Views of Alibunar A

and B Wind Projects

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April 2015

Alibunar A Wind Project Environmental and Social Action Plan

WindVision Operations d.o.o. and WindVision Alibunar Windfarm A d.o.o. (individually and collectively, “WindVision”) are planning to construct and operate the Alibunar A Wind Power Plant (also known as Alibunar 1) about 50 kilometres northeast of , Serbia, in the municipality of Alibunar, Autonomous Province of Vojvodina. The Project includes about 45 kilometres of improved access and site roads, construction of 33 foundations and turbines, construction of an on‐site substation, burial of cables to convey electricity from turbines to the substation, and construction of an 11.8‐kilometer 220kV transmission line to convey electricity from the substation to the national grid. Project financing is being provided by the European Bank for Reconstruction and Development (EBRD) and the European Investment Bank (the “Lenders”). The Alibunar A project is part of a larger development that will ultimately include at least another 25 turbines upon completion of Alibunar B (also known as Alibunar 2), and possibly more in the future. WindVision will need to implement a number of actions to ensure and verify that the Project is constructed and operated in compliance with Serbian law, EBRD Performance Requirements, EIB Environmental and Social Standards, and Good International Practice (GIP). This Environmental and Social Action Plan (ESAP) defines those actions. In general, the ESAP requires compliance with the Environmental and Social Management and Monitoring Programmes (ESMMP) that are part of an Environmental and Social Impact Assessment (ESIA) and includes specific requirements for actions whose purpose is to avoid, reduce, or otherwise mitigate the most significant potential impacts. The table below constitutes the ESAP. It identifies the required actions, the basis of the requirement, the timing of the action, the criteria to be used for determining whether the required action has been successfully achieved, and information that will be reported to the Lenders. Implementation of the actions is the responsibility of WindVision. When contractors perform work under contract to WindVision or their designee(s), WindVision will be responsible for those contractors’ compliance with the requirements of the ESAP. This is expected to be accomplished by inclusion of requirements in contracts and subcontracts, and by direct oversight and supervision by WindVision and/or its designee, as needed. It is anticipated that the primary contractor will have primary responsibility for implementation of most ESAP requirements during construction, with WindVision overseeing performance. WindVision will have primary responsibility during operation. Performance of the actions required by this ESAP will be reported to the Lenders by WindVision as required by the ESAP and the financing agreements. Performance and compliance will be audited or otherwise evaluated by the Lenders throughout construction and operation of the Project. As agreed by the Lenders and WindVision, this ESAP may be revised from time to time during Project implementation, sometimes in response to evaluations conducted under the ESAP itself. No changes will be made if they could allow violations of Serbian law or of Lenders’ requirements for environmental and social performance.

Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement 0 WindVision to prepare and submit environmental and EBRD PR1 Every six months during KPI: submission of report in mutually social monitoring reports that show status of EIB Std 1 construction, at agreed format compliance with EBRD PRs, EIB E&S Standards, and commissioning, and with the requirements of this ESAP. Report to cover annually during operation WindVision and contractor activities and performance. EBRD PR1: Environmental and Social Assessment and Management EIB E&S Standard 1: Assessment and Management of E&S Impacts and Risks 1.1 Design a framework for defining the organisational EBRD PR1 Framework designed, - Organogram designed structure of WindVision and Alibunar A Project EIB Std 1 responsible person(s) - Responsible person(s) Management Team, with all key roles represented in an appointed: Within 90 days appointed/hired and on staff organogram. For construction, this is to include main of financial close, but prior ESHS reporting: contractor. Appoint and maintain person(s) to be to construction - Status of appointment(s), including responsible for environmental, social, and occupational CVs of appointed professionals health and safety (ESHS) for Alibunar A, to report directly to the project manager, and subsequently to WindVision management board. 1.2 Develop and implement an integrated management EBRD PR1 - Approve contractor - Development and implementation of system for environmental and social performance and EIB Std 1 systems: prior to the ESHS management system for occupational health and safety. System and construction throughout the project. implementation during construction should be the - Develop operations ESHS reporting: responsibility of key project contractor under system: prior to WindVision oversight; during operation, the commissioning

1 “KPI”: Key performance indicator. “Reporting” = information to be reported to the Lenders in annual environmental and social monitoring reports under item 0. Page 1 of 18

Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement responsibility of WindVision. (See also requirement 1.5 - Implement: throughout - Report to Lenders on status of below.) [Note: system(s) should generally meet during construction and system development and objectives of ISO14001 and OHSAS 18001, but need not operation implementation be certified] 1.3 Update the ESIA’s Environmental & Social Management EBRD PR1 - Develop construction - ESMMP(s) developed and in place and Monitoring Programmes (ESMMPs) incorporating EIB Std 1 ESMMP/CEMP or approve - Construction and operation in requirements of the EIAs’ ESMMPs and this ESAP for contractor plans: prior to compliance with ESMMP construction and then operation: contractor to update financial close ESHS reporting: for construction, WindVision for operation. ESMMP to - Develop operation - Report status of plan development require detailed construction environmental ESMMP & ESMPs: prior to - Report material deviations from plans management plan (CEMP) made up of associated commissioning subplans, including those specified in this ESAP. To - Implement: throughout include detailed timelines for implementation of construction and specific mitigation measures and monitoring activities. operation 1.4 WindVision (see requirement 1.1) to review and EBRD PR1 - Prior to construction - ESMMP and CEMP subplans approve ESMMP and contractor CEMP subplans, E&B Std 1 reviewed and approved by including review and approval by third‐party WindVision and competent third‐ consultancy acceptable to Lenders. party acceptable to Lenders - Plans provided to Lenders for review and no‐objection approval ESHS reporting: - Status of ESMMP and subplan review and approval 1.5 WindVision to develop and implement EBRD PR1 - Develop/adopt: prior to - Development, adoption, and Contractor/Subcontractor Management Plan to EIB Std 1 executing contracts/ implementation of contractor manage ESHS planning and performance of GIP subcontracts management system

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement

construction and other contractors, including at a - Implement: throughout ESHS reporting: minimum: execution of - Report to Lenders on development of - Inclusion of relevant ESAP requirements in contracts/subcontracts policy/procedures contracts/subcontracts - Report ESHS training(s) of - Clear assignment of WindVision and contractor ESHS contractors/subcontractors responsibilities - Report status and highlights of - Contractor reports sufficient to allow WindVision to contractor oversight include relevant data in reports to Lenders, and to allow evaluation of need for corrective actions - Verification of training and/or proper credentials for contractor staff/managers responsible for ESHS 1.6 WindVision and contractor(s) to undertake activities Serbian law Prior to undertaking any - Permits/authorizations received that require permits or consents/decisions by relevant EBRD PR1 activity that requires permit ESHS reporting authorities only after such permits and/or decisions are EIB Std 1 or authorization - Report on status of permits/ in place. Comply with all required conditions. authorizations - Report immediately any citations or fines for noncompliance, and other instances of material noncompliance 1.7 WindVision to appoint a qualified independent EBRD PR1 - Appoint: 3 months after - Consultancy approved by Lenders consultancy to audit ESHS performance against this EIB Std 1 construction start and appointed ESAP and EBRD PRs/EIB E&S Standards. Implement - Audit report: 5 months - Audits completed and reports corrective actions as needed to reach compliance. after construction start submitted to Lenders and one year after - Corrective actions implemented as commissioning and full specified by Lenders operation ESHS reporting: - Identify candidate consultancy(ies)

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - Report on status of appointment and audit - Report on status of corrective action implementation EBRD PR 2: Labour and Working Conditions EIB E&S Standards 8 & 9: Labour Standards & Occupational Health, Safety and Security 2.1. Amend WindVision Rule Book on Employment to EBRD PR2 Within 3 months of - Rule Book amended include: EIB Stds 8&9 commitment of funds or - Rule Book inspected and approved - Prohibition against child labour prior to construction by Lenders or third party acceptable - Explicit right to collective bargaining and association (whichever is first). to Lenders - Employee grievance mechanism, including availability ESHS reporting: to contract employees - Report status of HR policies and procedures - Provide summary of makeup of WindVision and contractor workforces by skill level, age, gender, geographic origin (local, other Serbian, expat), and other key variables 2.2 WindVision to require contractor(s) to adopt Rule Book EBRD PR2 Contractor adoption of Rule - Contractors’ policies and procedures on Employment or to review and approve contractor’s EIB Stds 8&9 Book or WindVision inspected and approved by HR policy: approval of contractor(s) WindVision, and by Lenders or third - Contractor policy(ies) must include ILO Core Labour policy: prior to site activities party acceptable to Lenders Standards and meet requirements of EBRD PR2 and ESHS Reporting: EIB E&S Standard 9.

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - Contractor policy(ies) must contain an enforceable - Report status of HR policies and code of conduct applicable to all workers, including in procedures particular those who are not of local origin, or contractor must have a stand‐alone code. - Contractor policy(ies) must be available to workers in their language(s). 2.3 Develop and implement occupational health and safety Serbian law Plans in place prior to - OHS plans developed, plan(s) to guide all activities on project site during site EBRD PR2 undertaking on‐site reviewed/approved, and in place preparation, construction, and operation – for site EIB Std 8 activities that would be - Safe workplace, minimal incidents preparation & construction, contractor to develop and subject to requirement. and lost time implement plan, WindVision to review/approve. Plan ESHS reporting: requirements to include, at a minimum: - Provide evidence of review and - Job‐ and task‐specific hazard analysis and controls for approval of OHS plan(s) for all project all activities contractors and subcontractors by - Provision of personal protection equipment, qualified professional requirements for use, and enforcement of use - Report on OHS matters, including - Safety training for all personnel in their language, work hours, incident statistics, and covering general hazards and safety protocols and status of training (to cover entire site those that are specific to their assigned tasks workforce) - Special training for specific hazards: working at - Report immediately (within 48 hours) heights, in excavations, with electricity in case of major accidents and/or - WV review and approval of contractor OHS plan(s), fatalities contractor review and approval of subcontractor plan(s) - Oversight of contractor OHS implementation, including mandatory reporting by contractor(s)

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - Recording incident statistics, including total work hours, lost time incidents, major injuries, fatalities, etc. 2.4 WindVision to develop and implement a grievance EBRD PR2 - Same as item 2.1 above - Adoption and implementation of procedure for all workers, including contractor EIB Std 8 - Dissemination of employee grievance procedure employees, or require contractor to have equivalent information to workers: at ESHS reporting: procedure. Include in formal HR policy, ensure all time of hiring or first work - Report to Lenders summary of workers know it is available (see requirement 2.1 grievances and resolutions (WV & above). contractors) Note: this mechanism is separate from the one for external stakeholders that is part of the Stakeholder Plan under PR/PS 10. EBRD PR 3: Pollution Prevention and Abatement EIB E&S Standard 2: Pollution Prevention and Abatement 3.1 Contractor to develop and implement construction‐ Serbian law - Develop: prior to Minimal occurrence of dust nuisance phase dust suppression plan to ensure dusty loads are EBRD PRs 3,4 construction ESHS reporting: covered while in transit and earthen/gravel roads are EIS Stds 2,9 - Implement: throughout - Report any complaints and actions wetted as needed to suppress dust. construction when taken suppression is needed 3.2 If concrete batch plant is brought on‐site, contractor to Serbian law - Develop: prior to - Emissions managed and in develop and implement emissions control plan (air and EBRD PR3 operation of plant compliance water and noise) EIB Std 2 - Implement: throughout ESHS reporting: operation - Report compliance status

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement 3.3 Contractor to develop and implement waste and Serbian law - Plan(s): prior to - Identification of wastes and hazardous materials management plans for EBRD PR3 generation of wastes and hazardous materials, development of construction, to cover all liquid and solid wastes and EIB Std 2 management of hazardous plan(s) materials (chemicals, paint, fuel, construction debris, materials - All wastes and materials managed excess spoil, domestic/household wastes, spill cleanup - Implementation: according to plan debris, etc.). All vehicles to have spill cleanup kit. throughout construction ESHS reporting: WindVision to develop and implement plan for and operation - Report on status of plan operation. development and approval by authorities (if required) - Report immediately any major releases or incidents 3.4 Contractor to prepare and implement earthen EBRD PR3, 6 - Plan: Prior to ground‐ - Adoption of plan, implementation of materials management plan, to include requirement to: EIB Std 2, 3 disturbing activities best practices, protection of topsoil - Salvage, segregate, and store in stable piles all topsoil GIP - Topsoil/subsoil salvage and stored rock and subsoil salvaged from all disturbed areas and storage: salvaged - Minimal erosion and loss of topsoil - Store rock in stable piles immediately, stored until ESHS reporting: - Protect all storage piles with covers, including used for reinstatement - Report to Lenders on plan status and vegetative cover (native grass species) as needed to - Erosion control per plan: highlights of erosion control program prevent wind/water erosion and desiccation throughout construction - Use specific best practices to prevent or retard run‐ - Reinstatement: as soon as off from piles and from disturbed areas. disturbance ends - Reinstate all disturbed areas by covering with topsoil and seeding/planting with native species, or returning to tillage. Avoid plants attractive to small mammals or insects near turbines.

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement 3.5 Contractor to develop water management plan for EBRD PR3, 4 - Plan developed: prior to - Sufficient and sustainable water construction phase, to include: EIB Std 2, 8 initial use of water from supply for all current users - Detailed assessment of water needs and potential project wells or other ESHS reporting: sources, including measures to reduce water usage sources - Status of water management plan including use of wastewater for wetting roads, - Plan implementation and - Limitations on source sustainability, use/reuse in batch plant, etc. monitoring: throughout if any, and highlights of contingency - Hydrogeologic evaluations of sustainability of water period of water use plans extraction from aquifers used by private and public - Actions taken in case changes in wells, to include monitoring nearby wells to measure water supplies or usage are needed and evaluate aquifer response to project pumping including adjustments in plans or providing other water sources during periods of excessive drawdown. - Contingency actions and sources in case any public or private well cannot or does not provide all water needs, either continuously or periodically - If applicable, curtailment of water imports from any public water system as necessary to ensure other users suffer no shortages or loss of water 3.6 If SF6 is to be used for insulation and current EBRD PR3 - Plan developed: Prior to - Plan developed and implemented if interruption in electric transmission equipment, EIB Std 2 substation commissioning SF6 to be present WindVision to develop and implement plan to manage - Plan implemented: - Minimal release of SF6 EU F‐Gas SF6 so as to minimize release to atmosphere. Plan throughout operation ESHS reporting: should be consistent with Energy Network Association Regulation - Report need for SF6 plan guidelines. - Report status of plan development - Report any major releases

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement EBRD PR 4: Community Health, Safety and Security EIB E&S Standard 9: Occupational and Public Health, Safety and Security 4.1 Contractor to develop and implement plans and Serbian law - Develop/approve plans - Plans and procedures developed, procedures to protect public health, safety and EBRD PR4 and procedures: before made available, and implemented security. Plans and procedures to include, at a EIB Std 9 construction. - Compliance with (as applicable) UN minimum: - Update plans and Basic Principles on the Use of Force - Traffic management plan (see 4.2) procedures as needed to and Firearms by Law Enforcement - Public notices of hazards associated with works and keep up to date and Officials, UN Code of Conduct for Law equipment during construction and operation (see relevant: throughout the Enforcement Officials, Voluntary ESAP requirements 10.1 and 10.2) project lifecycle. Principles on Security and Human - Emergency preparedness and response plan, Rights and the International Code of including collaboration with local responders Conduct on Private Security - Security measures to prevent unauthorised access Providers during construction and minimize access to ESHS reporting: substation and turbine interiors during operation - Report on status of plans and procedures development/approval - Report summary of incidents involving members of the public, including trespassers - Report to Lenders immediately if WindVision and/or contractors propose armed security ‐‐– report before providing arms. 4.2 Contractor to develop and implement traffic and Serbian law - Develop/approve: prior to - Plan developed in consultation with transport management plan(s) to include access, EBRD PR4 transport local authorities routing, diversions, exceptional loads, driver training, EIB Std 9

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement and signage. Plans must cover transport of turbines, - Implement: throughout - Traffic managed in compliance with rock/stone, and other materials to be brought to or equipment/materials plan removed from the site. Consult with local stakeholders transport ESHS Reporting and provide timely information to users of land of the - Report on status of plan times access to their land may be necessary, or when development/approval access may be limited. Plan to be developed in - Report summary of training and of consultation with traffic/road authorities. Supported by traffic incidents WindVision, contractor to make every effort to coordinate traffic planning with developers/contractors of Čibuk wind project, including consultations with authorities.

4.3 Beyond requirements of the environmental consent Serbian law Monitoring and controls: - Appropriate construction design to (including annual monitoring at nearest houses): EBRD PR3,4 monitor as requested and if minimise noise - During operation, WindVision to monitor noise at EIB Std 2 piles are driven, control/ - On‐demand monitoring and residences upon request and take actions to reduce GIP reduce noise as needed mitigation as needed or control noise as needed to meet applicable - Compliance with noise standards standards. ESHS reporting: - Contractor to ensure proper noise controls on - Report noise complaints, monitoring vehicles and equipment. results, and mitigation measures - When designing the substation, WindVision to use applied technology whose specifications ensure that noise standards will not be exceeded. - If piles are to be driven, contractor to conduct monitoring at nearest residences to verify noise levels are within standards and limit work to normal business hours.

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - WindVision to implement mitigation measures to reduce operation noise if levels increase 3dB or more over background (compared to 5dB cited in environmental consent). 4.4 WindVision to meet with potentially affected EBRD PR4 - Investigate: upon receipt - No shadow flicker disturbance, or households (see ESIA) annually, investigate EIB Std 9 of complaint appropriate mitigation/ reports/complaints of shadow flicker. If needed, GIP - Mitigation (turbine compensation in place develop mitigation to prevent shadow flicker shutdown at certain hours ESHS reporting: of certain days in certain - Report shadow flicker complaints weather conditions): as and actions taken needed - Compensation/mitigation: if needed and agreed by affected people 4.5 WindVision to implement actions to ensure community EBRD PR4 - Establish goals: prior to - Significant local hiring, including benefits, including: EIB Std 9 engaging contractors semi‐skilled and skilled workers - Set goals for and encourage contractors to hire local - Commission training - Training for local workers workers, with preference for those who may be program: by financial - Educational support provided directly affected by noise, traffic, or other project close - Maintenance of “social license to activities. operate” - Commission and implement a training program to ESHS reporting: upgrade skills of unskilled local workers as part of the - Report numbers of local vs non‐local social investment program. vs expatriate workers, and skill levels - Provide funding for local students’ university - Report funding provided for social education in science and/or engineering disciplines investment program, including results (e.g., ornithology, electrical engineering). such as training, education,

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - Establish a Social Investment Program that would guide annual investments to benefit the Project as well as local communities and people. EBRD PR 5: Land Acquisition, Involuntary Resettlement and Economic Displacement EIB E&S Standard 6: Involuntary Resettlement 5.1 WindVision to document and continue to implement Serbian law Replace/compensate as - No economic losses by any affected procedure used to compensate landowners and others EBRD PR5 soon as possible after person for incidental damages and losses caused by the EIB Std 6 damages or losses ESHS reporting: Project. - Report summary of damages/losses and status of replacement/ compensation EBRD PR 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources EIB E&S Standard 3: EIB Standards on Biodiversity and Ecosystems 6.1 WindVision to appoint qualified professional(s) with EBRD PR6 - Appointment of expert(s): - Expert(s) approved by Lenders and expertise in ornithology and chiropterology to assist in EIB Std 3 prior to financial close appointed implementation of requirements 6.2, 6.3, 6.4, 6.8, & 6.9. 6.2 Expert(s) appointed under 6.1 to review/revise Serbian law - Modified and approved - Methodologies modified, approved methodology for bird and bat monitoring to include the EBRD PR6 methodologies: within 60 by Institute for Nature Protection proposed transmission line corridor and the three EIB Std 3 day of financial close and/or independent third‐party valleys of conservation concern, plus the corridor to the - Monitoring program expert. pig farm pond, and to oversee implementation of the implemented: within 90 - Data collected, compiled, reported modified monitoring program, which is to continue for days of financial close - Compiled data publicly available at least three years. Also survey for Falco cherrug nests - Monitoring results: each ESHS reporting: and common roosts/hunting grounds within 2km. Bat 12 months of monitoring

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement monitoring to cover loss of habitat, mortality, - Provide evidence of Institute and/or migration, and behaviour. Make data available to expert approval of methodology Institute for Nature Protection. - Provide summary of survey results 6.3 Expert(s) appointed under 6.1 to design and oversee Serbian law - Methodology designed: - Methodology designed, approved by implementation of methodology to measure bird and EBRD PR6 prior to commissioning Institute for Nature Protection bat mortality due to collision with turbines and blades, EIB Std 3 - Implemented: at least and/or independent expert and with transmission line. Continue monitoring until three years during - Additional mitigation implemented, if expert(s) conclude risk is adequately understood and operation, until expert(s) needed acceptable, but for at least three years. recommend cessation ESHS reporting: - Provide evidence of Institute and/or expert approval of methodology - Provide summary of survey designs and results - Describe any additional mitigation 6.4 Expert(s) appointed under 6.1 to conduct annual EBRD PR6 - Appoint: prior to year 1 of - Reassessments/assessments evaluation of bird and bat monitoring (items 6.2 and EIB Std 3 operation completed 6.4) and results in order to: - Recommendations for - Recommended mitigations, if any, - Reassess previous conclusions concerning bird/bat mitigation, possibly implemented use, residence, and passage on and near the site including radar: annually ESHS reporting: - Reassess potential impacts on birds and bats for three years - Provide summary of assessments, - Recommend changes to operating parameters (such including cumulative evaluations and as rotation speed or operating hours during sensitive recommendations periods/hours) and/or other mitigation needed to - Describe mitigation measures reduce risk and mortality. recommended, if any

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - Consult with other operators and Institute for Nature Protection concerning cumulative monitoring results and the need for regional mitigation 6.5 Prior to construction of transmission line towers, EBRD PR6 - Competent professional - Competent professional appointed WindVision to appoint (or approve contractor‐ EIB Std 3 appointed and surveys - Survey completed appointed) qualified ecologist/botanist to conduct conducted: immediately - No adverse effects on protected surveys of habitat ALI05 in the transmission line prior to construction of species corridor (and elsewhere, if detected); micro‐locate transmission line towers ESHS reporting: towers to avoid specimens/populations of protected and associated roads - Report on status of appointment and plant species. Also appoint ornithologist/ecologist to - Mitigation/conservation surveys, and of any required survey for Calandrella brachydactyla hungarica and implemented: as required mitigations other resident birds of conservation nesting in corridor. to avoid impacts on If needed to avoid disturbance to bird/fauna species of species of conservation conservation concern, schedule nearby work to avoid concern critical lifecycle periods as recommended by expert. Expert to supervise construction within 100m of ALI05 habitat. 6.6 Take other measures to reduce impacts on birds, Serbian law - Apply stripes: prior to - Stripes applied if required including: EBRD PR6 commissioning - Vegetation cleared initially and - Contractor to paint red stripe on blades if required by EIB Std 3 - Clearing vegetation: prior periodically thereafter authorities to commissioning and at ESHS reporting - Contractor to clear vegetation around all turbines and least annually thereafter - Report highlights of actions taken remove any perching points (fences, bushes, etc.) - Crop spill cleanup: within 100m of turbines. WindVision to maintain immediately after spill clearance during operation

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - WindVision to ensure crop spills are removed from around turbines as soon as practicable

6.7 Contractor to prepare and implement a landscape EBRD PR4,6 - Plan: Prior to construction - Development and implementation of management plan for all project activities. Plan is to call EIB Stds 3,8 - Implementation: the plan for (at a minimum): throughout construction - Agreement of planting areas - Vegetation planting to screen views of substation and and operation - Clearing of vegetation only where permanent buildings required - Buildings, turbines, other permanent features painted ESHS reporting: in neutral unobtrusive colours, without logos, etc. - Report highlights of plan and of - Use of native species for seeding/replanting. Avoid implementation plants attractive to small mammals or insects near turbines. - Monitoring and repairs until vegetation is self‐ sustaining for at least three successive years - See also 3.6 6.8 WindVision to design transmission line towers to be EBRD PR6 - At time of design - Bird‐friendly towers “bird‐friendly”, with sufficient spacing and insulation to EIB Std 3 - Minimal risk of electrocution of large minimize risk of electrocution of the largest bird GIIP birds species known to occur in Project area and ESHS reporting: Sands area. - Report status of tower design 6.9 If recommended by competent experts appointed EBRD PR6 - Install diverters and/or - Bird diverters installed as under 6.1 above: EIB Std 3 platforms: as recommended - Install bird diverters on all or part of transmission line GIP recommended by experts - Platforms installed as recommended conductors, including where the line crosses the - Minimal collision and electrocution valley with habitat ALI05. mortality

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement - Install nesting platforms on towers over 2‐3km (or - Increased nesting by bird species other recommended distance) from nearest turbine. whose nest are co‐opted by Saker falcons and other raptors ESHS reporting - Report status of bird diverters and platforms 6.10 WindVision to establish and maintain a collaborative EBRD PR6 - Information shared: as - Adaptive management approach relationship with developers of other windfarms in the EIB Std 3 needed implemented based on engagement vicinity of Alibunar A and B to enhance collective GIP - Adaptive management: with other developers/operators understanding of the potential cumulative impact of throughout construction - Revision of methodologies as needed these windfarms. The objective will be to share and at least three years of to address cumulative impacts; information on bird and bat movement, collision risk, operation Information shared as requested mortality, as well as management actions to mitigate - Collaboration leads to project and possible cumulative impacts. The conclusions of any social benefits collaborative CIA activity should be used to inform and ESHS Reporting: if relevant, revise the monitoring methodologies under - Report status of other wind projects 6.2, 6.2, and 6.3 above. Other areas of collaboration in area and operators’ collaborative could be social investment programs (education grants, efforts worker training, etc.). - Report on recommended changes to methodologies 6.11 WindVision to continue to engage with General Serbian law - At least once prior to - Authorities engaged/consulted and Secretariat and Institute for Nature Protection to verify commissioning and again convinced monitoring programs under 6.2, 6.3, and 6.4 meet the after one year of ESHS reporting: Compensation Rule Book’s requirement for operation - Report results of engagement “continuous monitoring.

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement EBRD PR 8: Cultural Heritage EIB E&S Standard 5: Cultural Heritage 8.1 Contractor(s) to develop and implement chance finds Serbian law - Provide funding to - Institute involved at every stage procedure for Alibunar A, substation, and transmission EBRD PR8 Institute for Zone I: 6‐12 - Procedure developed and line. Prior to construction of transmission line, EIB Std 5 months before implemented WindVision to provide funding for Institute for the construction of t‐line - No removal or loss of cultural Protection of Cultural Monuments in Pančevo to - Notify Institute: at time of heritage without appropriate complete excavations at transmission line tower t‐line construction permit conservation locations and roads in Protection Zone I, appoint application ESHS reporting: qualified archaeologist (or Institute) to oversee - Excavation in t‐line - Report status of excavations and excavations at tower locations and roads in Protection Protection Zones: as finds in protection zones, Institute Zone II, design tower 10 and route between 23‐25 with specified by Institute decisions and changes in schedule or appropriate “technical protection measures” as - Implement chance find methods specified in Institute Decision 31/13. procedure: during all - Report discoveries and any ground‐disturbing implications for project activities EBRD PR 10: Information Disclosure and Stakeholder Engagement EIB E&S Standard 10: Stakeholder Engagement 10.1 WindVision to implement the Stakeholder Plan (SEP), EBRD PR10 - Implement second round: - Stakeholders informed and engaged including the grievance mechanism for external EIB Std 10 during EBRD/EIB as defined in SEP stakeholders, and a second round of public disclosure periods - Grievance mechanism for external consultation. Engagement to include: - Implement continuing stakeholders in place and operational - Make monitoring data available via website or engagement per SEP: ESHS reporting: otherwise on request. throughout construction - Report to Lenders highlights of - Public meeting in Alibunar during disclosure period and operation stakeholder engagement following notices in in settlements Seleuš,

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Alibunar A Wind Project Environmental and Social Action Plan Source of Requirement Implementation date KPI / Reporting1 requirement Vladimirovac, , and Alibunar - Report to Lenders summary of municipality: invite all stakeholders, prepare visual grievances and responses displays of key project information, provide knowledgeable company officials to answer stakeholder questions. - Make available copies of ESIA documentation (updated ESIA, SEP, ESAP, NTS) at all open houses and maintain documents in all town halls. - Notify Bird Protection Society and Institute for Nature Protection of the availability of updated ESIA documentation and of open house meetings. - Post signs in populated zones along IB‐10 and at junction with access road with notice of changes in traffic patterns, including days and times. - Post warning signs along municipal roads used by public and on IB‐10 at intersection with access road. 10.2 In accordance with SEP, contractor to assist WindVision EBRD PR10 Notice provided: before - Affected people given advance notice in providing early notice to villages and residents prior EIB Std 10 impacts occur of changes in impacts to major increases in traffic or other project activities ESHS reporting: that could affect them. - Report to Lenders highlights of notices

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