Final Initial Environmental Examination

Project Number: 54433-001 August 2021

Georgia: M Square Affordable Housing Project

Prepared by Paragon Ltd. for the Asian Development Bank.

The initial environmental examination is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “terms of use” section on ADB’s website.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Initial Environmental Examination

White Square Affordable Housing Project Tbilisi, Georgia February – August 2021

FINAL Client Projects No:

“Optima” LLC (“White Square”) By BHP - Paragon

Summary and Version history: Date: 13 August 2021 This page is the record of all revisions in Approved by: this document. All previous issues are hereby superseded.

------Name/Company/Position

Revision Description By Reviewed Approved Date

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V - 01 Draft Initial Environmental K. Khabalashvili 8 April Examination /L.Bibichadze 2021 V - 02 Draft Initial Environmental K. Khabalashvili 19 April Examination, comments from /L.Bibichadze 2021 ADB addressed

V – 03 Draft Report, second set of K. Khabalashvili 31 July comments from ADB /L.Bibichadze 2021 discussed and reflected FINAL Final agreed version of the K. Khabalashvili 13 Initial Environmental /L.Bibichadze August Examination 2021

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Table of Contents 1. EXECUTIVE SUMMARY ...... 6 2. ACRONYMS AND ABBREVIATIONS ...... 7 3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK ...... 9 3.1 Asia Development Bank (ADB) ...... 9 3.2 Georgian Laws and Regulations ...... 12 3.2.1 Framework legislation ...... 12 3.2.2 Applicable licenses and approvals ...... 18 3.2.3 Administrative Structure in Georgia ...... 24 3.3 National legislation and ADB requirements cross-comparison ...... 25 3.4 National legislation and ADB requirements harmonisation ...... 26 4. DESCRIPTION OF THE PROJECT ...... 27 4.1 Type of the project ...... 27 4.2 Need of the project ...... 29 4.3 Location ...... 31 4.4 Project description ...... 33 4.4.1 “Mirtskhulava” ...... 33 4.4.2 “Chkondideli” ...... 35 4.5 Operation activities ...... 37 5. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA) ...... 38 5.1 Physical resources ...... 38 5.1.1 Atmosphere ...... 38 5.1.2 Ambient Air Quality...... 41 5.1.3 Noise ...... 50 5.1.4 Geomorphology and Geology ...... 59 5.1.5 Seismicity ...... 59 5.1.6 Soils and fundamental landscapes ...... 60 5.1.7 Surface water and groundwater ...... 61 5.2 Biodiversity...... 62 5.2.1 Flora ...... 62 5.2.2 Fauna ...... 64 5.3 Natural background radiation ...... 65 5.4 Socio-cultural resources ...... 65 5.4.1 Demography ...... 66 5.4.2 Medical Outpatient facilities ...... 74 5.4.3 Educational institutions ...... 74

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5.4.4 Agriculture...... 76 5.4.5 Motorways ...... 76 5.5 Waste management and landfill ...... 79 5.5.1 Municipal landfill ...... 79 5.5.2 Inert waste disposal ...... 79 5.5.3 Hazardous waste disposal/treatment ...... 80 5.6 Water supply system...... 80 5.7 Wastewater system ...... 80 5.8 Transport ...... 81 5.9 Cultural heritage ...... 81 5.9.1 German settlement in district of Tbilisi ...... 83 5.10 Tourism ...... 86 6. ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES ...... 86 6.1.1 Noise and Dust ...... 87 6.1.2 Noise and Dust Mitigation measures ...... 89 6.2 Water and wastewater ...... 90 6.2.1 Water ...... 90 6.2.2 Wastewater disposal ...... 91 6.2.3 Water and Wastewater Mitigation measures ...... 91 6.3 Soil quality and topsoil management ...... 92 6.3.1 Soil and topsoil ...... 92 6.3.2 Soil and Topsoil Mitigation measures ...... 92 6.4 Biological environment ...... 92 6.4.1 Flora and fauna ...... 92 6.4.2 Flora and Fauna Mitigation measures ...... 92 6.5 Traffic ...... 93 6.5.1 Traffic ...... 93 6.5.2 Traffic Mitigation measures ...... 93 6.6 Waste management ...... 93 6.6.1 Inert waste ...... 94 6.6.2 Domestic waste ...... 95 6.6.3 Hazardous waste ...... 95 6.6.4 Medical waste ...... 95 6.6.5 Waste Mitigation measures ...... 95 6.7 Socio-Cultural resources ...... 96 6.7.5 Chance Find Procedure ...... 97

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6.8 Occupational and Community Health and safety ...... 98 6.9 Climate change impact ...... 99 7. Environmental and Social Impact and Mitigation Matrix ...... 100 8. ROLES AND RESPONSIBILITIES ...... 119 8.1 Company CEO ...... 119 8.2 Project Manager...... 119 8.3 E&S manager ...... 119 8.4 Project Site Manager ...... 120 8.5 H&S site officer ...... 120 8.6 Site Personnel and Workforce ...... 120 9. ANALYSIS OF ALTERNATIVES ...... 120 10. INFORMATION DISCLOSURE, CONSULTATION, AND PARTICIPATION ...... 121 11. GRIEVANCE REDRESS MECHANISM ...... 122 9.1 Employee Complaints and Grievance Redress Mechanism procedure ...... 123 9.2 Community Complaints and Grievance Redress Mechanism procedure ...... 127 12. APPENDICES ...... 132

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1. EXECUTIVE SUMMARY The project described comprises development of two residential areas - “Mirtskhulava” and “Chkondideli” project sites. The developing company “Optima” LLC – (“the Company”) i.e., client, requested consulting company “Paragon” Ltd (“the Consultant”) to conduct an Environmental and Social Due Diligence, including the preparation of an Initial Environmental Examination. ADB is considering provision of a secured loan to partially finance the construction and finalization of the “Chkondideli” and “Mirtskhulava” housing complexes. Since the project is unlikely to have significant adverse impacts, it is classified as Category B for environmental impact, Category B for Involuntary Resettlement (IR), and Category C for Indigenous Peoples / ethnic minorities (IP) and accordingly an Initial Environmental Examination (IEE) is required. The IEE, conducted in February to April 2021, is supplemented with an Environmental and Social Compliance Audit (ESCA) and Corrective Action Plan (CAP) to review the Project’s Existing Facilities as required by ADB. The primary ownership of the project is under the company “White Square” LLC, that is a commercial brand name for “Optima” LLC and is 100% owned by “M2 Group” LLC, wholly owned by “Georgia Capital” PLC (GCAP) listed in the London Stock Exchange, through JSC “Georgia Real Estate” (GRE). The Project will offer affordable, cost-efficient apartments in “white finishing” condition. This is above local market standards, where most apartments are sold under “black frame”, being left with cement finishing - without plumbing or electric system. Both housing complexes will cater to low/low-middle income populations as they are in blue-collar neighbourhoods – with old-styled Soviet-blocks, trading warehouses, and near railway stations. The complexes will include common areas including green areas, basketball courts and commercial spaces, which are rare in Tbilisi. The development project described within this IEE was originally initiated in 2016 by the “Sveti Group” Ltd., “Sveti Development” Ltd., “Sveti Nutsubidze” Ltd (“joint owners”), however due to the inability to complete the project, it was transferred to the Company in 2018. Following intervention by the Tbilisi Municipality and “M2 Group” in 2019, development of the three complexes was

Page 6 of 204 revived. The project’s implementation was re-initiated in 2020 and is currently planned to be completed in 2023.

The project sites “Mirstkhulava” and “Chkondideli” are located in Didube and Nadzaladevi districts of Tbilisi respectively, on the streets with the same respective names, both being heavily settled residential area.

The Project comprises a 10-residential-building development at “Mirtskhulava” and a 12-residential-building development at “Chkondideli” site. The development area of the “Mirtskhulava” residential project covers 25,365 m² of land with the overall buildable area being up to 205,289 m² (1,667 the Company sellable apartments). The development area of the “Chkondideli” residential projects covers 31,011 m² of land with the overall buildable area being 136,722 m² (905 the Company sellable apartments). The Project will be implemented according to the national legislative framework as well as ADB’s Safeguards Policy Statement (SPS 2009) and social requirements which include ADB’s Social Protection Strategy (2001), Gender and Development Policy (2003), and Access to Information Policy 2018. Based on the specifics of the project, a number of mitigation measures are required to avoid or minimize expected negative environmental and social impacts. The construction activities implemented in dense residential area of Tbilisi will cause disturbance to the population due to noise and dust. In addition to that, generation of waste can be significant, specifically inert construction, but also domestic and other non-hazardous waste, requiring proper disposal. The document hereby has been developed in order to avoid and/or minimize a number of anticipated negative impacts with the proper and timely implementation of the mitigation measures. The overall conclusion of the IEE is that provided the mitigation and enhancement measures are implemented in full, there should be no significant negative environmental or social impacts as a result of location, design and construction of the Project.

2. ACRONYMS AND ABBREVIATIONS Acronyms Definitions ADB Asian Development Bank

ADB’ s SPS ADB Safeguard Policy Statement

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AP Affected People m.a.s.l. Meters Above Sea Level CAI Completion Acceptance Inspection CAP Corrective Action Plan GCAP Georgia Capital PLC CR Critically Endangered (flora or fauna species) HSE Health, Safety and Environmental HSES Health, Safety, Environmental and Social EIA Environmental Impact Assessment EN Endangered (flora or fauna species) EPB Environmental Protection Bureau ERP Enterprise Resource Planning (database) E&S Environmental and Social ESMP Environmental and Social Management Plan ESMS Environmental and Social Management System HR Human Resource IFC International Finance Corporation ILO International Labour Organization ISO International Standardization Organization km Kilometre km² Square kilometre LLC Limited Liability Company m Meter m² Square meters m³ Cubic meter

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MEPA Ministry of Environmental Protection and Agriculture (Of Georgia) MLC Most Likely Cases PLC Public Limited Company PPE Personal Protective Equipment Q HSE Quality, health, Safety and Environmental RE Regionally Extinct (flora or fauna species) RWC Reasonable Worst Cases SIA Social Impact Assessment SPS Safeguard Policy Statement VU Vulnerable (flora or fauna species) WHO World Health Organisation

3. POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK This section discusses the national and local legal and institutional framework within which the environmental examination is carried out. It also identifies project-relevant international environmental and social agreements to which the country is a party/signatory. 3.1 Asia Development Bank (ADB) Superseding the previous safeguard policies (the Involuntary Resettlement Policy, 1995, the Policy on Indigenous Peoples, 1998, and the Environment Policy 2002), ADB adopted a comprehensive Safeguard Policy Statement in 2009 (SPS, 2009). The SPS describes common objectives of ADB’s safeguards, lays out policy principles, and outlines the delivery process for ADB’s safeguard policy. It applies to all ADB-financed and administered projects, and their components including investment projects funded by a loan, grant or other means. Aiming on promotion and sustainability of project outcomes by protecting the environment and people from projects’ potential adverse impacts, the objectives of ADB’s safeguards are to: o Avoid adverse impacts of projects on the environment and affected people, where possible;

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o Minimize, mitigate, and/or compensate for adverse project impacts on the environment and affected people when avoidance is not possible; and o Help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks. The objective of environmental safeguards is to ensure the environmental soundness and sustainability of projects and to support the integration of environmental considerations into the project decision-making process. All ADB funded projects are screened at initial stages of preparation and categorized according to significance of the project’s potential environmental impacts. In accordance with the ADB SPS 2009, the projects are assigned to one of the following three environmental categories: Category A - Projects likely to have significant adverse environmental impacts, which are irreversible, diverse, or unprecedented and may affect an area larger than the location subject to physical works. An Environmental Impact Assessment is required.

Category B – Projects with adverse environmental impacts that are less significant than those of Category A projects, are site-specific, generally not irreversible, and in most cases can be mitigated more readily than for Category A projects. An Initial Environmental Examination (IEE) is required. Category C - likely to have minimal or no adverse environmental impacts; EIA is not required.

In accordance with ADB SPS 2009 “Involuntary Resettlement” all projects will be screened to determine whether or not they involve involuntary resettlement. For a project involving involuntary resettlement, a resettlement plan will be prepared that is commensurate with the extent and degree of the impacts. The degree of impacts shall be determined by (i) the scope of physical and economic displacement, and (ii) the vulnerability of the affected persons.

In accordance with the ADB SPS 2009 “Indigenous Peoples” all projects will be screened to determine whether or not they have potential impacts on Indigenous Peoples. For projects with impacts on Indigenous Peoples, an Indigenous Peoples plan will be prepared. The plan’s level of detail and comprehensiveness will be commensurate with the degree of impacts. The degree of impacts is determined by evaluating (i) the magnitude of the impact on Indigenous Peoples’ customary rights of use and access to land and natural

Page 10 of 204 resources; socioeconomic status; cultural and communal integrity; health, education, livelihood systems, and social security status; or indigenous knowledge; and (ii) the vulnerability of the affected Indigenous Peoples. Tbilisi Affordable Housing project has been classified as environmental assessment category B, Indigenous Peoples category C and Involuntary resettlement category B. Other applicable ADB requirements for the project include the following: o ADB Social Protection Strategy, 2001. o ADB Gender and Development Policy, 1998. o ADB Access to Information Policy, 2019. The issues applicable to the project include air quality, waste and chemical management, pollution prevention, social protection, which are either prescribed in relevant national laws and regulations or are to be adhered to international standards. In addition to the above ADB follows a four-tier gender categorization system to assess the extent to which gender is integrated in project design.1 The categories are 1. Gender Equity Theme. The project outcome directly addresses gender equality and/or women’s empowerment by narrowing gender disparities through promoting access to social services, such as education, health, water supply, and sanitation; access to economic or financial resources or opportunities; access to basic rural or urban infrastructure; and enhancement of women’s voice and rights. 2. Effective Gender Mainstreaming (EGM). The project outcome does not directly address gender equality or women’s empowerment, but the project outputs are designed to deliver tangible benefits to women by directly improving their access to economic or financial resources, social services, or basic rural or urban infrastructure, and/or by enhancing their voice and rights, which contribute to gender equality and women’s empowerment. 3. Some Gender Elements. The project is likely to directly improve women’s access to services, opportunities, and improved voice, but does not meet EGM design criteria; or efforts were made to include some gender features.

1 Guideline for Gender mainstreaming categories of ADB projects, 31 March 2021

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4. No Gender Elements. All program and projects are now required to include gender elements. The ADB Operational Plan, 2013–2020 calls for meaningful integration of gender issues into country partnership strategies, for a higher number of programs with a gender equality theme, and for an emphasis on gender-focused policy dialogue, as well as knowledge and capacity development on gender.

3.2 Georgian Laws and Regulations 3.2.1 Framework legislation The basic legal document is “The Constitution of Georgia”, which was adopted in 1995. While the Constitution of Georgia does not directly address environmental matters, it does lay down the legal framework that guarantees environmental protection and public access to information with regard to environmental conditions.

Article 37, Part 3 states that “any person has the right to live in a healthy environment, use the natural and cultural environment. Any person is obliged to take care of the natural and cultural environment.” Article 37 Part 5 states that “an individual has the right to obtain full, unbiased and timely information regarding his working and living environment.” Article 41, Part 1 states that “a citizen of Georgia is entitled to access information on such citizen as well as official documents available in State Institutions provided it does not contain confidential information of state, professional or commercial importance, in accordance with the applicable legal rules. Environmental Assessment Code of Georgia (2017) regulates matters related to strategic documents and public or private activities which may have significant effects on the environment, human life and/or health. The procedures for environmental impact assessment, strategic environmental assessment, transboundary environmental impact assessment, and public participation in decision-making, as well as the conduct of expert examinations, fall within the scope of this Code. This Code aims to: a) promote the protection of the environment, human life and/or health, cultural heritage and material assets, in the implementation of strategic

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documents or activities which may have significant effects on the environment, human life and/or health; b) ensure, for the purpose of the promotion of the country's democratic development, the exercise of a fundamental human right to obtain timely complete and objective information on the state of the environment, guaranteed by the Constitution of Georgia, as well as ensure public participation in environmental decision-making; c) proportionally take account of the environmental, social and economic interests of the State and the public in decision-making on the implementation of strategic documents or activities which may have significant effects on the environment; d) apply standards of best international practice in the implementation of environmental assessment procedures. The objectives of this Code are to: a) determine the rights and obligations of persons carrying out activities, and planning authorities and public and competent administrative bodies in decision-making related to issues provided for by this Code; b) ensure public access to information on all likely effects of the implementation of strategic documents or activities to maximally prevent, reduce or mitigate adverse effects on the environment, human health and safety, cultural heritage and material assets; c) determine procedures which shall be carried out in the case of transboundary impacts. The Law of Georgia on Environment Protection (1996) regulates the legal relations between the state establishments and physical or legal entities in the field related to the use of territorial waters, air space, including continental shelf and special economic zones, environmental protection and natural resources on the territory of Georgia. The Law regulates the standards of the environmental protection and issues of environmental management; it describes the economic sanctions, standards and issues of environmental impact, different issues of protection of the natural eco-systems and biodiversity, and global and regional management issues. In addition to the above-mentioned, the Law considers the major principles of waste management. The law defines the ecological requirements for the waste (Article 34). According to the provision of the given

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Article, an entrepreneur is obliged to reduce the origination of industrial, domestic and other types of waste, ensure their treatment, utilization, placement or burying by considering the environmental, sanitary-hygienic and epidemiological standards and rules. The Law defines the requirements for the placement of toxic, radioactive and other hazardous waste and prohibits their discharge in the surface water sources. Georgian Waste Management Code (2014) establishing a legal framework in the field of waste management to implement measures that will facilitate waste prevention and its increased re-use as well as environmentally safe treatment of waste (which includes recycling and separation of secondary raw materials, energy recovery from waste and safe disposal of waste). The objective of this Code is to protect the environment and human health through: a) the prevention or reduction of waste and its adverse impact; b) the establishment of effective mechanisms for waste management; c) the reduction of damage caused by the consumption of resources and the more efficient use of resources. The Law of Georgia on Licenses and Permits (2005) defines the list of activities needing licenses or permits, including so called “Environmental permit”. It also defines the requirements for the license or permit issue. The Law, together with the normative by-laws, regulates such organized activity or action, which relates to an indefinite circle of entities, is characterized by increased hazard to the human life or health, affects particularly important state or public interests or is related to the use of a state resource. The given Law regulates the field regulated by a license or permit; it gives a thorough list of licenses and permits and establishes the rules to issue the licenses and permits, 28 makes amendments to them or abolish them. Under the Law, a state regulation of the activity or action through a license or permit is undertaken only when the given activity or action is directly associated with the increased hazard to the human life or health or fields of state or public interests. The state regulation is undertaken only when the issuance of a license or permit is a real means to reduce the hazard in question or consider state or public interests. The aim and major principles of regulating the activity or action via licenses or permits are as follows:

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o Provision and protection of human life and health; o Safety and protection of a human’s residential and cultural environment; o Protection of state and public interests; The Law of Georgia on Cultural Heritage (2007). Article 14 of the Law specifies the requirements for ‘large-scale’ construction works. According to this Article, a decision on career treatment and ore extraction on the whole territory of Georgia, as well as on construction of an object of a special importance as it may be defined under the legislation of Georgia, is made by a body designated by the legislation of Georgia based on the positive decision of the Ministry of Culture and Monument Protection of Georgia. The basis for the conclusion is the archaeological research of the proper territory to be carried out by the entity wishing to accomplish the ground works. The entity wishing to do the ground works is obliged to submit to the Ministry the documentation about the archaeological research of the territory in question. The preliminary research should include field-research and laboratory works. In case of identifying an archaeological object on the territory to study, the conclusion of the archaeological research should contain the following information: (a) a thorough field study of the archaeological layers and objects identified on the study territory by using modern methodologies, (b) recommendations about the problem of conservation of the identified objects and planning of the building activity on the design territory, on the basis of the archaeological research. The aim of the Law of Georgia on Public Health (2007) is as follows: Promotion of the introduction of a good health and healthy lifestyle of the population; Creation of the environment, which is safe for a human health; Promotion of the protection of the reproductive health of a family; Prevention of infectious and non-infectious diseases. The Law defines the rights and obligations of the population and legal entities in the field of public health. Aiming at establishing the environment safe to the public health, the Ministry sets the qualitative standards for the environment safe for a human health (atmospheric air, water, soil, noise, vibration, electromagnetic radiation), including maximum permissible concentrations and rates of harmful impact. The standards are mandatory. Every person on the territory of Georgia is obliged not to carry out the activity, which causes a hazard of the infectious and non-infectious diseases to spread and helps the origination of the risks to human health; protect the sanitary and epidemiological standards; to supply the information to the public health department about all emergencies caused by the violation of the sanitary norms in the production or technological process, etc. The observance of the

Page 15 of 204 standards is controlled by appropriate state structures. The responsibility for the internal and external audits rests with a certified, independent laboratory. Labour code of Georgia regulates labour and its concomitant relations in the territory of Georgia, unless they are otherwise governed by other special law or international agreements of Georgia. Georgia ratified the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) in 1994 with no reservations. Under the convention, signatories are expected to “take all appropriate measure to ensure the full development and advancement of women” and to “pursue by all appropriate means and without delay a policy of eliminating discrimination against women.” The convention commits governments to reflect the principles of equality between women and men in all legislation, procedures, and institutions. In 1995, Georgia was a signatory to the Beijing Platform for Action (BPFA), a global agenda for women’s empowerment. Progress in translating these gender equality-focused agreements into reality has been slow, but the past 5 years have seen increased awareness of gender issues— particularly of the need to end violence against women—and political commitments to tackle them. Concrete actions are being taken in response to the CEDAW Committee’s recommendations in 2014, which called upon Georgia to strengthen its Gender Equality Council (GEC), establish a comprehensive mechanism to implement and monitor gender equality policies, take action to fight gender stereotyping, take measures to prevent child marriage and domestic violence, and give effective protection to victims of violence28 (section III. E.).

In 2000, Georgia integrated the Millennium Development Goals (MDGs)— including Goal 3 on promoting gender equality and empowering women—in its National Development Strategy. Georgia is also party to the following relevant international agreements:

• The International Covenant on Civil and Political Rights, which commits signatories to uphold the right to access to justice for human rights violations, protect the equal rights of men and women, and prohibits forced marriage.

• The International Covenant for Economic, Social and Cultural Rights, which protects the equal rights of men and women, applies special protections

Page 16 of 204 to mothers, and calls for governments to ensure the right to the highest attainable standard of health and education.

• The European Convention of Human Rights, which protects the right to life and to respect for private and family life and prohibits discrimination. Gender Equality (GE) law - in 2006, the government of Georgia adopted a State Concept on Gender Equality. In March 2010, the concept was enshrined in the GE Law. It prohibits gender-related discrimination and puts in place provisions for guaranteeing gender equality. These include ensuring equal access to education for boys and girls, equal employment opportunities for women and men, fair and equitable working conditions and pay, promoting equal rights and freedoms of women and men, enabling equal access to information, and supporting elimination of gender-based violence and harassment. The law also calls for the systematic generation of gender-disaggregated data. Nondiscrimination law - the Law on Elimination of all Forms of Discrimination (NonDiscrimination Law) was adopted in 2014. This law clearly states the “unacceptability of discrimination” on the basis of one’s gender identity or sexual orientation along with race, color, language, national, ethnic or social belonging, sex, pregnancy or maternity, marital or health status, disability, age, nationality, origin, place of birth, place of residence, internal displacement, material or social status, religion or belief, political or any other ground. The Non-Discrimination Law includes the principle of equality established by CEDAW. In addition to protecting rights to nondiscrimination, it sets out available complaint mechanisms and procedural paths to obtain remedies. ADB Gender Policy and Processes ADB is committed to ensuring gender- sensitive development that contributes to gender equality and women’s empowerment. In 1998, ADB progressed from a Women in Development (WID) to a Gender and Development (GAD) approach, which sees gender as a crosscutting issue influencing all social and economic processes.134 The shift reflects the recognition that women’s needs and concerns cannot be addressed in isolation from the social and personal relations through which gender inequalities are perpetuated and reproduced. ADB holds that addressing these inequalities is not only an issue of rights or social justice, but also that “it makes economic sense and is good development practice.” ADB is committed to reflecting gender dynamics and promoting gender equality through a twin-track strategy that promotes gender mainstreaming in all areas of its work—including macroeconomic and sector work, and lending and technical assistance (TA)

Page 17 of 204 operations—while retaining a specific focus on women, adopted by many development agencies, was criticized because it treated women’s issues in isolation from their relationships with men. This led to an industry-wide shift to a GAD approach, which focuses on the social relations between women and men and recognizes the importance of actively engaging men in changing inequitable gender norms.2 3.2.2 Applicable licenses and approvals The Annexes I and II of Environmental Assessment Code of Georgia defines the activities which requires the screening and/or EIA process. Annex II of this code indicates that some Urban development projects with a development area of more than 10 hectares (including the construction of shopping centres and car parks for 1 000 cars) requires the screening process. According to entire project specifications, the project development areas for “Mirtskhulava” and “Chkondideli” project sites are 2.5 hectares and 3 hectares accordingly. Therefore, none of the components of the proposed Affordable Housing project in Tbilisi fall under requirements of above-mentioned code and its articles and therefore, no EIA process is required. Resolution N57 of the Government of Georgia on the procedure for issuing a construction permit and permit conditions covers the field of regulation of public legal relations related to the construction permit on the territory of Georgia. In particular, it regulates the process of issuing a construction permit on the territory of Georgia, fulfilling the permit conditions and recognizing the building as suitable. The purpose of the resolution is to ensure the implementation of the requirements and principles of the Law of Georgia on Licenses and Permits in the field of its regulation. Issuing of construction permit and determination of permit condition is carried out according to the principles of: • safety of life and health; • ensuring a safe environment; • protection and preservation of cultural heritage; • protection and realization of property rights; • publicity; • the principle of one window;

2 ADB. 2003. Gender and Development Framework and Policy. Manila; and R. Shahrashoub and C. Miller.

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The Company obtained all the necessary architectural and construction permits as reflected within the Table 3.2 Project Specific Permits. Resolution N17-55 on the approval of the rule of protection, care and restoration of green plants on the territory of Tbilisi Municipality regulates the protection, maintenance and restoration of green plants in order to maintain the ecological balance, species composition and quality of green plants on the territory of Tbilisi Municipality, to establish high-yielding groves, to maintain climatic conditions and to avoid the negative factors caused by climate change. The resolution stipulates: • the rules of protection, care and restoration of green plants; • the procedure for allocating the area of felling trees and marking the trees; • the procedure for production of the green plant registration form. Tree cutting permits for both “Mirtskhulava” and “Chkondideli” sites have been issued by Tbilisi Municipality with reference numbers and date of issue provided within the table of project-specific permits.

The Law of Georgia “On the Red List and Red Book” (2003) regulates the legal relations in the field of developing the Red List and Red Book, protecting and using the endangered species. According to Article 10 of the Law, any activity, including hunting, fishing, extraction, cutting down and hay-mowing, except particular cases envisaged by the present Law, Law of Georgia ‘Wildlife’ and legislation of Georgia, which may result in the reduction in number of the endangered species, deterioration of the breeding area or living conditions, is prohibited. The Red List of Georgia was approved by the Presidential Decree No. 303 ‘On approving the Red List of Georgia’ (May 2, 2006). The Company conducted inventory of all trees present on the territory of the projects constructions sites including identification of red list and red book species and consequent relocation where required.

Table 3.1 – Other National Environmental Legislations and Applicability LEGISLATION APPLICABILITY REMARKS Law on Ambient Air Overall It stipulates Maximum Allowable Protection, Concentration (MAC) of various pollutants in Ambient Air; 2000 however, the establishment of

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emission standards for various sources or activities is under process, therefore at present no standards are available. Technical Regulation of Applicable to Water supply and monitoring Drinking Water, 2007 water supply shall comply with the technical (Decree N 349/N), the projects regulation. Ministry of Labour, Health and Social Affairs of Georgia

“Approval of Applicable The Georgian standards for Environmental Quality noise control as approved by the Standards” - approved Decree of the Minister for by Minister of Health, Health, Labour and Social Affairs Labour and Social (297n of August 16, 2001) upon Affairs [Decree number the ‘Approval of Environmental - 297n of August 16, Quality Standards’; specifying 2001]) the tolerable and maximum admissible levels of noise for different zones. Technical Regulation Applicable to all Defines the reference criteria for N398 - "On the norms of projects and background noise in and around acoustic noise on the activities workplace and residential premises of residential including buildings. It establishes noise buildings and public / construction thresholds for the daytime public institutions” 2017 projects evening and night-time. These threshold values apply to the boundaries of residential areas. Environmental Quality Applicable to all Defines the reference criteria for Condition Normative, projects and various pollutants into the Technical Regulation N activities Environment. 297/N addition 38/N, including 2003 construction projects

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Law of Georgia Railway Applicable to Defines railway right-of-way Code – 22.01.2003 “Mirtskhulava” width project site Some of the International Treaties and Conventions Ratified or Signed by Georgia are provided in the list below: o Ramsar Convention on Wetlands (1996); o United Nations Framework Convention on Climate Change (UNFCC) (1994); o Kyoto Protocol (1994); o Kyoto Protocol (1999); o Basel Convention on the Control of Transboundary Movement of Hazardous Waste and Their Disposal (1999); o Convention on Access to Information, Public Participation in Decision- making and Access to Justice in Environmental Matters (Aarhus Convention) (1999); o Convention on Biological Diversity (1994); o Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) (1996); o Convention on Long-range Transboundary Air Pollutants (1999); o Stockholm Convention on Persistent Organic Pollutants (2006); o Convention on the Conservation of European Wildlife and Natural habitats (2008); o The Vienna Convention for the Protection of the Ozone Layer (1995); o Montreal Protocol on Substances that Deplete the Ozone Layer (1995); o Paris Agreement (2017) o World Bank Group/IFC EHS as well as sector specific Guidelines. o International Covenant on Economic, Cultural and Social Rights and relevant ILO Core Labour Standards Conventions. As signatory to the latter since 1993, Georgia developed a few Georgian National laws and regulations which enforce International Labour Organisation fundamental conventions. The details of the Georgian National labour, social security and human right legislation can be found at https://www.ilo.org/dyn/natlex/natlex4.countrySubjects?p_lang=en&p_ country=GEO

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In addition to the above the Project specific construction, architectural, water and drain, and tree cutting permits list is provided within the table below.

Table 3.2 – Project-specific permits Permit Issuing Authority- Remark Date

Architectural; Construction Tbilisi City Hall – Mirtskhulava Blocks 1, 2 01.13.04.017.406 31/01/2020; 30/10/2020

Architectural; Construction Tbilisi City Hall – Mirtskhulava Blocks 3,4 01.13.04.017.405 31/01/2020; 30/10/2020

Architectural; Construction Tbilisi City Hall – Mirtskhulava Block 5 01.13.04.017.409 4/2/2020; 20/05/2020

Architectural; Construction Tbilisi City Hall – Mirtskhulava Block 6,7 01.13.04.017.408 5/2/2020; 9/10/2020

Architectural; Construction Tbilisi City Hall – Mirtskhulava Block 8 01.13.04.017.411 31/01/2020; 20/05/2020

Architectural; Construction Tbilisi City Hall – Mirtskhulava Blocks 9, 10 01.13.04.017.109 3/2/2020; 14/12/2020 Architectural; Construction Tbilisi City Hall Mirtskhulava Roads 01.13.04.017.407 Architectural; Construction Tbilisi City Hall Mirtskhulava Green Zone 01.13.04.017.106 Water and drain Georgian Mirtskhulava water and drain infrastructure Water and Power - 29/06/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 1 01.12.12.024.211 17/02/2020; 02/12/2020

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Architectural; Construction Tbilisi City Hall – Chkondideli Block 2 01.12.12.024.213 14/02/2020; 23/10/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 3 01.12.12.024.215 06/02/2020; 04/03/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 4 01.12.12.024.214 10/02/2020; 04/02/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 5 01.12.12.024.212 06/02/2020;

Architectural; Construction Tbilisi City Hall – Chkondideli Block 6,7 01.12.12.024.224 06/02/2020; 04/03/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 8, 9, 10 01.12.12.024.262 07/02/2020; 09/03/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 11 01.12.12.024.260 06/02/2020; 20/05/2020

Architectural; Construction Tbilisi City Hall – Chkondideli Block 12 01.12.12.024.216 04/02/2020; 11/12/2020 Architectural; Construction Tbilisi City Hall Chkondideli Roads 01.12.12.024.209 Architectural; Construction Tbilisi City Hall Chkondideli Green Zone 01.12.12.024.206 Architectural; Construction Tbilisi City Hall Chkondideli Green Zone 01.12.12.024.218 Architectural; Construction Tbilisi City Hall Chkondideli 01.12.12.024.263

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Water and drain Georgian Chkondideli water and drain infrastructure Water and Power - 29/06/2020

Tree cutting პ/6449260 Tbilisi City Mirtskhulava Hall 25/01/2021 Tree cutting 18-01202023485 Chkondideli Tbilisi City Hall 20/07/2020

3.2.3 Administrative Structure in Georgia Ministry of Environmental Protection and Agriculture of Georgia (MEPA) has the overall responsibility for protection of environment in Georgia. The Department of Permits of MEPA is responsible for reviewing EIAs and for issuance of the Environmental Permits. MEPA is the main state body pursuing state policy in the sphere of environment. Their functions for regulating economic or development activities with regard to environmental protection include: o Provision of environmental decision for project development o Setting emission limits and issuing surface water intake and discharge consents o Responding to incidents and complaint For the projects, which do not require Construction Permit, the Environmental permit is being issued by the MEPA on the ground of State Ecological Examination. State Ecological Examination is carried out by MEPA upon official submission of Environmental Impact Assessment (EIA) prepared by project developers.

The “Mirtskhulava” and “Chkondideli” projects require Construction Permit, therefore no special permit is issued by MEPA (according to “One window principle”, only one permit shall be issued for each activity). The Construction Permit is issued by the Ministry of Economy and Sustainable Development of Georgia, but the issuance of the Permit is subject to the consent of the MEPA in a form of Conclusion of Ecological Expertise, as well as the Ministry of Sport, Culture and Youth of Georgia (Centre of Archaeological Studies, Department of Monuments protection). Consent of the MEPA in such cases should be issued according to the same procedures (EIA, public consultations; SEE etc.) as for

Page 24 of 204 issuing Environmental Permit. However, based on the Impact Assessment code of Georgia, “Mirtskhulava” and “Chkondideli” projects do not require EIA including public consultation3. The Ministry of Economic and Sustainable Development as an administrative body issuing a permit ensures the involvement of the MEPA as a different administrative body in the administrative proceedings initiated for the purpose of permit issuance, in accordance with Georgia’s Law on Licenses and Permits. As a rule, EIA permitting conditions contains requirement for informing MEPA regarding fulfilment of the EIA permit conditions. This basically means giving information regarding implementation of Environmental Management and Monitoring Plans. The Ministry of Sport, Culture and Youth of Georgia is responsible for the supervision of the construction activities in order to protect archaeological heritage. In case if construction is to be carried out in a historic sites or zones of cultural heritage, consent of the Ministry of Sport, Culture and Youth of Georgia is also required for issuing construction permit (if such is necessary). 3.3 National legislation and ADB requirements cross-comparison The above accounts of national environmental law and ADB policies indicate that the two systems are similar but then there are certain aspects in which ADB policy is more stringent or specified than the Georgian procedure. The main differences are as follows.

ADB’s SPS provides a detailed description of procedures for screening, scoping, and conducting EIA and explain a complete list of stages, which are not specified under the national legislation. Considering ecological risk, cultural heritage, resettlement and other factors, ADB classifies projects supported by them under categories A, B, C and FI. However, in the Georgian legislation, EIA is carried out only if a developer seeks to implement projects listed in the Environmental Assessment Code of Georgia. This list is compatible with the category A projects of the Bank classification. According to the Georgian legislation EIA is not required in other instances, while Asian Development Bank requires limited EIA or IEE for the B category projects, and an environmental review of projects that are not expected to produce environmental impacts (category C).

3 For development area covering less than 10 ha of land

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Georgian legislation does not specify the format of Environmental Management Plans (EMPs) and the stage of their provision for projects requiring EIA and does not require EMPs for projects not requiring EIAs. The Asian Development Bank Guidelines described the requirements for preparation of EMP for all categories of projects and provides detailed instructions on the content. According to Georgian legislation MEPA is responsible for monitoring of project implementation and compliance with the standards and commitments provided in the EIA, and the role of the EMP is less clearly defined. The PIU or “Project Proponent” is responsible for implementing “self-monitoring” programs for projects requiring EIA. In contrast ADB guidelines stress the role of EMPs, which are important for all categories of projects, and the Project Proponent (in our case – “White Square”) is required to ensure inclusion of a monitoring scheme and plans into EMPs. Monitoring of performance compliance against EMPs is important element of ADB requirements. The national legislation also does not take into account the issue of involuntary resettlement at any stage of environmental permit issuance. The Georgian legislation considers social factors only in regard to life and health safety (e.g. if a project contains a risk of triggering landslide, or emission/discharge of harmful substances or any other anthropogenic impact). The ADB establishes the responsibility for conducting the Initial Environmental Examination (IEE), while the national legislation for the type of project does not provide any responsibilities of a Project Proponent for preparation of the Environmental Impact Assessment (EIA) and to ensure public consultations. The role of the MEPA is restricted to participation in EIA consultation and carrying out state ecological examination required for the adoption of a decision on issuing an EIA permit as established under the legislation of Georgia. Under ADB regulations ADB carries out project screening and categorization at the earliest stage of project preparation when sufficient information is available for this purpose, also according ADB’s Access to Information Policy 2018, ADB is committed to working with the borrower/client to ensure that relevant information (whether positive or negative) about social and environmental safeguard issues is made available in a timely manner. 3.4 National legislation and ADB requirements harmonisation In order to comply with both regulations – the ADB and Georgian legislation – the content of the IEE should comprise issues required in both, thus

Page 26 of 204 complementing each other with focus on more stringent requirements. The EMP should therefore be elaborated in detail, as required by the ADB regulations.

4. DESCRIPTION OF THE PROJECT 4.1 Type of the project “White Square” LLC, the commercial brand name for the Company, is 100% owned by “M2 Group” LLC, (“M2 Group”) which is wholly owned by “Georgia Capital” PLC (Geo Capital of GCAP) listed in the London Stock Exchange, through JSC “Georgia Real Estate” (GRE). “White Square” LLC is responsible for the overall completion of the project which comprises development of two residential areas. “BK Construction” LLC is the construction contractor of the Company

Figure 4.1 – Company structure

Georgia Capital (GCAP) PLC

JSC Georgia Real Estate

M2 Group LLC

Optima LLC (White Square)

BK Construction LLC

The Company project areas - “Mirtskhulava” and “Chkondideli”, are located in Didube and Nadzaladevi districts of Tbilisi respectively, on the streets with the same respective names, which are both heavily settled residential area.

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Project covers a 10-residential-building development at “Mirtskhulava” and 12- residential-building development at “Chkondideli” project site. The Company project management office reported that the overall Project at both project sites is expected to be completed in 2023.

Figure 4.1 – “Mirtskhulava” and “Chkondideli” project site’s locations

Figure 4.2 – “Mirtskhulava” site – project aerial plot plan

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Figure 4.3 – “Chkondideli” site – project aerial plot plan

The Project will provide 1,667 apartments at “Mirstkhulava” and 905 apartments at “Chkondideli” site. The construction area covers up to 205,289 m² at “Mirtskhulava” and 136,722 m² at “Chkondideli”. 4.2 Need of the project The development project described within this IEE was originally initiated in 2016 by the “Sveti Group” Ltd., “Sveti Development” Ltd., “Sveti Nutsubidze” Ltd (“joint owners”), however due to the inability to complete the project, it was transferred to the Company in 2018. Following intervention by the Tbilisi Municipality and “M2 Group” in 2019, development of the three complexes was revived. The project’s implementation was re-initiated in 2020 and is currently planned to be completed in 2023. After conducting due diligence and agreeing a plan with all stakeholders (including additional floor space in these projects - to make them economically viable projects), a Memorandum of Understanding (MoU) was signed in September 2019 between Tbilisi Municipality and “M2 Group”, under which the unencumbered title to the land and all the project development rights were transferred from “Sveti” to the Company.

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Construction of the housing complexes resumed in 2Q 2020 and is expected to be completed by 2Q 2023 by “BK Construction” LLC (“BK Construction”), a leading Georgian construction company with over 27 years of experience. “BK Construction” was acquired in 2017 by “M2 Group”, however due to the latest 2021 changes it was separated from “M2 Group” and is currently operating as independent construction contractor.

The Project offers affordable, cost-efficient apartments in “white finishing” condition. This is above local market standards, where most apartments are sold under “black frame”, being left with cement finishing - without plumbing or electric system. Pre-sales of the apartments started in May 2020, and 14,044 sqm have already been sold (11% of the aggregate sellable area) as of 15 October 2020. Both housing complexes will cater to low/low-middle income populations as they are in blue-collar neighbourhoods – with old-styled Soviet-blocks, trading warehouses, and near railway stations. The complexes will include common areas including green areas, basketball courts and commercial spaces, which are rare in Tbilisi. Available detail regarding the two housing development project sites in “Chkondideli” and “Mirtskhulava” are summarized in the table below. Table 4.1 – Summary of the project Project sites Location Buildable No of Sellable area area (m²)4 buildings (m²)

“Mirtskhulava” Alio Mirtskhulava 205,289 10 91,630 (1,667 site street, Didube district, apartments) Tbilisi, Georgia

“Chkondideli” Giorgi Chkondideli 136,722 12 49,697 (905 site street, Didube district, apartments) Tbilisi, Georgia

ADB is considering provision of a secured loan to the Company to partially finance the construction and finalization of the “Chkondideli” and

4 Including all buildings’ all apartments and surrounding space such as parking lots, common areas within the buildings etc.

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“Mirtskhulava” housing complexes. In connection with the potential financing of the Project and to ensure the Company meets ADB’s safeguards and social requirements, the Company commissioned Paragon Ltd (the Consultant) to undertake the Environmental and Social Due Diligence and develop the Initial Environmental Examination (IEE) in February – April 2021.The IEE, is supplemented with an Environmental and Social Compliance Audit (ESCA) for existing facilities. 4.3 Location Both construction sites of the two housing developments are located within the area of Tbilisi in Didube and Nadzaladevi districts, which are dense residential areas. Tbilisi is traditionally mixed cultures area with no ethnic minority dominated communities. No naturally protected areas, buffer zones of protected areas, wetlands, mangrove, estuarine, or cultural heritage are identified in the vicinity of the project sites’ areas. “Mirtskhulava” site is located in Didube district, on Alio Mirtskhulava Street - between the left bank of the river Mtkvari and Tsereteli Avenue, 800 m from the Didube subway station. The area has a good location in terms of traffic. Due to the location, it is easy to get to the main transport highways and consequently to other areas of the city in a short time.

“Chkondideli” site is located in Nadzaladevi district, on Giorgi Chkondideli Street, 600 m from the Gotsiridze subway station. Due to the location of the area, it is easy to get to the main transport highways and consequently to other areas of the city in a short time as well.

Figure 4.3 – Project Location “Mirtskhulava” project site

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Figure 4.4 – Project Location “Chkondideli” project site

Figure 4.5 – Projects’ Locations – “Mirtskhulava” and “Chkondideli” – projects sites areal

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4. 4 Project description 4.4.1 “Mirtskhulava” The development area of the “Mirtskhulava” project site covers 25,365 m² of land. According to the submitted project, the open space of the facility is 12,500 m². Out of the overall open space 5,500 m² is designated for development of internal yards and green zones. Remaining 7,000 m² of open areas will be used for development of open parking, internal roads, and playground.

In total “Mirstkhulava” projects site employs 98 Contractor labourers. Power supply to the site is provide by the contracted “Telasi” company. Water supply to the site is provided by the contracted “Georgia Water and Powers” company. The labour force does not require project specific workers’ accommodation as all workers are either permanently or temporarily resident in Tbilisi.

The “Mirtskhulava” project site includes 10 buildings with different floors, namely the storeys are distributed as follows:

Building I – 14 floors Building II – 16 floors Building III – 16 floors Page 33 of 204

Building IV – 14 floors Building V – 19 floors Building VI – 24 floors Building VII – 25 floors Building VIII – 19 floors Building IX – 25 floors Building X – 23 floors A total of 2,160 apartments are designed in the area (from 40 m² to 150 m²) out of which 1,667 apartments are sellable by the Company while the remainder 493 apartments to be transferred to the original customers of the previous projects development company “Sveti” as part of the legacy agreement. 303 underground parking, 177 overground parking (for common use) and one playground will be developed. The charging stations for electrical vehicles is planned to be installed at open areas of the site. A 25 cm ytong blocks will be used on the external perimeter of the buildings. Ytong blocks are four times lighter than the cement blocks. They are characterized by high fire resistance and good thermal insulators (46% higher energy efficiency) and noise isolation features. 5 cm thermal insulation layer is also considered for the buildings’ external perimeter. Partitions separating neighbours will be constructed with a 20 cm ytong block. A 10 cm ytong block will be used for the interior partitions of the flats. The complex will be equipped with a generator that will ensure the operation of fire safety systems, drinking water pumps and elevators in emergency mode. It also provides evacuation and emergency lighting for parking lots, corridors, public spaces and inner courtyards. Fire hydrants will also be installed in the yard. At least one elevator of each building's entrance will be adapted for people with disabilities. The space connecting the entrance and stairwell of all buildings will be separated by fire doors. Fire hoses will be installed in all stairwells, which will be connected to a hydrant in the yard. In the parking zones, which do not have natural ventilation, ventilation devices are provided, which are intended for work in both, normal and fire mode and in a such parking zone, an auto-spray system will also be arranged.

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Fire detectors and fire alarms will be installed on common areas of every floor. The halls will be equipped with smoke ventilation shafts, which will be activated in case of fire. The buildings will be equipped with fire hydrants and fire extinguishers. At the time of site visit, construction activities covering 7 residential buildings were under construction while 3 buildings’ construction and the landscaped areas and playgrounds were not initiated. The status of construction progress is following:

• Buildings 1, 2, 3 and 4 – The structural frame construction is completed; • Buildings 5 and 8 – Construction is in progress; • Building 6 – The foundation of building is completed, and the construction works will start in nearest future; • Building 7 – Preparation for foundation works is in progress; and • Buildings 9 and 10 – Demolition works of existing infrastructure to be completed prior the construction activities started. The project management office reported that the overall Project at both “Mirtskhulava” and “Chkondideli” project sites is expected to be completed in 2023. 4.4.2 “Chkondideli” The development area of the “Chkondideli” project site covers 31,011 m² of land. According to the submitted project, the open space of the facility is 12,400 m². Out of the overall open space 4,400 m² is designated for development of internal yards and green zones. Remaining 8,000 m² of open areas will be used for development of open parking, internal roads and playgrounds.

In total “Chkondideli” projects site employs 50 Contractor labourers all of whom are either permanently or temporarily resident in Tbilisi and therefore not requiring project specific worker accommodation. Power supply to the site is provide by the contracted “Telasi” company. Water supply to the site is provided by the contracted “Georgia Water and Powers” company. The “Chkondideli” project site includes 10 buildings with different floors, namely the storeys are distributed as follows:

Building I – 9 floors Building II – 9 floors

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Building III – 10 floors Building IV – 10 floors Building V – 10 floors Building VI – 10 floors Building VII – 10 floors Building VIII – 10 floors Building IX – 10 floors Building X – 10 floors Building XI –25 floors Building XII – 25 floors A total of 1,547 apartments are designed in the area (from 40 m² to 150 m²) out of which 905 apartments are sellable by the Company while the remainder 642 apartments to be transferred to the original customers of the previous project’s development company “Sveti” as part of the legacy agreement. 168 underground parking spaces, 302 overground parking spaces (for common use) and one playground will be developed. The charging stations for electrical vehicles are planned to be installed at open areas of the site. Out of total apartments, 35 apartments are currently occupied by owners or owner representatives, and 4 apartments have been modified to prepare for occupation. A 25 cm, 20 cm and 10 cm ytong blocks will be used for external perimeter, partitions separating neighbours, and interior partitions of flats accordingly. The only exceptions are Buildings I and II, the construction of which is almost completed by “Sveti”, and Buildings 3, 4 and 5, most of which have already been constructed and will be finished with previously used materials. The complex will be equipped with a generator that will ensure the operation of fire safety systems, drinking water pumps and elevators in emergency mode. It also provides evacuation and emergency lighting for parking lots, corridors, public spaces and inner courtyards. Fire hydrants will also be installed in the yard. At least one elevator of each building's entrance will be adapted for people with disabilities.

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The space connecting the entrance and stairwell of all buildings will be separated by fire doors. Fire hoses will be installed in all stairwells, which will be connected to a hydrant in the yard. In the parking zones, which do not have natural ventilation, ventilation devices are provided, which are intended for work in both, normal and fire mode and in a such parking zone, an auto-spray system will also be arranged. Fire detectors and fire alarms will be installed on common areas of every floor. The halls will be equipped with smoke ventilation shafts, which will be activated in case of fire. The buildings will be equipped with fire hydrants and fire extinguishers. At the time of site visit, construction activities covering 11 residential buildings were ongoing while 1 building construction and the landscaped areas and playgrounds were not initiated. The status of construction progress is following:

• Buildings 1 and 2 – Internal works completed. One elevator to be installed in Building 2. External works almost completed. Area to be cleaned up from construction waste, car parking access to be developed for both buildings and the landscaping works to be completed; • Buildings 3, 4 and 5 – One additional floor to be developed for each building. Common spaces, external façade works and installation of the communication utilities to be completed; • Buildings 6, 7, 8, 9, 10 and 11 – Are under construction; and • Building 12 – Construction area clearance works completed. Foundation works will start at nearest future. The project management office reported that the overall Project is expected to be completed in 2023. 4.5 Operation activities Operation activities of the projects are not in the scope of this Initial Environmental Examination due to the nature of the project i.e., constructed buildings to be transferred under the ownership of the customers for use as the residential premises. The maintenance and upkeep of all the buildings and common areas will be transferred to the homeowners.

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5. DESCRIPTION OF THE ENVIRONMENT (BASELINE DATA) 5.1 Physical resources This section describes relevant physical, biological, and socio-economic conditions of the country and city where relevant and within and immediately adjacent to the Project sites. Baseline data for the Project area was collected using the combined approach of desktop studies and the Project site visits. The desktop study includes the data available on internet, previous similar reports approved for utilization and scientific evidence as well as the documented evidences provided by the client. The Project site visits were completed in March 2021 with the purpose to supplement and verify the existing data or obtain data where no previous information is available. The baseline monitoring for noise and Ambient Air Quality (dust) parameters was completed by certified laboratory “DG Consulting”. The following components were focused on for the purposes of this study: o Air/Noise Environment (climate, ambient air quality and noise levels) o Land Environment (topography, geology, hydrogeology) o Ecological Environment (flora, fauna and protected areas) o Socio‐Economic Environment (demographic profile, occupational structure, Educational status, economic development, labour market, etc.) 5.1.1 Atmosphere Tbilisi is located in the South Caucasus at 41° 43' North and 44° 47' East Longitude. The city is situated in East Georgia on both banks of the Mtkvari River. The elevation of the city ranges from 380‐770 meters above sea level (m.a.s.l.) and possesses the shape of an amphitheatre surrounded by mountains on three sides. The climate is influenced by geographic location, complicated terrain, radiation regime and circulation processes dominated in the atmosphere. The climate of Tbilisi is transitory from moderate continental to a moderate humid subtropical. The city's climate is influenced both by dry (Central Asian/Siberian) air masses from the east and humid subtropical (Atlantic/Black Sea) air masses from the west. Tbilisi experiences relatively cold winters and hot summers. The geographical proximity to large bodies of water (Black and Caspian Seas) and the fact that the Greater Caucasus Mountain Range blocks the intrusion of

Page 38 of 204 cold air masses from North, determines that Tbilisi has a relatively mild micro‐ climate compared to other cities along the same latitudes. Precipitation of the area is in the range of 520 mm per year. The highest rainfall months are May and June (90 mm), while the light rainfall is January (20 mm). Precipitation in the form of snow can come on average 15-25 days a year. Average annual temperature in Tbilisi is 12.7°C. The coldest month of the year is January with average temperature 0.9°C. The hottest month is July with average temperature 24.4°C. Absolute minimum temperature is - 23°C, absolute maximum 40°C. North and north-west winds prevail, south-east winds are also frequent.

Figure 5.1 – Climate map of Georgia

The nearest weather station from “Mirtskhulava” and “Chkondideli” project sites located in Vashlijvari district 1 km from “Mirtskhulava” and 2.2 km from “Chkondideli” sites. Figure 5.2 and Table 5.1 presenting 2018-2020 wind and temperature data measured by above mentioned station.

Figure 5.2 – Wind speed and wind directions

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Table 5.1 – Average monthly and annual temperatures 5 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Daytime Max 14 21 25 27 32 37 40 37 32 29 26 18 28

Daytime Average 5 7 11 14 22 27 29 27 24 19 10 6 17

Daytime Min -6 -7 0 0 8 15 15 16 14 9 -1 -1 5

Night-time Max 11 11 18 21 25 29 32 30 27 23 18 15 22

Night-time Average 3 5 8 11 17 22 24 23 20 15 7 4 13

Night-time Min -5 -6 0 0 8 13 12 15 9 6 0 -2 4

5 In addition, it presents the average minimum and maximum, both monthly and annual temperatures.

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5.1.2 Ambient Air Quality The National Environmental Agency (NEA) which is a subordinate organization of the Ministry of Environmental Protection and Agriculture (MEPA) is responsible for monitoring the state of ambient air quality in Tbilisi. The air quality monitoring stations exist in this area of Tbilisi, with one of them located in Didube district so the air quality data is available for the project impacted area. The concentrations of various parameters are measured in ambient air among them particulate matter, carbon monoxide (CO), nitrogen dioxide (NO₂), sulphur dioxide (SO₂), lead (Pb) and ground level ozone. For the purposes of the IEE the relevant parameters data is provided in the table below.

Table 5.2 – Tbilisi, Didube and Nadzaladevi district air quality data Tbilisi 2019 air quality monitoring results annual average (µg/m³) Monitoring Distance from Distance from station PM₁₀ PM₂.₅ Mirtskhulava (km) Chkondideli (km) Tsereteli Ave 49 24 0.7 0.9 Kazbegi ave 37 17 2.7 3.5 Gelovani ave 35 19 1 2.2 Varketili 3 39 20 10.1 8.5

According to the visual audit results, no stationary sources contributing to ambient air contamination are located within the study area. The quality of the ambient air in the study area may be affected by exhaust gases produced by the vehicles moving along the city roads, however Project activities are in general affecting dust pollution around the Project area. The dust concentration is subject to World Health Organization (WHO) standards, which are also referenced by International Finance Organization (IFC). In addition to that the Environmental Quality Condition Normative, Technical Regulation N 297/N addition 38/N is available in Georgia, however listing air quality standards per specific chemical composition rather than Particulate Matter size, therefore WHO standards are considered to be applicable for the purposes of the monitoring.

Table 5.3 – IFC/WHO Air Quality standards

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Parameter Averaging Period Guideline Value in (µg/m³)

Particulate Matter PM ₁₀ 1 year 70 (Interim target-1) 50 (Interim target-2) 30 (Interim target-3) 20 (guideline)

24 hours 150 (Interim target-1) 100 (Interim target-2) 75 (Interim target-3) 50 (guideline)

Particulate Matter PM ₂.₅ 1 year 35 (Interim target-1) 25 (Interim target-2) 15 (Interim target-3) 10 (guideline)

24 hours 75 (Interim target-1) 50 (Interim target-2) 37.5 (Interim target-3) 25 (guideline)

According to the above table the dust baseline monitoring to be conducted on the 24-hours averaging period applicable standards.

Figure 5.3 – “Mirstkhulava” project site dust monitoring locations

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“Mirstkhulava” project site dust monitoring point No1 is located on Mirtskhulava street at a distance of 20 m from main project site entrance at the south boundary of the project site perimeter across the street from the site where the nearest residential building is located. Monitoring point No2 is located on Mirtskhulava street at a distance of 20 m from the building to be demolished at the south-east boundary of the site next to the residential building located across the street.

Figure 5.4 – “Chkondideli” dust monitoring location

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“Chkondideli” project site dust monitoring point No1 is located at a distance of 20 m from north-west boundary of the project site perimeter where the nearest residential building is located. Monitoring point No2 is located at a distance of 10 m from the south-east boundary of the site next to the two residential buildings.

5.1.2.1 Dust Monitoring Duration During the baseline monitoring field activities implementation night activities were restricted by pandemic related governmental regulations with curfew established for the timeframe of 9 pm – 5 am. The projects’ working hours are set for the specific timeframe from 9 am to 6 pm. Therefore, points of interest for monitoring is the timeframe when construction activities will be undertaken in future. The proposed methodology includes 3 short term (60 min) measurements at all monitoring locations. The Average values for all three measurements are considered to be an average 24-hour value. 5.1.2.2 Dust Monitoring Equipment and Monitoring Methodology During monitoring activities consultant’s field team used dust monitoring tool Dust Trak DRX Desktop aerosol monitor – 8533. This equipment simultaneously allows the measurement of the PM₁₀ and PM₂.₅. All collected data is logged in the software for further analyses and interpretation and is appended to this report as Appendix 12.2.

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To collect representative samples, monitoring was undertaken in dry weather conditions. Site management to ensure that all site activities are shut down during the monitoring period. The interpretive air monitoring report is developed based on the measurements obtained. Figure 5.5 – Dust monitoring equipment

Baseline data for dust generation has been collected by the “Paragon” Ltd as part of the preparation for the Initial Environmental Examination sampling program. 5.1.2.3 Baseline dust monitoring results Mirtskhulava project site During the weekday, the dust concentration levels were not high, and all values measured are within the acceptable levels defined by the monitoring methodology. The highest level was detected at the monitoring point #1 in session 3 and the Monitoring point 2 during the session 1 and 2.

Table 5.3 – The Results of dust monitoring at “Mirtskhulava” project site - Weekday

Session Session PM total, PM₁₀, PM₂.₅, “Mirtskhulava” - weekday Start End µg/m3 µg/m3 µg/m3 Point 1

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Session 1 25/03/2021 11:30 12:30 Minimum 4 4 4 Maximum 107 107 102 Average 15 15 14 Session 2 25/03/2021 13:40 14:40 Minimum 5 5 5 Maximum 54 54 52 Average 15 15 15 Session 3 25/03/2021 16:10 17:10 Minimum 19 19 19 Maximum 772 772 770 Average 37 37 37 Average for the Point 22.3 22.3 22 Point 2 Session 1 25/03/2021 12:35 13:35 Minimum 18 18 18 Maximum 772 772 770 Average 37 37 37 Session 2 25/03/2021 13:40 14:40 Minimum 19 19 19 Maximum 772 772 770 Average 37 37 37 Session 3 25/03/2021 17:15 18:15 Minimum 10 10 10 Maximum 177 177 167 Average 27 27 26 Average for the Point 33.7 33.7 33.3

The results recorded during the weekend are similar to the monitoring results recorded during the working day and do not exceed the project specified limit values.

Table 5.4 – The Results of dust monitoring at “Mirtskhulava” project site - Weekend (Non-Working Day)

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Session Session PM total, PM₁₀, PM₂.₅, “Mirtskhulava” - weekend Start End µg/m3 µg/m3 µg/m3 Point 1 Session 1 27/03/2021 10:27 11:27 Minimum 13 13 12 Maximum 146 146 140 Average 23 23 23 Session 2 27/03/2021 12:45 13:45 Minimum 9 9 9 Maximum 158 158 141 Average 19 19 19 Session 3 27/03/2021 15:02 16:02 Minimum 12 12 12 Maximum 402 402 401 Average 31 31 30 Average for the Point 24 24 24 Point 2 Session 1 27/03/2021 11:37 12:37 Minimum 8 8 8 Maximum 162 162 147 Average 13 13 13 Session 2 27/03/2021 13:50 14:50 Minimum 13 13 13 Maximum 1310 1310 1280 Average 0.027 0.027 0.026 Session 3 27/03/2021 16:10 17:10 Minimum 11 11 11 Maximum 41 41 41 Average 15 15 15 Average for the Point 18 18 18

Chkondideli project site

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During the weekday, the dust concentration levels were practically at very low level, close to the detection limit of the equipment, accordingly the average values are similar and very close to each other. It can be stated, that there was practically no dust pollution at site during the monitoring sessions.

Table 5.5 – The Results of dust monitoring at “Chkondideli” project site - weekday

Session Session PM total, PM₁₀, PM₂.₅, “Chkondideli” - weekday Start End µg/m3 µg/m3 µg/m3 Point 1 Session 1 22/03/2021 10:00 11:00 Minimum 7 7 7 Maximum 28 28 26 Average 12 12 12 Session 2 22/03/2021 13:00 14:00 Minimum 18 18 18 Maximum 142 142 133 Average 22 22 22 Session 3 22/03/2021 15:55 16:55 Minimum 7 7 7 Maximum 59 59 55 Average 10 10 10 Average for the Point 15 15 15 Point 2 Session 1 22/03/2021 11:15 12:15 Minimum 10 10 10 Maximum 25 25 24 Average 13 13 13 Session 2 22/03/2021 14:05 15:05 Minimum 15 15 15 Maximum 37 37 35 Average 18 18 18 Session 3 Minimum 23/03/2021 16:30 17:30 30 30 30

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Maximum 58 56 56 Average 36 36 36 Average for the Point 22 22 22

The results recorded during the weekend are similar to the monitoring results recorded during the working day and does not exceed the limit values set in by project.

Table 5.6 – The Results of dust monitoring at “Chkondideli” project site - Weekend (Non-Working Day)

Session Session PM total, PM₁₀, PM₂.₅, “Chkondideli” - weekend Start End µg/m3 µg/m3 µg/m3 Point 1 Session 1 28/03/2021 09:30 10:30 Minimum 3 3 3 Maximum 180 180 177 Average 7 7 7 Session 2 28/03/2021 12:30 13:30 Minimum 5 5 5 Maximum 272 272 269 Average 15 15 14 Session 3 28/03/2021 15:25 16:25 Minimum 5 5 5 Maximum 246 246 237 Average 11 11 11 Average for the Point 11 11 11 Point 2 Session 1 28/03/2021 10:40 11:40 Minimum 3 3 3 Maximum 196 196 182 Average 6 6 6 Session 2 28/03/2021 14:20 15:20 Minimum 3 3 3

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Maximum 244 244 235 Average 7 7 7 Session 3 28/03/2021 16:35 17:35 Minimum 5 5 5 Maximum 251 251 238 Average 8 8 8 Average for the Point 7 7 7

Conclusions

Based on the analysis of dust baseline monitoring data PM₁₀ at each monitoring location of both project sites are within WHO Guideline 24-hour average standards (50 µg/m³). However, PM₂.₅ at “Mirtskhulava” project site monitoring point No 2 is slightly higher than WHO Guideline 24-hour average standards (33.3 µg/m³ of actual vs 25 µg/m³ of standard). The latter are still within the interim target 3 = 37.5 µg/m³. Monitoring point No 1 at “Mirtskhulava” projects site and both monitoring points at “Chkondideli” project site are within the WHO Guideline 24-hour average standards. When evaluating the dust concentration results, it should be considered, that the baseline monitoring activities were undertaken when no construction work was conducted on project site. It also should be noted that the baseline monitoring was conducted in March, when humidity was high, and the period, when the monitoring was undertaken had a few rainy days. It is expected that some specific construction activities are anticipated to increase dust concentrations.

5.1.3 Noise Technical Regulation N398 - "On the norms of acoustic noise on the premises of residential buildings and public / public institutions. August 2017 Government of Georgia defines the reference criteria for background noise in and around workplace and residential buildings. It establishes noise thresholds for the daytime evening and nighttime. These threshold values apply to the boundaries of residential areas. The boundary noise level during construction period is exempt from the Georgia Standard of Environment Noise during the daytime (see article 1 section 2)

Page 50 of 204 therefore combination of the IFC Environmental Noise Management Guideline and Georgia Noise Standards (which are at cases more stringent) were utilized with the project applicable standards provided within the table below. Table 5.7 – IFC and Georgian Noise Standards Receptor IFC Noise Georgian Noise Applicable Noise standard standard standard (dBA) (dBA) (dBA) day night day evening night day evening night Residential 55 45 50 45 40 55 45 40

Noise impacts from the project should not contribute to the exceedance the levels presented in Table above or result in a maximum increase in background levels of 3 dBA at the nearest receptor location off-site, whichever is applicable. As determined in result of the audit, no fixed noise sources exist within the Project area. Baseline data for noise level has been collected as part of the preparation of the Initial Environmental Examination.

Figure 5.6 – “Mirstkhulava” project site noise monitoring locations

“Mirstkhulava” project site noise monitoring point No1 is located on Mirtskhulava street at a distance of 20 m from main project site entrance at the south boundary of the project site perimeter across the street from the site where the nearest residential building is located. Monitoring point No2 is

Page 51 of 204 located on Mirtskhulava street at a distance of 20 m from the building to be demolished at the south-east boundary of the site next to the residential building located across the street.

Figure 5.7 – “Chkondideli” project site noise monitoring location

“Chkondideli” project site noise monitoring point No1 is located at a distance of 20 m from north-west boundary of the project site perimeter where the nearest residential building is located. Monitoring point No2 is located at a distance of 10 m from the south-east boundary of the site next to the two residential buildings.

5.1.3.1 Noise Monitoring duration As per IFC 2007 General EHS Guidelines (1.7 Noise), Noise monitoring programs should be designed and conducted by trained specialists. Typical monitoring periods should be sufficient for statistical analysis and may last 48 hours with the use of noise monitors that should be capable of logging data continuously over this time period, or hourly, or more frequently, as appropriate (or else cover differing time periods within several days, including weekday and weekend workdays). Work at the Project sites, as well as any other non-essential night activities, are currently restricted by pandemic related governmental regulations with a curfew established for the timeframe of 9 pm – 5 am. Hence around-the-clock

Page 52 of 204 continuous monitoring would be challenging for completion, while monitoring covering differing time periods within several days, including weekday and weekend workdays is suggested to be conducted during the hours not restricted by the curfew. The projects’ working hours are set for the specific timeframe from 9 am to 6 pm. The expected pick hours in relation with noise in urban area are 9 am – 11 am and 4 pm – 6 pm. Taking that into consideration and from the pandemic constraints described above, the following monitoring scheme was implemented to the project site baseline noise monitoring data collection to assure the measurement obtained is representative of the project activities variations: • Conduct noise monitoring at two points at each project sites during a weekday; • Conduct noise monitoring at two points at each project sites during a weekend; • Ensure the monitoring period of continuous 1-hour measurement will be cover expected peak hours and period between peak hours at all locations (3 sessions of the monitoring with 1-hour duration will be performed at each location). 5.1.3.2 Monitoring Equipment All noise data will be measured using a Rion NL52 integrated sound level meter class 1 and class 1 field calibration Rion NC 74 (Figure 3-1). Figure 5.8 – Noise Meter and Noise Meter Calibrator

5.1.3.3 Monitoring Methodology Noise is defined as unwanted sound. The unit of measurement is the decibel. Readings are taken on a logarithmic scale. This means that 90 dB is ten times the

Page 53 of 204 intensity of 80 dB and a hundred times more than 70dB. A rise of 3 dB is roughly the equivalent of doubling the sound intensity. The effects of excessive noise are hearing impairment, either temporary or permanent, and irritation or annoyance. Loud explosive noises can produce instant and short-term deafness, which could cause permanent damage as can, prolonged exposure. Long exposure can wear people down and effect their ability to function properly. The following noise indices to be measured during the monitoring: • LAeq – the equivalent continuous sound pressure level over the measurement period. • LAmax – the maximum sound pressure level occurring within the defined measurement period. • LAmin – the minimum sound pressure level occurring within the defined measurement period. • LA90 – the sound pressure level exceeded for 90% of the measurement period and is used within BS 4142 as a descriptor of background noise level. • LA10 – the sound pressure level exceeded for 10% of the measurement period. To receive accurate readings, calibration of the equipment is conducted before each measurement. All measurements were taken with a windscreen on the microphone. Minimum 3.5 m distance from monitoring point and any reflective surfaces at all locations to be maintained and the monitoring equipment were set on tripod at minimum 1.5 m high from the ground level. Noise measurements were be undertaken in windy weather conditions (up than 5 m/s). Wind speed was measured by portable meter during whole season of monitoring. Site management to ensure that all site activities are shut down during the monitoring period. All collected data was logged in the software for further analyses and interpretation. The interpretive noise monitoring report is developed based on the measurements obtained 5.1.3.4 Baseline noise monitoring results Mirtskhulava projects site

The Noise pattern on “Mirtskhulava” Street site during the weekday was recorded in a condition when the activities on site were stopped or minimized in such manner that the site noise was not audible at monitoring location. The

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character is similar in all three sessions and is within the range of 60-68 dBA for equivalent noise levels.

Table 5.8 – The results of noise monitoring at “Mirtskulava” projects site - weekday

Date Monitor LA eq Time LAeq. LAma LAmin ing Session Ave. period dBA x dBA dBA point# dBA

11:30 – Session 25/03/2021 66.7 87.6 57.3 12:30 1

13:40 – Session 25/03/2021 Point 1 68.0 87.8 56.9 64.8 14:40 2

16:15 – Session 25/03/2021 59.7 75.3 50.3 17:15 3

12:35 - Session 25/03/2021 67.2 94.8 51.9 13:35 1

14:50 – Session 25/03/2021 Point 2 63.7 87.7 54.0 64.2 15:50 2

17:15 – Session 25/03/2021 61.7 89.6 45.7 18:15 3

During non-working day, at the “Mirtskhulava” Point #1 the noise levels were even higher than during the workday, this should be considered as increased activity of pedestrians and traffic on the street and is not caused by the construction site.

Table 5.9 – The results of dust monitoring at “Mirtskhulava” project site - weekend (Non-working day) Date Monitor Time LAeq. LAma LAmin ing Session LA eq period x dBA point# dBA dBA

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Ave. dBA

9:45 – Session 27/03/2021 68.8 90.1 58.6 10:45 1

12:50 – Session 27/03/2021 Point 1 67.5 93.6 56.8 68.9 13:50 2

15:30 – Session 27/03/2021 70.3 98.3 58.2 16:30 3

10:50 – Session 27/03/2021 63.8 87.2 52.2 11:50 1

13:55 – Session 27/03/2021 Point 2 64.5 93.5 53.9 65.3 14:55 2

16:35 – Session 27/03/2021 67.6 99.9 53.2 17:35 3

Chkondideli project site

The noise monitoring at “Chkondideli” site was undertaken similarly as at “Mirtskhulava” site during the weekday and over the weekends as it was defined by the methodology for the baseline monitoring survey methodology. The summary of monitoring session results is given separately for the working days and over the weekend in the tables below. The activities at working site were stopped or undertaken in the area of construction far away from the monitoring points to ensure that site noise was not audible at the monitoring locations. The character is similar in all three sessions and is within the range of 53-68 dBA for equivalent noise levels. This is mostly related with the noise levels in the dwelling house, and small size car repair shops located in the area. The noise character is with high amplitude change and dropping down within the short periods of time, which is very well visible on the noise graphs presented in the annex of the present report. From the comparison of the noise monitoring data

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during pick-time/non-pick-time and the time when all construction activities were ceased for lunch break and during non-working days, the influence on baseline monitoring from the “Chkondideli” project site is considered as negligible.

Table 5.10 – The results of Monitoring at “Chkondideli” projects site - weekday

Date Monitor Time LAeq. LAmax LAmin LA eq ing Session period dBA point# dBA dBA Ave. dBA

10:05 – Session 22/03/2021 57.7 82.1 43.2 11:05 1

13:00 – Session 22/03/2021 Point 1 57.3 82.9 38.9 58.8 14:00 2

15:55 – Session 22/03/2021 61.3 93.2 45.7 16:55 3

11:15 - Session 22/03/2021 67.1 79.2 42.6 12:15 1

14:05 – Session 22/03/2021 Point 2 62.5 77.9 41.2 60.9 15:05 2

16:30 – Session 23/03/2021 53.0 70.1 39.9 17:30 3

Table 5.11 – The results of Monitoring at “Chkondideli” project site - weekend (Non-working day) Date Monito Time LAeq. LAmax LAmin LA eq ring Session period dBA point# dBA dBA Ave. dBA

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9:30 – Session 28/03/2021 66.2 91.7 43.3 10:30 1

13:15 – Session 28/03/2021 Point 1 61.7 90.5 40.8 59.8 14:15 2

16:25 – Session 28/03/2021 51.4 88.1 39.8 17:25 3

10:40 – Session 28/03/2021 68.8 112.5 42.2 11:40 1

14:20 – Session 28/03/2021 Point 2 60.7 79.0 44.6 60.43 15:20 2

16:35 – Session 28/03/2021 51.8 73.1 41.4 17:35 3

The noise levels at “Chkondideli” is significantly lower than at “Mirtskhulava” street, due to the fact, that the influence of street traffic practically does not exist, and the monitoring points are located far from streets with traffic. From the comparison of the noise monitoring data during pick-time/non-pick time and the time when all construction activities were ceased for lunch break and during non-working days, the influence on baseline monitoring from the “Chkondideli” project site is considered as negligible. Conclusions The baseline monitoring activities were implemented at the closest receptors at “Mirtskhulava” and “Chkondideli” project sites during the workday and over the weekend. The works are started on site, so for the baseline monitoring reasons it was requested to be stopped or minimized to the manual labour with no equipment used (such as general housekeeping) during the monitoring, so the interference of the construction activities on the noise levels recorded was non- existent.

The Noise levels are higher at “Mirtskhulava” project site, which is mostly caused by the vehicular traffic on the public road located between the construction site and the closest receptors.

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At “Chkondideli” project site, the noise levels are lower, the influence of the background noise from the street is significantly less and existing noise is mostly generated by the dwelling houses, pedestrians, cars entering in the closed yard and dead end and small size manufactures and repair shops providing car repair services. To summarize, the Noise levels are already high in both cases and all monitoring sites. All records were around 60 dBA of LAeq level. With implementation of active construction, the levels is anticipated to further increase. 5.1.4 Geomorphology and Geology Tbilisi and its surrounding territory represent mountainous region jagged with ravines in the middle of river Mtkvari flow. Basic orographic lines of relief are connected to north‐east endings of Trialeti ridge, representing significant ring of Small Caucasus mountain system chain. In this mountainous region Tbilisi is located in deep cavity which is elongated from North to South. River Mtkvari divides Tbilisi in two asymmetrical parts. The width of cavity is 3‐4 km at some places, but at Metekhi fortress it gets narrow up to 35‐40 m. Absolute height of plain surface of the studied territory is 504‐540 m, but surrounding ridges’ height is within 534‐768 m absolute elevation areas. The diversity of Tbilisi relief is the result of its geo‐morphological structure. Tbilisi is located between two folded mountain systems, in particular, the foot of an intensely dislocated southern slope of the Central Caucasus in the north and the folded system of Ajara‐ Trialeti in the south. Its tectonomorphic structure means that the topography mirrors the underlying structure, when anticlines6 form ridges, while synclines7 produce depressions. Paleogene‐ Neogene alluvio‐volcanic and terrigenous deposits are covered in many places by thick Quaternary formations. 5.1.5 Seismicity Tbilisi is located in the active seismic zone. Due to this, the development shall be designed and constructed in compliance with the requirements stipulated in the applicable Georgian construction standard Seismic Resistant Construction (PN 01.01-09). The area selected for construction of the project facility is located in the seismic intensity zone 8 (MSK 64 scale), which dimensionless seismic

6 fold of geological formation with swelling or arch (saddle) form directed upward, where the oldest geological deposits are located in the central (nuclear) part 7 synclinal basin, fold of geological formation with depression form (saddle) directed downward

Page 59 of 204 coefficient ‘A’ equals to 0.15 and the “Mirtskhulava” and “Chkondideli” projects permits consider the seismic intensity zones for the projects’ design Figure 5.4 – Seismic Zone Map of Georgia

5.1.6 Soils and fundamental landscapes 8“Within the Republic of Georgia lies the juncture between the Afro-Arabian (Gondwana) and Eurasian plates. The evidence reviewed here suggests that this was an active margin throughout most of the Phanerozoic, although the relationships between the plates during much of the pre-Mesozoic cannot always be clearly defined and hence can only be presented in broad outline. The less deformed and better exposed Jurassic and younger beds provide an opportunity to interpret the tectonic history of the region and to begin to establish eustatic cycles, but their correlation with sequences established in other regions must await more detailed study. Hercynian as well as Cenozoic Alpine collisional events have been proposed. The Mesozoic was marked by the presence of two island arcs, the northern Transcaucasian arc being separated from the Scythian Platform by a shorter- lived basin than that which separated the southern Transcaucasian arc from the Gondwana plate margin. The two arcs were separated by the Black Sea-Caspian Basin which opened for a relatively short period during the late Mesozoic-early Cenozoic.

8 “Geology of the Republic of Georgia: A Review” Shota Adamia et al., July 1992 Page 60 of 204

The coexistence of the relatively undeformed Dizi Series in the southern slopes of the Caucasus and the Hercynian suture under the Main Caucasus as interpreted from the seismic data, suggests that the Hercynian collision may have passed to a transform.” “Mirtskhulava” project site is located at a distance of up to 0.2 km from the left bank of Mtkvari river and is an artificially levelled embankment. The surface is covered with modern technogenic and diluvial alluvial sediments. Geological study of the area demonstrates presence of mid- and high- oligocene age sediments. In addition to that the past-pleocene sediments are also present, which are represented by the diluvial-prolluvial origin and sediments of the first (Didube-Chughureti) terrace. Post-pleocene sediments are vast in the area. These in general consist of diluvian, prolluvian as well as the sdiments of river Mtkvari first terrace.

“Chkondideli” project site is located at 1.5 km from river Mtkvari within the river alluvial second level terrace. Geological study demonstrated the presence of the technogenic soils, mix of clay, sand and gravel, with presence of some construction inert waste. Beneath upper level the diluvial clay semi-solid soils are found. The bottom level of geological study shows alluvial soils. Both Project site, being construction legacy projects and located on historically industrial area are lacking fertile topsoil, hence no topsoil management is required at either of those. 5.1.7 Surface water and groundwater Georgia is rich in water resources; there are in all 26,060 rivers with a total length of ~ 59,000 km. Besides, there are many thermal and mineral water springs, lakes and man-made water reservoirs. These however are distributed unequally, with major concentration in the western part of the country. Nearly all rivers of East Georgia flow into the Caspian Sea while and the rivers in the west join the Black Sea. Tbilisi is located along the Mtkvari river. The river divides the city into two asymmetric parts, with the left side of the city exceeding the right in both territory and population categories. The part of the city which lies on the left bank of the Mtkvari River starts from the Avchala District and extends to River Lochini. The part of the city which lies on the right side of the Mtkvari River is located along the foothills of the Trialeti Range, descending all the way to the edges of the river Mtkvari at most of its parts.

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Based on the groundwater characteristics, Georgia is divided into five hydrogeological zones, which further break down into sub-zones/districts. Project area, Tbilisi is in Zone – Kura-Fold Thrust belt and in hydro-geological district – Tbilisi artesian basin. The depth of groundwater is varying from 3.5 m to 18 m.9 According to the hydrogeological zoning of Georgia, the Project area and its adjacent territory are located within the area with the fissure and fissure‐karst10 waters of Tbilisi artesian basin11. The feeding area of the underground waters of Tbilisi is mostly located beyond the city borders. The relief of the city, in particular, the lithological content of the constituent rocks and their bedding elements, negative humidity balance and other conditions, do not support the feeding of the underground waters. Hydrogeological study of the project sites revealed the significant depth of the ground waters deposits. At “Chkondideli” site ground water was found at a depth of about 14 m with water originating from the atmospheric precipitation filtration. At “Mirtskhulava” site groundwater was found at a depth of 4.3-5.4m with water originating from the groundwater filtration of adjacent slopes. The maximum excavation depth at “Mirstkhulava” project site is up to 4 m, while at “Chkondideli” projects site – up to 5 m. There are no surface water resources at the territories adjacent to the Project site. Distance from the “Mirtskhulava” Project site to the river Mtkvari is up to 0.2 km, while from “Chkondideli” site – 1.5 km. 5.2 Biodiversity Information on biodiversity of the project area is prepared on the basis of the materials given in literary sources and field survey results. Field surveys were conducted in February and March 2021. 5.2.1 Flora Tbilisi is situated in the central floristic region of Transcaucasia. The flora within the Tbilisi areal includes 1,643 species belonging to 623 geni and 107 families and is similar to Eastern Mediterranean, Southwest Asian and Transcaucasian flora.

9 Buachidze I., 1970 10 type of groundwater that circulates in the karst structures (cavities, channels, fissures) formed due to washing out of soluble materials of the rock formations 11 basin of pressurized (confined) groundwater

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Tbilisi environs are featured by phytocoenological diversity. The prevailing wood vegetation species are: Pinus sp., Quercus sp., and Fagus sp., Carpinus sp. There can also be found Acer campestre, Populus sp.. However, due to the urban nature of the environment, ecological values in the project area are quite insignificant. Flora in the project area is negligible and includes some typical urban tree and shrub species: Pinus sp., Larix sp., Aesculus sp., Platanus orientalis, Fraxinus excelsior, Populus sp. As a visual audit has revealed, the project areas are historical industrial sites where the land surface is lacking topsoil and at many places is covered with inert waste. Considering this, only ruderal plants are spread throughout the project area. This section provides the detailed inventory of the flora on the Project area.

Table 5.12 – Flora inventory Mirtskhulava English Latin Total amount Dried Red list Poplar Populus italica 1 1 NA Walnut Juglans regia 3 2 VU Pine Pinus 10 9 NA Mulberry Morus 2 1 NA Ash Fraxinus 1 0 NA Cyprus Cupressus 3 2 NA Lime Tilia caucasica 1 1 NA

Table 5.13 – Flora inventory Chkondideli English Latin Total amount Dried Red List Aspen Populus 7 2 NA Figs Ficus carica 3 0 NA Ailanthus Ailanthus 8 0 NA Vine Vitis 1 0 NA Walnut Juglans regia 2 0 VU Pear Pyrus 1 0 NA American Maple Acer rubrum 1 0 NA Mulberry Morus 5 0 NA Wild cherry Prunus avium 1 1 NA Apricots Prunus armeniaca 3 1 NA Cerry Prunus cerasus 1 1 NA Almond Amygdalus 1 0 NA

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Acacia Acacia 3 0 NA Pine Pinus 1 1 NA Quince Cydonia 1 0 NA Cyprus Cupressus 3 3 NA Pomegranate Punica granatum 1 0 NA

5.2.2 Fauna Considering urban nature of the area, fauna values in the project area is limited to domestic animals. There are, however, several species of birds that can be found such as: o Dwelling birds: Passer domesticus, Turdus merula, Chloris chloris, Turdus viscivorus, Fringilla coelebs; o Hibernating birds: Anas platyrhynchos, Turdus pilaris, Serinus pusillus; o Nestling birds: Coturnix coturnix, Cuculus canoris, Apus apus, Hirundo rustica, Delichon urbica; o Birds of passage: Scolopax rusticola. All the above species are adapted to the urban environment. Vermin such as rats and mice can also be found. Reptiles can sometimes be seen within Tbilisi boarders. The most significant are: Lacerta strigla, Lacerta sacsicolor, Ophisaurus apodus, Natrix tescelata, Vipera lebetina, Emys orbicularis and Testudo graeca (VU – Vulnerable fauna species) are noted. As for amphibians, in Tbilisi environs there could be found Bufo bufo and Rana ridibunda.

In the Mtkvari River and its tributaries, as well as in the number of reservoirs of Tbilisi environs the various kinds of fish are also found: Leuciscus cephalus fauriscus, Varicorhynus capoeta, Barbus cyri, Nemachilus brundti, Silurus glanis, Cobius platirostris cyricus.

None of the species of mammals have been recorded during the visual audit of the project area. The area is near the residential area with no wild animals usually present, though stray animals can sometimes be found around the sites. There are no protected areas in or in the vicinity of the project area. According to the survey results, habitats and species of flora and fauna of high conservation value are not presented in the Project area. No non‐captive, endangered species are expected to be found in the project area, which allows

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the conclusion that fauna values in the project area are very insignificant, as it corresponds to an urban area. 5.3 Natural background radiation In Georgia, the radiation safety issues are regulated by the Laws of Georgia on Health Care, and on Nuclear and Radiation Safety, and the secondary legislation including Radiation Safety Limits (RUN-2000), and Principal Hygienic Standards Applicable to Handling Radioactive Substances and Other Ionizing Radiation Sources. In May 2014, monitoring of the background radiation was carried out in the study area aiming exploration of the background gamma radiation and identification of the possible non-controlled radioactive sources. It should be stated that the natural radiation background in Tbilisi surrounds varies in the range of 10.7 µR/h and has remained generally stable. The radiation monitoring was conducted by NEA (National Environmental Agency) using the dosimeter RADEX intended for determining the background gamma radiation for the area. According to the monthly information bulletins data of 2019 of the National Environmental Agency of Georgia, the average background radiation level for Tbilisi (exposition strength of radiation in the near-ground atmospheric air) was 10.7 mR/hr.

Table 5.14 – Tbilisi monthly and annual radiation Tbilisi monthly and annual radiation mR/hr Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual 10.3 11.1 10.7 10.5 10.5 10.5 10.6 10.8 10.8 10.9 10.9 11 10.7

Radiation monitoring of the project locations is only required during the completion of the Environmental Impact Assessment (EIA), hence for the purposes of the Initial Environmental Examination (IEE), no baseline radiation monitoring has been conducted. 5.4 Socio-cultural resources Construction industry, transport, retail, and telecommunications are core of the economic foundation of Tbilisi with more than half of the products produced in Tbilisi coming on these fields. There is well developed infrastructure in the Project area that includes water supply, power supply, gas supply, communication cables (telephone, internet, cable TV).

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5.4.1 Demography Tbilisi, the capital, and the largest city of Georgia. The territory of Tbilisi occupies 504 km², population number of up to 1.2 million people, population density – 2.3 persons on km². Tbilisi communities have always been multi‐ethnic. The Kurds, Armenians, Jewish, Azeri, Russians, Greek and others have been living side by side with the Georgians. However, massive emigration that occurred in the 1990s after the breakup of the Soviet Union in the past two-three decades resulted in significant reduction of ethnical minorities with Tbilisi ending in a significant increase in Georgian population. Up to 90% of population in Tbilisi are national Georgians. There are representatives of other nationalities in the city, mainly they are Armenians, Azerbaijanis, Kurds and other minorities. The city is divided into six districts: -, Old Tbilisi, Didube-Chughureti Gldani-Nadzaladevi, Vake-Saburtalo, and Didgori. Out of these, five districts are further sub-divided into 30 smaller managerial units also known as “ubani”. The distribution of the population by gender has changed during the past century from a predominantly male population (59.7% in 1897), to, after 1970, a stable and higher percentage of women. There are currently more women than men living in Tbilisi, accounting for almost 55% of the population. This can be explained by the longer life expectancy of women (an average of 81 years in comparison to 73.99 years estimated for Georgia overall), as well as by higher share of men emigrating from Tbilisi 12.

The shifting age‐sex structure of Tbilisi’s population negative impacts is originated by the civil war and ethnic conflicts (1991 - 1993) and the subsequent emigration of portions of the male population. Tbilisi has the biggest population of the internally displaced persons. The percentage of active working population in Tbilisi fluctuates between 52% and 56%. Tbilisi employs 21% of the Georgian labour force; however up to half of unemployed people, registered in the country, reside in Tbilisi. The most significant employers are retail niche (20%), industry (19%), and transport and communications companies (16%). These are followed by the educational and heath care section (12%) and the construction sector (10%).

12 Meladze, 2003 and https://www.cia.gov/library/publications/the‐world‐factbook/geos/gg.html Page 66 of 204

5.4.1.1 Socio-economic analysis The local (Tbilisi) unemployment level is 16.3%. Average salary in Georgia is GEL 1,227 with average salary by gender to be GEL 869 for females and GEL 1,360 for males.13

Populations’ absolute majority has primary and secondary education. Higher education is broadly developed in Tbilisi area with 62% of post-school educational institutions located in Tbilisi (39 colleges and universities). Up to 25,000 students graduate from those annually. In addition to those there 118 professional colleges across Georgia, from which 12,000 students graduate annually. As mentioned above, there are some families (39) that are currently residing in the “Chkondideli” project site incomplete buildings. The residents will need to temporarily relocate while the apartments are completed by the Company. Current residents are all (34 families) moving voluntarily, to which a verbal agreement is already available, while written agreement will be developed and implemented for signature as part of the project’s corrective actions requirements. A sample of written agreement provided as Appendix 5 to this IEE. Below is description on the economic and quality conditions improvements for the current residents of incomplete buildings on “Chkondideli” project site: 1. Security (current situation) - The area currently isn’t fenced and building entrances don’t have any doors, which leads to trespassers. o Trespassers and homeless people take shelter in the empty areas in the buildings o Areas are used as dumping grounds for garbage and feces o Areas attract drug users Security (going forward) - Doors will be installed at each entrance as part of the building rehabilitation

2. HSE – health, environmental, and safety standards are all being neglected due to current condition of buildings. Tenants must deal with serious health and safety concerns daily and it is the Company number one

13 Georgian statistical service “Sakstat” 2020 data Page 67 of 204

priority to mitigate these issues as soon as possible during tenants’ temporary relocation. 3. Utilities (current situation) o Tenants currently don’t have access to wastewater line; there are informally connected to the individual apartments’ electricity and water o Tenants wastewater and garbage is currently being dumped in the underground parking areas and that creates unsanitary conditions o Storm water also gets into the underground parking areas further worsening already unacceptable sanitary conditions o Electricity and water payments are done based on the commercial tariffs which is for electricity - 70% higher and for water - 10 time greater than residential tariff until the building is commissioned Utilities (going forward) o All internal utilities infrastructure for gas, water, wastewater, electricity will be constructed/updated by the Company and then officially be connected to utility company’s infrastructure o Tenants will all be registered with utility companies and will pay the residential tariffs (instead of commercial tariffs)

4. Infrastructure (Current situation) o Following infrastructure elements are currently missing • Roof is missing and/or damaged leading to rainwater leaking into the building • Building façade is incomplete leading to materials falling from the building onto the street • Façade hydro and heat isolation isn’t done at this stage; therefore, tenants must deal with the weather affect • Rails on balconies and stairwells aren’t installed, leading to serious safety concerns • Fire safety provisions aren’t available anywhere in the building, leading to serious safety concerns

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• Lifts are not installed, and shafts are currently open, leading to serious safety concerns • Doors aren’t installed at the entrances, therefore security is currently an issue • Ventilation system isn’t available in the apartments, leading to tenant’s serious health concerns • Utility infrastructure system and proper equipment storage spaces aren’t available • Access to parking area isn’t constructed leading to series falling/safety hazard • Outdoor spaces infrastructure and landscaping isn’t available Infrastructure (Going forward) - All the above-mentioned issue will be addressed and corrected while the tenants are temporarily relocated 5. Commercial Tariffs x Average Consumption per family (water/sewage + electricity) – subsidies for residents o Electricity 800kw * 0.33 = 264 GEL (per family) – commercial o Electricity 800kw * 0.19 = 152 GEL (per family) – residential o Monthly averaged utility saving per family – 112 GEL o Water 24 m³/month * 6 GEL = 144 GEL (per family) – commercial o Water 24 m³/month * 0.5 GEL = 12 GEL (per family) – residential

6. Treatment of wastewater discharge – current wastewater which currently flows into parking structures is being cleaned/pumped every week. Which is 1,000GEL per visit service

There are no residents in the buildings to be demolished at “Mirtskhulava” project site, only users renting the commercial premises. The existing agreement allows the Company to provide them a notice to vacate with the details provided below.

On 27th of August 2019, “Sveti Group” Ltd., “Sveti Development” Ltd., “Sveti Nutsubidze” Ltd (“joint owners”), “Sveti Transfers” (hereinafter “Seller”) and “M2 Vake” (presently the Company – “buyer”) placed the purchase agreement, according to which the joint owners, among other conditions’ fulfilment, shall

Page 69 of 204 transfer property under their ownership in legally and materially flowless condition to the seller (point “b” of the agreement’s “Pre-conditions” addendum point 3). Thereafter the property was to be transferred from the seller under the ownership of the buyer considering fulfilment of all pre-conditions the buyer undertook as an obligation from the existing owners under the contract. Based on the purchase agreement of 27th of August 2019, the agreement on “Mirtskhulava” project site was signed on 30th of August 2019 among “Sveti Development” Ltd., company “Geomeridian” (former owner of the property presently renting the premises for use as commercial areas), “Sveti Transfer” Ltd and “M2 Vake” (presently the Company), which reflects the pre-conditions fulfilment by “Geomeridian” similar to those they had towards the “Sveti Development” Ltd. Based on the above, the property transferred to the ownership of the Company, including project site located at “Mirtskhulava” street, should have been in legally and materially flawless condition that in turn precludes any legal presence of the third-party representatives. 5.4.1.2 Gender analysis The local (Tbilisi) gender analysis has been conducted as part of the development of this IEE. The relevant legislative analysis as well as the data from National Statistics department of Georgia and “Georgia country Gender Assessment” 2018 conducted by ADB. Throughout the last 20 years, Georgia achieved significant progressive changes in gender equality. Georgia continues to strive for development of the socio- economic aspects and advancing women and gender equality is crucial for it. To achieve the promotion of the equal economic, social, and political participation of women and men it is required to continue efforts in this direction. Women’s contribution to the development and well-being of the society is an integral part of the overall process, recognised by the Government of Georgia, public and private sectors. There is a notable gap between the numbers of boys and girls in Georgia, leading to a worrisome situation of “missing girls.” In 2018, there were 108 boys for every 100 girls for children aged 0–4. The gap has narrowed since 2013, when there were 112 boys for every 100 girls in this age-group. This difference is more prevalent in rural regions, where the average sex ratio gap in 2005–2013 was

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113.4, compared to 109.5 in urban areas. The gap is also much higher in regions with a high proportion of ethnic minority population There is parity in school enrolment rates in Georgia for both boys and girls at both primary and secondary levels. This translates into high national literacy rates, which are nearly 100% for both women and men. However, figures indicate that around a quarter of boys and girls do not attend primary school, particularly children in disadvantaged and marginalized groups. A slightly higher number of boys (91%) of the relevant age group progress to secondary school than girls (89%). Gender norms and perceptions also strongly influence the curriculum and the choice of subjects for specialist study. Over 80% of students of arts and humanities, and 70% focusing on health at tertiary level are female; while only around 30% of women are studying engineering, manufacturing, and construction, with less than a quarter enrolled in agriculture courses.

Figure 5.5 – Higher education by gender

Official figures from the National Statistics Office of Georgia indicate the participation of women ages 15 and over in the formal labour market is lower than that of men: in 2012–2015, around 46% of women were employed compared with 53% of men. Among younger women, the discrepancy is significantly higher—in 2014, only 19% of women ages between 15 and 34 were employed, compared with 35% of men.

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Figure 5.6 – Average monthly income by gender

Occupations are strongly segregated by gender, with a much higher share of men in stereotypically male professions such as engineering, construction, energy, transport and communications, and gas and water supply. The majority of women are employed in jobs with a caring or service aspect. Women account for around 75% of employees in the healthcare and social sectors, 60% of those working in the hospitality sector, and 84% of schoolteachers. Less than 10% of women work in construction, while 23% are employed in transport and communications. Many women also work in the informal sector and in unpaid subsistence farm work. Farm work undertaken by women includes managing crops and livestock, dairy production, and processing. A UN Women study found that, on average, women engage in agricultural work 80 days per year more than men.72 However, this work often goes unrecognized and is undervalued because it is not remunerated, forming part of the unpaid care work women are expected to

Page 72 of 204 take on. Georgia’s women are also engaged in other informal sector jobs, such as domestic work, where they do not have the protection of formal labour laws and consequently face many potential risks, including unsafe work conditions and violence. Even within these female-dominated sectors, women rarely occupy executive, upper management, or other decision-making positions and have fewer opportunities for promotion and career advancement. Men generally own and manage farms. According to official statistics, men head 70% of farms, while only 30% of women are farm owners or managers— and the figure is much lower for women under the age of 60.74

Figure 5.7 – Unemployment rate by gender

The percentage of female employees within the construction sector in Georgia is traditionally quite low – average of 15% of all construction sector employees. The gender analysis of the Company and the Contractor employees demonstrated 17.3% of office-based staff are female employees, with the Company this percentage being over 48% with almost half females holding managerial positions. While, from the nature of the project being mail-biased with site-based employees are mostly male, the employees tagged “office- based” with significant percentage of females, are also conducting frequent site visits for various construction related activities. This shows some improvement

Page 73 of 204 of gender balance within the construction sector comparing with country average. In addition to the above, the conducted analysis allows the consideration of the project for the category of “Some Gender Elements” of the Guidelines for gender mainstreaming categories of ADB projects.

5.4.2 Medical Outpatient facilities The core of the primary health care system in Tbilisi is made up from polyclinics, dispensaries, health centres, female consultation clinics, doctor ambulatories and hospitals (in‐patient healthcare), both private and public. Some of the health care facilities are located close to the Project area and are seen on the map below.

Figure 5.6 – Health care facilities around Project area

5. 4.3 Educational institutions Georgia’s education system is structured in the following way: o Non-compulsory preschool education (2 years), o Compulsory education (9 years: 6 years for primary education and 3 years for lower‐secondary education), o Upper secondary (3 years),

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o Tertiary education (4 years for Bachelor’s degree and 2 years for Masters‐ level education). Due partly to migration and partly to declining fertility rates, the population of Georgia has been decreasing in recent years, which also explains a noticeable drop for the education system in general but increase in a better-quality educational institution. The number of people that have completed secondary and university education has also consistently increased for the last several decades; this has resulted in a high share of residents with secondary and university degrees, and in a highly educated supply on the labour market.

Figure 5.7 – Educational institutions at “Mirtskhulava” project site

Figure 5.8 – Educational institutions at “Chkondideli” project site

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5. 4.4 Agriculture There are no agricultural locations within the city of Tbilisi. 5.4.5 Motorways There are three types of automobile roads in Georgia, international, state and local, with Tbilisi roads falling under the latter category. The total length of roads and motorways of Tbilisi is 1200 km. Below figures provide the visual understanding of the roads surrounding “Mirtskhulava” and “Chkondideli” project sites.

Figure 5.9 – “Mirtskhulava” project site surrounding roads

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Figure 5.10 – “Chkondideli” project site surrounding roads

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Traffic survey has been conducted by Paragon Ltd. in order to identify existing traffic load on Mirtskhulava and Chkondideli streets and identify whether the increased heavy machinery movement will affect the current load. Monitoring locations were chosen close to construction sites main entrances. Monitoring was conducted during the weekday and weekend at each site. Monitoring period covered morning and evening peaks and the period between peak times at both sites. Duration of monitoring was 1hr for each session. The methodology of monitoring was simple counting the traffic at monitoring location including the light cars, trucks, busses and pedestrians.

Mirtskhulava street is two-way road with one line on both directions. It’s location in close vicinity of “Eliava Market”- construction materials market, plays the significant role on road traffic load especially during the week ends.

Table 5.15 – Traffic survey “Mirtskhulava” project site Date Time Duration Cars Trucks Buses Pedestrians 10:10 696 25 0 288 23.03.21 11:45 711 21 0 97 18:25 819 16 0 179 60 min 10:25 709 19 0 87 27.03.21 15:35 651 17 0 126 18:15 970 12 0 148

According to project specifications, about 39,000 m³ concrete will be delivered on site in 2021-2022 period, for about 600 days. In addition, about 50,000 m³ of demolition waste will be removed during the remaining months of 2021 (about 240 days) and about 13,000 m³ excavated soil will be removed from site during 2022. The average volume of one concrete truck is about 10 m³. The volume of one dump truck is about 20 m³. During 2021, the average daily number of heavy machineries entering the facility will be around 22. This is the highest number for the whole project duration. On hourly average bases with consideration the 8hr shift, number of the trucks will be between 2 and 3. Based on above calculations, during 2021 heavy trucks movement at Mirtskhulava street will not be increased significantly. Chkondideli street is two-way road with one line on both directions. The street is significantly busy due to the high density of the population. During the

Page 78 of 204 morning rush hour, the school, located 200 m from the construction site, plays a noticeable role in road congestion during morning pick.

Table 5.16 – Traffic survey “Chkondideli” project site Date Time Duration Cars Trucks Buses Pedestrians 8:45 1344 9 12 288 23.03.21 13:25 1128 14 10 97 17:10 1411 7 14 179 60 min 9:10 987 11 10 87 27.03.21 14:15 1095 12 8 126 16:55 1072 8 11 148

According to project specifications, about 12,000 m³ concrete will be delivered on site in 2021-2022 period, for about 600 days. In addition, about 3,600 m³ of excavated soil to be removed during the remaining months of 2021 (about 240 days). During 2021, the average daily number of heavy machineries entering the facility will be around 8, which is the highest number for whole project duration. On hourly average bases with consideration the 8hr shift, number of the trucks will be 1. Based on above calculations, during 2021 increase of heavy trucks movement at Chkondideli street will be negligible.

5.5 Waste management and landfill 5.5.1 Municipal landfill Didi Lilo Municipal Landfill for domestic and inert waste, which was established in 2010, is the main waste disposal site in Tbilisi, located 1 km east of the village of Didi Lilo. According to the existing project documentation, its total area is 84 hectares. The area designated for landfill cells is 63.3 ha (76% of the total area). The design capacity of the landfill is approximately 74.8 million tons. It is divided into 4 cells. 5.5.2 Inert waste disposal Inert waste shall be disposed of in Didi Lilo Municipal waste landfill. Alternatively, inert waste that can be used for backfilling operations or construction purposes may not be disposed of in landfills, but in coordination with a state or a municipality authority, might be used for backfilling operations

Page 79 of 204 or construction purposes of the project.14 Waste management contractor shall provide the disposal options as part of project Waste Management Plan. 5.5.3 Hazardous waste disposal/treatment Currently, there are several licensed companies operating on the territory of Georgia, which collect and dispose of hazardous waste.

“Sanitary” - is the multi profile company, which main direction is management of household and non-household toxic and dangerous wastes. It restores and cleans contaminated soil by using bio-remediation method; builds, serves and restores pipeline corridors, provides light scale constructional works. “Sanitary” also provides management of landfill and hazardous wastes accumulating work area for non-hazardous wastes, which meets Euro Standards.

“Medical technology” - was established in 2010 and provides services to pharmaceutical, medical, industrial, chemical and other companies on waste disposal and utilization (incineration). Carries out the transportation of hazardous and non-hazardous unsuitable products-waste transportation for further disposal. Has a properly equipped enterprise base and experience in disposal activities. The study completed as part of the preparation for this IEE demonstrated no existing asbestos and asbestos containing materials. No such materials is planned to be used either. 5.6 Water supply system Water supply utilities company “Georgian Water and Power” (GWP) delivers 21 m³/sec of drinking water to Tbilisi and its neighbourhood. Tbilisi water supply system uses both, groundwater, and surface water resources. The intake of underground waters takes place in Aragvi Gorge, which is located in about 40 km from Tbilisi, while surface water intake is carried out from Tbilisi Sea. The residential districts bordering Project area are supplied with drinking water with 300 and 600 mm‐diameter steel pipes. The system pressure reaches 6 atmospheres. The system is amortized and requires replacement, however there are no visible leakages on the Project area at present. 5.7 Wastewater system Tbilisi storm water drainage system piping of 150‐1,200 mm diameter is built with brick, arch, concrete, reinforced concrete, ceramic, cast iron, asbestos

14 According to Tbilisi Municipality waste management plan.

Page 80 of 204 cement, and polyethylene components. The total length of the network system is 1,600 km. The length of the main trunk wastewater sewer is 72 km. The drainage system is self‐flowing through the sewer to Gardabani Treatment Plant. There are 42 separating chambers on the main sewer with the total capacity of Gardabani Treatment Plant being up to 1 million m³/day. The water‐ drainage system is amortized but is in the working condition and is the subject of ongoing rehabilitation. 5. 8 Transport Tbilisi transportation network includes metro, buses, and microbuses (both public and private). Most of the buses and microbuses run on diesel fuel and with several phases of recent replacement of the available resources are mostly in quite acceptable technical condition. , originally opened in 1966, is a rapid transit system in Tbilisi. Presently the system consists of two lines (red and green), 23 stations on up to 60 kilometres of track. Out of those, 21 stations are below ground and two are at surface level due to the Tbilisi uneven landscape. Of the subterranean stations 16 are deep level and 5 are shallow. Despite some deficiencies, the Tbilisi transport infrastructure is extremely functional and widely used for public transportation. The annual number of municipal transport passengers in Tbilisi amounts to 149.9 million/year for both buses and metro. There is the non-hazardous carbo alternative transportation railway running through the “Mirtskhulava” project site. This case’s details are provided within the section of 6.8 Health and Safety. 5.9 Cultural heritage Historically, Tbilisi has played an important role in the region. It was located on the road that connected Georgia with the eastern Transcaucasus and the eastern and southern countries. Large-scale archaeological excavations were impossible due to the town’s dense settlement, and therefore each new discovery is of a random nature. However, archaeological studies have demonstrated that territories of Tbilisi have been populated since the IV-III millennia. Tbilisi has been mentioned in historical sources since the IV century AD. The territory of Tbilisi was particularly densely populated in the Late Bronze and Early Iron Ages (XIV‐VII cc. B.C.). The sites of ancient settlements and burials of this period have been found in Avlabari, Ortachala, Saburtalo, Didube, Digomi, Mtatsminda slope, Nadzaladevi, Avchala and in other places. The monuments of the Antique Age (VI c. BC – II‐IV c. AD) were found in Avlabari, Mtatsminda slope,

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Tavisupleba Square, Agmashenebeli Avenue, Digomi, Saburtalo, Gldani, Vake, Didube, Nadzaladevi, Ortachala, Grmagele The cultural heritage objects located within Didube district of Tbilisi are provided within the table below.

Table 5.17 – Didube and Nadzaladevi district historical locations15 No Description Timeframe Location 1 Residential house Beginning of XX 41, A. Tsereteli ave. century 2 Didube Pantheon Park art and landscape architecture memorial 3 State security police XIX century building 56, A. Tsereteli ave. 4 Didube church Mid-centuries 44, A. Tsereteli ave. temple 5 Silk museum XIX century building 6, G. Tsabadze str., / 1 V. Maiakovski str.

6 Park “Mushtaidi” Beginning of IX 182, D. Agmashenebeli century ave.

7 Park “Mushtaidi” XIX century 182, D. Agmashenebeli admin building ave.

8 Park “Mushtaidi” XIX century building 182, D. Agmashenebeli former café-shantan ave.

9 Park “Mushtaidi” XIX century building 182, D. Agmashenebeli entertainment railroad ave.

10 War veteran’s hospital XIX century building 3, S. Iamanidze str. 11 “Expo-Georgia” XX century (1938) 118, A. Tsereteli ave. architectural building

15 Cultural heritage portal https://memkvidreoba.gov.ge/?fbclid=IwAR1dnb0Oodmjh- ysU36XkNuXC9JVvWZrLiYO2S3qBpqbc7y78juNoiHc-cQY

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5.9.1 German settlement in Didube district of Tbilisi16 German colony – Alexandersdorf was established in 1818 in the vicinity of village Didube (present locations of Agladze, Samtredia and Tskhaltubo streets in Didube district of Tbilisi). The colony was named after emperor Alexander I. Agriculturally oriented Swabian Germans17 settled there, which dictated the colony’s agrarian character. In the middle of colony, the road connecting Tskaltubo and Samtredia streets was initially named “Samtredia-Kroitsgasse”, where St. Paul evangelical Lutheran church was located. During the soviet period the church was first turned into the warehouse and later destroyed along with the nearby German cemetery. Figure 5.11 Samtredia-Kroitsgasse road

Alexandersdorf colony became part of Tbilisi which also led to urbanisation of the agricultural land surrounding it; however, the area still retains 20 original houses and German school building. Residential areas replaced colony’s orchards and vineyards, although their significant part was turned into the large recreational area where Didube “Expo-Georgia” park is currently located.

16 Nestan Tatarashvili “German settlement and cultural heritage in Georgia”, Cultural Heritage National Agency, Tbilisi, 2018 17 Swabiais a cultural, historic and linguistic region in southwestern Germany.

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Any signs of cultural heritage existence in the project area have not been recorded during the visual audit and based on those and the desk-top study Paragon conducted, the risk of late discovery of archaeological sites is minimal due to the high anthropogenic load and secondary development of the area.

Residential house “Didube pantheon”

Security Police building Silk Museum

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Didube church “Mushtaidi” park

“Mushtaidi” park admin building “Mushtaidi” park former café- shantan

“Mushtaidi” park entertainment railroad War veterans’ hospital

“Expo-Georgia” Alexandersdorf

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“Alexandersdorf” school wall fragment “Alexandersdorf” house

5.10 Tourism The development of tourism in Georgia begins at the turn of the XIX-XX centuries. In fact, it has become widespread since the second half of the XX century, especially in the post-World War II years. During this period, well- equipped tourist bases and hotels in Tbilisi, Sukhumi, Batumi and others were put into operation. According to the statistical information, in 2018, there were about 31,000 hotels with about 65,500 beds in place in Georgia. About 21,000 beds from above mentioned number were available in Tbilisi. Due to its location and abundance of cultural monuments, Tbilisi has a significant tourist potential. In addition to branded and small family hotels in the city, daily renting of the apartments to tourists became increasingly popular. It is noteworthy that in 2018, there were more than 10,000 apartments per month for rent on airbnb.com18 portal. In 2019, revenues from the portal exceeded $23 million.

6. ANTICIPATED ENVIRONMENTAL AND SOCIAL IMPACTS AND MITIGATION MEASURES The IEE study has identified that the implementation of the project will generate both positive and negative environmental and social impacts. The project will result in some short-term and long-term positive impacts, among them employment during construction period and provision of the

18 Online platform for renting the accommodations

Page 86 of 204 residential areas to the owners of the premises, which was paused for a certain period of time. The identified potential negative impacts include air pollution, noise nuisance, soil pollution, waste generation and disposal. The identified potential negative impacts are likely to be minimized and managed effectively with the implementation of the measures detailed in the sections below. The activities to be performed within the scope of the Project were examined below. The Project is subject to the HSE policies and plans of “White Square” or overarching policies and plans of the “Georgia Capital”. The management of EHSS risks can be strengthened by providing training to the construction contractors as well as regular on-site monitoring. In order to fulfil this requirement, qualified E&S personnel will need to be hired as identified as a corrective action in the Environmental and Social Compliance Audit Report (ESCAR). As project work is ongoing, it was noted that daily Health and Safety toolbox talks are conducted for site personnel. All visitors go through a Health and Safety site induction and are provided with the Personal Protective Equipment (PPE), where required. Evacuation plans are available and visible at sites. For the purposes of the project the Company utilises the overarching Environmental and Social Management Plan (ESMP). The monitoring and reporting of social mitigation measures, performances and problems is conducted based on the specific sections of the Environmental and Social Management Plan. So far, no demonstration of the monitoring on implementation of social mitigation measures for project aspects impacting schools, churches, recreation and entertainment areas etc., was available for provision. 6.1 Air Quality and Noise 6.1.1 Noise and Dust Noise and emissions of harmful substances are typical impacts of construction. Air quality is affected during construction by emissions from vessels, equipment, and land vehicles in work activities at work locations. The noise and dust generated in course of construction causes nuisance of the local residents that further increases during dry summer season. Modelling and assessment of the

Page 87 of 204 noise caused by construction activities is based on existing information about operation of various equipment at various stage of construction. Noise levels within 15 m from the working equipment as it is considered by the Federal Highway Administration of the ministry of transport of the USA (FHWA), California Department of transportation (CADOT) and SBAG is as follows:

Table 6.1 – Noise levels (Administration of the ministry of transport of the USA) Noise source Equivalent noise level dBA Excavator 84-85 Bulldozer 84-85 Grader 91-92 Compressor 80-88

Table 6.2 – Noise levels (California Department of transportation) Noise source Equivalent noise level dBA Excavator 72-92 Bulldozer 83-93 Grader 80-95 Compressor 75-88

As a rule, noise caused by moving equipment is reduced at some distance. Such reduction has logarithmic properties. In case of noise caused by construction activities, noise spread pattern from the noise point is used, that can be determined as: Noise level1-Noise level2=20 log r2/r1, meaning that by doubling of distance noise is reduced by 6dBA.

Table 6.3 – Noise levels

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Distance from noise Calculation level of the Calculation level of the source (m) noise Average value - noise Maximum value - dBa dBa 10 80 90 20 74 84 40 68 78 80 62 72 160 56 66 320 50 60

The existing and forecasted noise level at a distance of 80 meters from the point of use of construction equipment is not significant. In fact, after 120-130 m from the noise source, the noise level is acceptable without implementation of mitigation measures. It can be assumed according to rough calculations, that noise impact will not exceed 150 m and increase of noise level within 150 m is assessed as acceptable impact. There are houses within 150 m distance from the “Mirtskhulava” project site’s south and south-east boundaries and at “Chkondideli” project site’s north-west, eastern and south-east boundaries, therefore, the contractor should implement certain mitigation measures, as listed below. 6.1.2 Noise and Dust Mitigation measures The following mitigation measures are suggested for implementation with the purposes of dust pollution impact reduction/elimination: o Water spraying inside and around the construction sites as well as for transport vehicle wheels to be conducted regularly in dry weather conditions; o Loose materials transported to and from the sites (gravel, soil, sand) will be covered/ wetted down to reduce dust generation; o Only vehicles and equipment that are registered and have necessary permits to be used for the Project. o All vehicles to be checked and repaired on the on-need basis to reduce/eliminate emission resulting from damaged parts;

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o Burning any type of wastes generated at the construction sites shall be strictly prohibited; o Vehicle speed limits on construction sites to be imposed to minimize road dust generation. The mitigation measures for the noise impact reduction and/or elimination are listed below: o Only vehicles and equipment that are registered and have necessary permits to be used for the Project; o All vehicles to be maintained to reduce nuisance to both employees and local people; o All vehicles to be checked and repaired on the on-need basis to reduce/eliminate noise resulting from damaged parts; o No noisy construction‐related activities to be carried out during the night- time. Such activities to be restricted to daylight hours; o In case of elevated noise level, the use of silencers, mufflers and acoustic shields on plant and equipment to be considered; o Truck drivers and equipment operators to minimize the use of horns and unnecessary acceleration; o The number of simultaneous operations of the machines to be limited to as much extent as possible. Due to the proximity of residential houses, within 150 m distance from the “Mirtskhulava” project site’s south and south-east boundaries and at “Chkondideli” project site’s north-west, eastern and south-east boundaries, the potential impact of the project on air quality and noise levels could be considered as high. But as these impacts have short-term (temporary) nature and mostly limited to construction activities, the overall potential impact of project on air quality and noise levels is considered as moderate. Therefore, noise and dust monitoring program shall be established to ensure the compliance with project specified standards. 6.2 Water and wastewater 6.2.1 Water During implementation of the Project the risk of surface and groundwater contamination is of low level. The nearest surface water (Mtkvari river) is located at a distance of 0.2 km from the “Mirtskhulava” project site and 1.5 km from “Chkondideli” project site, while no shallow groundwater was found within the vicinities of the Project sites, minimizing the project’s impact on it. Due to

Page 90 of 204 the proximity of the surface water to the project sites, especially to the “Mirtskhulava”, the enforcement of the pollution prevention, chemicals and hazardous material management shall be considered with more frequent inspections, which is reflected in the E&S Impact and Mitigation Matrix. 6.2.2 Wastewater disposal Sewage water from the Project sites is currently stored in underground septic tanks, which are periodically pumped out with the sewage sludge transported to the Tbilisi municipal sewer. Upon availability of the sewage infrastructure, the employee toilets will be connected to it and disposal of sewage will take place through municipal sewage network. Chemically polluted water (e.g., oil polluted) if any generated on site, will be treated as hazardous waste, while cement wash down will be treated via evaporation within concrete wash down pits with the residual to be treated as inert waste. 6.2.3 Water and Wastewater Mitigation measures Regardless of the absence of the primary impact to the surface and groundwater, the specific mitigation measures are suggested for the implementation at the Project site to prevent any potential water pollution: o The proper storage and handling of lubricants, fuel and solvents to be ensured at the Project sites in accordance with the data reflected within the Material Safety Data Sheets and indicated within the Environmental and Social Management Plan; o The hazardous substances if any required at the Project site to be minimized and stored in paved, bunded areas in tightly sealed containers to avoid contamination of soil and water resources; o All chemical substances material containers to be regularly checked for leakage and necessary repair or replacement undertaken immediately; o If spills or leaks do occur, immediate clean up to be undertaken; o Refuelling of construction equipment and the addition of hydraulic oils or lubricants to vehicles construction sites, to be reduced to as minimum extent as practically possible and in case it is still required to take place – using pollution prevention and control equipment (e.g., drip trays) and in a designated bunded area. The designated refuelling area not to be situated in 50-meter proximity to any surface water drain; o Vehicles refuelling or addition of hydraulic oils to be completed under supervision of designated personnel.

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6.3 Soil quality and topsoil management 6.3.1 Soil and topsoil During construction, impacts on soils are mainly due to earthworks and the operation of the contractor's yard. 6.3.2 Soil and Topsoil Mitigation measures The below mitigation measures are suggested for the protection of soil and topsoil quality at the same time some of them providing the mitigation for waste reduction: o The proper storage and handling of lubricants, fuel and solvents to be ensured at the Project sites; o The fuel and hazardous substances if any required at the Project site to be minimized and stored in paved, bunded areas in tightly sealed containers to avoid contamination of soil and water resources; o All chemical substances material containers to be regularly checked for leakage and necessary repair or replacement undertaken immediately; o If spills or leaks do occur, immediate clean up to be undertaken; o Refuelling of construction vehicles and the addition of hydraulic oils or lubricants to vehicles, to be reduced to as minimum extent as practically possible and in case it is still required to take place using pollution prevention and control equipment (e.g., drip trays) and in a designated bunded area; o Equipment refuelling or addition of hydraulic oils to be completed under supervision of designated personnel. 6.4 Biological environment 6.4.1 Flora and fauna The Project impacts on flora and fauna is found to be negligible. 6.4.2 Flora and Fauna Mitigation measures As fauna values in the project area are very low, no specific measures are proposed except for to avoid any deliberate disturbance. The following measures need to be implemented to avoid any impacts on flora: o Avoid tree cutting or reduce it to as much extent as practically possible; o Obtain relevant regulatory permit to any tree requiring to be cut down; o Relocate the trees interfering with the construction activities wherever possible;

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o Install tree protection fences/signs for the trees to be retained at the territory of the project. 6.5 Traffic 6.5.1 Traffic Some negative traffic impact is anticipated during the Project, among that use of public road for delivery of construction material and disposal of waste from the project sites. 6.5.2 Traffic Mitigation measures The following mitigation measures are suggestion for implementation to minimize traffic disturbance: o Signs advising road users that construction is in progress to be provided where relevant; o When construction equipment is entering or leaving the Project site the flagman to be employed to assist with the traffic control for safety reasons; o Sufficient lighting at night-time within and in the vicinity of construction sites to be provided; o Delivery of construction materials and equipment and transportation of any material/waste from the Project site to be scheduled for non‐peak hours to as much extent as practically possible; o Noisy activities during night-time in vicinity of sensitive receptors to be avoided; o Adequate safety measures minimizing the risk of adverse interactions between construction works and traffic flows to be implemented through provision of temporary signals or flagging, proper lighting, fencing, signs installation and road diversions where required o Driver safety induction and traffic awareness raising measures in local area (especially near children’s play areas, school, crossing areas etc). o Regular alcohol / drug testing and vehicle tracking shall be part of H&S monitoring; 6.6 Waste management Project activities are expected to generate various types of waste including inert construction, domestic, hazardous and some medical wastes. Some of the waste streams are anticipated to be recyclable or reusable, while some of them to be disposed of in an environmentally friendly manner following the waste code of Georgia.

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6.6.1 Inert waste The most significant amount of waste is anticipated to be originated from construction and demolition activities of the Project. All such waste is expected to be inert construction type such as soil, old buildings parts and concrete wash down debris originated from concrete water wash down. 6.6.1.1 “Mirtskhulava” project site Concrete waste 39,000 m³ concrete will be delivered on site by 3,900 concrete mixer tracks. Each truck generates about 0.05 m³ of concrete waste. The concrete waste from concrete pump on daily bases are about 0.3 m³. concreting activities will be carried out for about 600 days. Therefore, concrete waste from “Mirtskhulava” project site will be the following: (0.05x3,900) + (0.3x600) = 375 m³ Demolition waste 50,144 m³ from demolition of existing building (as per demolition permit) Sub soil/Excavation waste The main contributor in generation of above-mentioned waste, will be the foundation works for building IX and X. The development area of these buildings is 2,600 m². Depth of the excavation 4 m. The total volume of the excavated soil with consideration of soil compaction factor (about 1.25) will be the following: 2,600x4x1.25 = 13,000 m³. Some amount of above-mentioned soil could be used for the landscaping and levelling of construction site, but significant part of them shall be removed from site. 6.6.1.2 “Chkondideli” project site Concrete waste 12,000 m³ concrete will be delivered on site by 1,200 concrete mixer tracks. Each track generates about 0.05 m³ of concrete waste. The concrete waste from concrete pump on daily bases are about 0.3 m³. concreting activities will be carried out for about 600 days. Therefore, concrete waste from “Chkondideli” project site will be the following: (0.05x1,200) + (0.3x600) = 240 m³. Demolition waste No demolition waste is expected from this stage of construction.

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Sub soil/Excavation waste The main contributor in generation of above-mentioned waste, will be the foundation works for building XII. The development area of these building is 678 m². Depth of the excavation 4.3 m. The total volume of the excavated soil with consideration of soil compaction factor (about 1.25) will be the following: 678x4.3x1.25 = 3,644 m³. Some amount of above-mentioned soil could be used for the landscaping and levelling of construction site, but significant part of them shall be removed from site. 6.6.2 Domestic waste It is anticipated that some of the domestic wastes will be originated during the Project, among that putrescible waste, paper, non-contaminated PPE and some others. 6.6.3 Hazardous waste Some amount of hazardous waste is anticipated to be generated mainly from the painting activities, equipment maintenance activities (liquid fuels; lubricants, hydraulic oils; chemicals, such as anti‐freeze, etc.). 6.6.4 Medical waste Negligible amount of medical waste is anticipated to be generated during Project activities, mainly originating from first aid kit use. 6.6.5 Waste Mitigation measures The mitigation measures dedicated for the reduction and/or elimination of the waste generation and management impact are listed within the section below: o Waste Management Plan to be prepared and agreed with MEPA and ADB on management of all available and potential waste streams originating from the project activities; o All waste residuals, domestic, hazardous and medical, to be stored within appropriately covered containers prior to removal by a suitable licensed waste management contractor for off‐site treatment, recycling, or disposal; o All Project sites to be maintained in as clean, tidy and safe condition as possible;

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o Project to provide and maintain appropriate facilities for a temporary storage of all types of wastes prior to transportation and final disposal in an environmentally friendly manner; o Hazardous and non‐hazardous waste streams shall be separated and temporarily stored on site within weatherproof secure facilities with controlled access and protection for drainage/ wastewater collection systems; o All personnel to receive at least a basic training in waste management practices as a component of the employee toolbox talks and appropriate PPE such as overalls, gloves, safety shoes and masks; o No wastes to be haphazardly dumped within the project site and/or adjacent areas’ o Adequate washing and toilet facilities to be provided at each Project site o Organise project site specific concrete water wash down pits for concrete water evaporation with the remaining residue to be treated as inert waste 6.7 Socio-Cultural resources 6.7.1 Social resources There are various social-cultural resources (such as school, churches, recreation and entertainment areas, etc.) adjacent to the Project sites. The impact on those will include noise, dust, and traffic, which are separately discussed within this section of IEE and the mitigation measures are also provided. 6.7.2 Social resources Mitigation measures As per noise, dust and traffic sections of the IEE impact mitigation measures. 6.7.3 Cultural heritage resources The major risk to archaeological and cultural heritage is Project related ground disturbance. However due to the legacy use of the Project sites there are no anticipated direct impacts to any known cultural relics by project development. 6.7.4 Cultural heritage resources Mitigation measures Regardless of no anticipated risk the following mitigation measures to be utilised in case any potential cultural heritage locations are identified during the Project activities: o All site employees are instructed to report any potential cultural chance findings to the site management

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o Site activities to be suspended until checking of the finding is executed by the archaeology/cultural heritage experts invited from the Ministry of Culture, Sports and Youth of Georgia o Decision on recommencement of stopped project activities to be issued by the Ministry of Culture, Sports and Youth of Georgia experts based on the significance of findings 6.7.5 Chance Find Procedure Georgian legislation comprises the Constitution, Cultural Heritage law, international agreements, subordinate legislation, normative acts, presidential orders and governmental decrees, ministerial orders, instructions and regulations. Along with the national regulations, Georgia is signatory to a number of international conventions, including those related to Cultural Heritage protection. Protection of heritage resources in Georgia is based on the Georgian Law on Cultural Heritage Protection, 2007 (last amended in 2020). This law is regulated by the Ministry of Education, Science and Culture of Georgia (MoC) and the National Agency for Cultural Heritage Preservation of Georgia (NACHP). Within this Law, monuments are classified by their significance. The Chance Finds Procedure ensures that if archaeological remains are encountered during construction they are reported and protected until satisfactory treatment strategy is identified, agreed, implemented, and completed. The procedure is intended to ensure that all activities around the Chance Find are stopped and construction site management and Environmental personnel are informed. The National Law on Cultural Heritage, Chapter 3 Initial (Temporary) Protection of Known and Identified Cultural Heritage requires:

• Stop Work for Chance Finds • Written notification of the Chance Find and Stop Work to the Ministry of Culture, Sports and Youth of Georgia within 7 days

• The Ministry verification and response within 14 days of receipt of above • Failure of the Ministry to verify and respond within 14 days is, by default, an authorization to lift the Stop Work.

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That means that during earthmoving, in case of accidental discovery of a cultural heritage object, artefact or other archaeological feature, in order to avoid its damage or destruction, it is necessary to take measures provided by the legislation of Georgia (Law of Georgia on Cultural Heritage, 2007). The company is obliged to stop the construction works at the given place, to protect the place of discovery and to invite the specialists of the body authorized by the legislation of Georgia (National Agency for Cultural Heritage Preservation of Georgia- NACHP - under the Ministry of Culture, Sports and Youth of Georgia) to determine importance of the discovered archaeological object and to make decision on the continuation of the construction works. Continuation of works will be possible on the basis of a permit issued by NACHP after evaluation the site or completion the necessary archaeological works.

6.8 Occupational and Community Health and safety 6.8.1 Health and Safety of employees and public Some of the Project activities have potential to expose employees to occupational health and safety risks, among that ground disturbance, operating heavy equipment, activities within the confined space, working on/along roads, working at height, heavy lifting, hazardous substances management, noisy condition, dropped objects, working with electricity and cutting machinery. The nearest residents can also be potentially exposed to these activities. In addition to that there is the unique case of the railway running through the “Mirtskhulava” project site. The railway initially deemed as abolished infrastructure to be removed as part of the nearby building’s demolition activities is in fact the active infrastructure used as alternative way under specific circumstances described below. The railway fragment is branching off the main line in the vicinity of the to-be-demolished building at “Mirtskhulava” project site. The railway is apparently under balance of the “Georgia Railroad” JSC and is used as reserve non-hazardous cargo transition line connecting two stations in exceptionally rare cases the main transition line is overwhelmed (average 2-3 times/quarter). The presence of the railway at the location of the project site upon completion of the construction would present safety issue to the local community. Considering significance of railway infrastructure for social development and with determination to avoid any potential legal disputes, the Company

Page 98 of 204 conducted investigation of the potential matter resolving options with “Georgian Railway” JSC. As an outcome of the process the Company obtained a written confirmation (available in Georgian language) on the railway right-of- way width reduction to accommodate “Mirtskhulava” project site construction activities and post-development period with the condition of the Company to erect the lightweight safety wall not less than 2 m high along both sides of the railway. 6.8.2 Health and Safety Mitigation measures o All Project employees and contractors to undergo on site inductions, and, as required, training in special skills, environment, emergency, and safety before allowing to conduct the Project activities; o Safety equipment including but not limited to Personal Protective Equipment (PPE), such as safety boot, hardhats, safety glasses, noise mitigation equipment, fall arrest equipment as well as masks, fire extinguishers, flashlights, medicines etc., to be available on sites; o Public from outside to be restricted from entering the Project sites to minimise unnecessary exposure and risks; o Project sites to be cleaned regularly and provided with adequate sanitary equipment to reduce any potential risk of spreading diseases; o Grievance Redress Mechanism to be used for complaints from employees as well as from project impacted communities; o Employee driver safety induction and traffic awareness raising measures in local area (especially near children’s play areas, school, crossing areas etc); o Employee regular alcohol / drug testing and vehicle tracking shall be part of H&S monitoring; o Adequate sanitary facilities for female staff on project sites; o Erect the lightweight safety wall not less than 2 m high along both sides of the railway o All regulations related to the current COVID-19 pandemic to be strictly adhered to. 6.9 Climate change impact Negligible climate change impact is anticipated from the project activities, hence no specific mitigation measures suggested.

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7. Environmental and Social Impact and Mitigation Matrix19 This chapter of the IEE describes the Environmental and Social impacts and relevant mitigation measures against each of them. The Matrix is developed based on the information described within the chapter 6 of this IEE. The impact mitigation is to complete to acceptable levels in accordance with the Georgian legal requirements and the ADB safeguard policy provided within the chapter 3 of this IEE. The monitoring program that is to be undertaken as part of the Project activities aims to confirm the effectiveness of the mitigation measures in achieving their objectives. Otherwise, the initiation of specific corrective actions would be required. The Company and the Contractor are obliged to implement the requirements reflected in the Matrix where applicable during the whole Project period with the Consultant to monitor these activities. The Consultant will point out any deviations from the Matrix and make sure that the Contractor addresses all issues of the Matrix in a timely and professional manner.

19 The project specific Environmental and Social Management Plan substitution.

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Table 7.1 – Environmental and Social Impact and Mitigation Matrix No Potential Suggested mitigation negative Responsibility Deliverable/Monitoring/Reporting Location Cost USD measures impacts 1 "Mirtskhulava" All project specific Roles and Roles and Responsibilities internal spot and As per compensation Capability Responsibilities are provided The Company check - biannually "Chkondideli" requirement within the section 8 of this IEE Project site 2 o Only vehicles and equipment that are registered and have necessary permits to be used for the Project; o All vehicles to be o All vehicles and equipment maintained to reduce nuisance to maintenance records to be checked as part both employees and local people; of periodic HSSE inspections; o All vehicles to be checked o Noise monitoring quarterly rounds $2500 per round of and repaired on the on-need will be conducted at both project sites monitoring for both basis to reduce/eliminate noise baseline monitoring locations "Mirtskhulava" sites. Demolition resulting from damaged parts; o Monthly noise monitoring rounds and activities are required at Noise o The Company will be conducted during demolition No noisy construction‐ "Chkondideli" one Project site, hence related activities to be carried out activities at “Mirtskhulava” project site Project site monthly monitoring during the night-time. Such o All noise monitoring rounds to be during this period to be activities to be restricted to conducted in accordance with the IFC about $1500 daylight hours; general EHS Guideline 1.7 Noise and Method o In case of elevated noise Statement agreed with ADB for the baseline level, the use of silencers, monitoring and provided as Appendix 12.6 mufflers and acoustic shields on plant and equipment to be considered; o Truck drivers and equipment operators to minimize

Page 101 of 204 the use of horns and unnecessary acceleration; o The number of simultaneous operations of the machines to be limited to as much extent as possible.

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3 o Water spraying inside and around the construction sites as well as for transport vehicle wheels to be conducted regularly in dry weather conditions; o Loose materials o All vehicles and equipment maintenance transported to and from the sites records to be checked as part of periodic (gravel, soil, sand) will be HSSE inspections; covered/ wetted down to reduce o PM ₁₀ and PM ₂.₅ monitoring dust generation; quarterly rounds will be conducted at both o Only vehicles and project sites baseline monitoring locations "Mirtskhulava" equipment that are registered o Monthly PM ₁₀ and PM ₂.₅ and Dust and have necessary permits to be The Company monitoring rounds will be conducted during "Chkondideli" used for the Project. demolition activities at “Mirtskhulava” Project site o All vehicles to be checked project site and repaired on the on-need o All PM ₁₀ and PM ₂.₅ monitoring basis to reduce/eliminate rounds to be conducted in accordance emission resulting from damaged Method Statement agreed with ADB for the parts; baseline monitoring o Burning any type of wastes generated at the construction sites shall be strictly prohibited; o Vehicle speed limits on construction sites to be imposed to minimize road dust generation.

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4 o The proper storage and handling of lubricants, fuel and solvents to be ensured at the Project sites in accordance with the data reflected within the Material Safety Data Sheets and indicated within the Environmental and Social Management Plan; o The fuel and hazardous substances if any required at the o HSSE dedicated personnel to Project site to be minimized and conduct daily project site HSSE walk and stored in paved, bunded areas in monthly HSSE inspection; tightly sealed containers to avoid o HSSE dedicated personnel to contamination of soil and water develop and maintain HSE inspection check- "Mirtskhulava" resources; list, chemical substances register, HSSE Water and and Included in Project o All chemical substances The Company incident register; Wastewater "Chkondideli" price; no additional cost material containers to be o For site due to “Mirtskhulava” project Project site regularly checked for leakage and the proximity to the surface water necessary repair or replacement bodies (0.2 km) the enforcement of the undertaken immediately; pollution prevention, chemicals and o If spills or leaks do occur, hazardous material management shall immediate clean up to be be considered with weekly inspections undertaken; o Refuelling of construction equipment and the addition of hydraulic oils or lubricants to vehicles construction sites, to be reduced to as minimum extent as practically possible and in case it is still required to take place – using pollution prevention and control equipment (e.g. drip

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trays) and in a designated bunded area. The designated refuelling area not to be situated in 50- meter proximity to any surface water drain; o Equipment refuelling or addition of hydraulic oils to be completed under supervision of designated personnel.

5 o The proper storage and handling of lubricants, fuel and solvents to be ensured at the Project sites; o HSSE dedicated personnel to o The fuel and hazardous conduct daily project site HSSE walk and $1500 to purchase substances if any required at the monthly HSSE inspection (including check of "Mirtskhulava" pollution Project site to be minimized and the spill response equipment); and Soil/Topsoil The Company prevention/spill stored in paved, bunded areas in o HSSE dedicated personnel to "Chkondideli" response equipment for tightly sealed containers to avoid develop and maintain HSSE inspection Project site both sites contamination of soil and water checklist, chemical substances register, HSSE resources; incident register; o All chemical substances material containers to be regularly checked for leakage and

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necessary repair or replacement undertaken immediately; o If spills or leaks do occur, immediate clean up to be undertaken; o Refuelling of construction equipment and the addition of hydraulic oils or lubricants to vehicles, to be reduced to as minimum extent as practically possible and in case it is still required to take place using pollution prevention and control equipment (e.g., drip trays) and in a designated bunded area; o Vehicles refuelling or addition of hydraulic oils to be completed under supervision of designated personnel.

6 For the purposes of the Project the IFC Environmental, Health, and Safety (EHS) Guidelines 1.5 o HSSE dedicated personnel to Hazardous Material Management conduct daily project site HSSE walk and the Guidelines on the General monthly HSSE inspection (including check of Hazardous Hazardous Materials “Mirtskhulava” the spill response equipment); and Included in Project material Management apply, i.e., all The Company o HSSE dedicated personnel to price; no additional cost management projects or facilities that handle “Chkondideli” develop and maintain HSSE inspection project sites or store any quantity of checklist, chemical substances register, HSSE hazardous materials. incident register; The main objectives of projects involving hazardous materials should be the protection of the

Page 106 of 204 workforce and the prevention and control of releases and accidents. These objectives should be addressed by integrating prevention and control measures, management actions, and procedures into day- to-day business activities. Potentially applicable elements of a management program include the following:

The inventory of hazardous materials presents in the project; Analysis of compatibility and proper storage of incompatible material; Properly equipped, well ventilated, weather protected and secured hazardous material storage; Training of the site personnel on hazardous material handling; Provision of relevant MSDSs

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7

o Avoid tree cutting or o Provision and maintenance of reduce it to as much extent as regulatory permits; practically possible; o HSSE dedicated personnel to o Obtain relevant conduct daily project site HSSE walk and regulatory permit to any tree monthly HSSE inspection (including check of "Mirtskhulava" requiring to be cut down; the available flora condition and observation and Included in Project Flora/Fauna o Relocate the trees The Company of any fauna representation and relevant "Chkondideli" price; no additional cost interfering with the construction signage, protection); Project sites activities wherever possible; o HSSE dedicated personnel maintain o Install tree protection tree relocation methodology agreed with fences/signs for the trees to be Tbilisi Municipality tree cutting and retained at the territory of the relocation permit condition; Project.

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8 o Signs advising road users that construction is in progress to be provided where relevant; o When construction equipment is entering or leaving the Project site the flagman to be employed to assist with the traffic control for safety reasons; o Sufficient lighting at night-time within and in the vicinity of construction sites to be provided; o Delivery of construction

materials and equipment and o HSSE dedicated personnel to transportation of any conduct daily project site HSSE walk and "Mirtskhulava" material/waste from the Project monthly HSSE inspection; and Included in Project Traffic The Company site to be scheduled for non‐peak o HSSE dedicated personnel to "Chkondideli" price; no additional cost hours to as much extent as develop and maintain HSSE inspection Project site practically possible; checklist, HSSE incident register; alcohol and o Noisy activities during drug testing register; night-time in vicinity of sensitive receptors to be avoided; o Adequate safety measures minimizing the risk of adverse interactions between construction works and traffic flows to be implemented through provision of temporary signals or flagging, proper lighting, fencing, signs installation and road diversions where required o Driver safety induction and traffic awareness raising

Page 109 of 204 measures in local area (especially near children’s play areas, school, crossing areas etc). o Regular alcohol / drug testing and vehicle tracking shall be part of H&S monitoring;

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9 o Waste Management Plan to be prepared and agreed with MEPA and ADB on management of all available and potential waste streams originating from the project activities; o All waste residuals, domestic, hazardous and medical, to be stored within appropriately covered containers prior to removal by a suitable licensed o HSSE dedicated personnel to waste management contractor conduct daily project site HSSE walk and for off‐site treatment, recycling, monthly HSSE inspection; or disposal; o HSSE dedicated personnel to o All Project sites to be conduct waste management tracking (waste "Mirtskhulava" maintained in as clean, tidy and transfer tracking, waste log, hazardous and $1500 for hiring the Waste safe condition as possible; The Company waste removal registration); "Chkondideli" consultant o Project to provide and o HSSE dedicated personnel to Project site maintain appropriate facilities for maintain the validation of waste a temporary storage of all types management contractors licenses; of wastes prior to transportation o To provide proposals to audit waste and final disposal in an management operations environmentally friendly manner; o Hazardous and non‐ hazardous waste streams shall be separated and temporarily stored on the project site within weatherproof secure facilities with controlled access and protection for drainage/ wastewater collection systems; o All personnel to receive at least a basic training in waste

Page 111 of 204 management practices as a component of the employee toolbox talks and appropriate PPE such as overalls, gloves, safety shoes and masks to be available; o No wastes to be haphazardly dumped within the project site and/or adjacent areas o Adequate washing and toilet facilities to be provided at each Project site o Organise project site specific concrete water wash down pits for concrete water evaporation with the remaining residue to be treated as inert waste • To prohibit uncontrolled burning or burial of waste • To ensure that all inert disposal sites and disposal plans are subject to an environmental review and an environmental risk assessment prior to their adoption

• Waste Management Hierarchy; • Proximity Principle; • Duty of Care; • Use of BATNEEC (Best Available Techniques (BAT) that does Not Entail Excessive Cost);

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• Polluter Pays Principle (This basically states that any party causing pollution shall pay the cost of mitigating that pollution).

10 o All vehicles and equipment maintenance records to be checked as part of periodic HSSE inspections; o Noise monitoring quarterly rounds will be conducted at both project sites baseline monitoring locations "Mirtskhulava" As per noise, dust and traffic o Monthly noise monitoring rounds and As per noise, dust and Social resources sections of the IEE impact The Company will be conducted during demolition "Chkondideli" traffic mitigation measures. activities at “Mirtskhulava” project site Project site o All noise monitoring rounds to be conducted in accordance with the IFC general EHS Guideline 1.7 Noise and Method Statement agreed with ADB for the baseline monitoring and provided as Appendix 12.6

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o PM ₁₀ and PM ₂.₅ monitoring quarterly rounds will be conducted at both project sites baseline monitoring locations o Monthly PM ₁₀ and PM ₂.₅ monitoring rounds will be conducted during demolition activities at “Mirtskhulava” project site o All PM ₁₀ and PM ₂.₅ monitoring rounds to be conducted in accordance Method Statement agreed with ADB for the baseline monitoring o HSSE dedicated personnel to conduct daily project site HSE walk and monthly HSE inspection; o HSSE dedicated personnel to develop and maintain HSSE inspection checklist, HSSE incident register; alcohol and drug testing register; 11 There are potential concerns o HSSE dedicated personnel to regarding worker safety on-site, conduct daily project site HSSE walk and safety risks to the public monthly HSSE inspection; associated with substantially o HSSE dedicated personnel to develop increased construction material and maintain HSSE inspection checklist, and machinery traffic, as well as HSSE incident register; alcohol and drug Public Awareness, the public health risks associated testing register; Stakeholder with an influx of workers. The Company o HSSE dedicated personnel shall maintain Engagement and Security along the work register of any communication held as Consultation • area; part of the Stakeholder Engagement; • Physical barriers at o HSSE dedicated personnel shall maintain specific locations to restrict illegal Grievance register; access; o As per the Annex on Temporary • To raise awareness of Relocation Plan for “Chkondideli” importance of vegetation; project site temporary residents to

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• Consultation with provide regular feedback to the communities on acceptable households on progress with the crossing points along the work construction activities (in person, area for local people; writing, or by telephone) communication • Local infrastructure, will be undertaken on a quarterly basis services and related disruptions as a minimum and a record of the to the local community; engagement and any issues maintained • Behaviour of the in an issues log. workforce within the community; o In an unlikely event, these “Chkondideli” In addition to that there are project site of current temporary “Chkondideli” project site specific residents’ buildings completion is impacts associated with the delayed beyond the August 2022 residents of 34 incomplete timeframe the Company takes apartments. Taking the certain responsibility to revisit the individual security, safety and health households’ needs on a case-by-case aspects into the consideration basis. temporary relocation of these o Two months prior to August 2022 families to be completed as timeframe, if the construction schedule detailed in the Appendix 12.7 is projected to run past August 2022 that Temporary Relocation Plan company will contact each temporarily relocated household individually and provide necessary support where required such as renting cost and utilities cost cover for the delayed period.

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12 o All site employees are instructed to report any potential cultural chance findings to the site management o Site activities to be suspended until checking of the finding is executed by the o Site management to communicate archaeology/cultural heritage to all site employees and maintain Chance "Mirtskhulava" experts invited from the Ministry Find Procedure; and Included in Project Cultural heritage The Company of Culture, Sports and Youth of o HSE dedicated personnel to conduct "Chkondideli" price; no additional cost Georgia daily project site HSE walk; Project site o Decision on recommencement of stopped project activities to be issued by the Ministry of Culture, Sports and Youth of Georgia experts based on the significance of findings 13 o All Project employees and o HSE dedicated personnel to conduct contractors to undergo on site daily project site HSE walk and monthly HSE inductions, and, as required, inspection; training in special skills, o HSE dedicated personnel to conduct environment, emergency, and site induction to newcomers; safety before allowing to conduct o HSE dedicated personnel to conduct "Mirtskhulava" the Project activities; daily HSE toolbox talks; and Included in Project Health and Safety o Safety equipment The Company o HSE dedicated personnel to develop "Chkondideli" price; no additional cost including but not limited to and maintain toolbox talks, daily walk, Project site Personal Protective Equipment inductions, incident/accident, alcohol and (PPE), such as safety boot, drug tests register; hardhats, safety glasses, noise

mitigation equipment, fall arrest

equipment as well as masks, fire

extinguishers, flashlights,

Page 116 of 204 medicines etc., to be available on sites; o Public from outside to be restricted from entering the Project sites to minimise unnecessary exposure and risks; o Project sites to be cleaned regularly and provided with adequate sanitary equipment to reduce any potential risk of spreading diseases; o Grievance Redress Mechanism to be used for complains from employees as well as from project impacted communities; o Employee driver safety induction and traffic awareness raising measures in local area (especially near children’s play areas, school, crossing areas etc); o Employee regular alcohol / drug testing and vehicle tracking shall be part of H&S monitoring; o Adequate sanitary facilities for female staff on project sites; o Project site-specific H&S plan to be developed; o Erect the lightweight safety wall not less than 2

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m high along both sides of the railway o All regulations related to the current COVID-19 pandemic to be strictly adhered to.

14 Negligible climate change impact o HSE dedicated personnel to conduct "Mirtskhulava" is anticipated from the project toolbox talks on conservation of water and and Climate change The Company N/A activities, hence no mitigation energy; "Chkondideli" measures suggested. Project site

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8. ROLES AND RESPONSIBILITIES 8.1 Company CEO • Is accountable for the overall management and implementation of the project specific Environmental and Social impact mitigations in accordance with the requirements of the E&S Impact and Mitigation Matrix of this IEE; • Is accountable for provision of the appropriate resources, including human resource allocation for the proper implementation of the requirements of the E&S Impact and Mitigation Matrix of this IEE; • Authorizes high level HSSE documentation such as E&S Policy, Code of Conduct etc. 8.2 Project Manager • Holds ultimate responsibility for the execution of the project and requirements of the E&S Impact and Mitigation Matrix of this IEE; • Ensures that there are sufficient resources (people, equipment, time and money) to manage and monitor the E&S impact mitigation of the project; • Ensures Input is received from all specialist E&S sources; • Ensures that the E&S Impact and Mitigation Matrix reflects any changes during the construction process that may have a significant environmental and social impact and manage them accordingly; • Manage relationships with external E&S organizations/agencies and the general public; 8.3 E&S manager • Ensures all site staff, including contractors and sub-contractors, complies with the requirements of the E&S Impact and Mitigation Matrix of this IEE, including monitoring and reporting; • Ensures staff awareness on E&S Impact and Mitigation through periodic trainings/toolbox talks; • Ensures that all applicable consents, licenses and permits are in place prior to carrying out the associated works; • Carries out E&S surveys as necessary to ensure any significant impact are identified and managed accordingly; • Ensures that the Project Manager and Site Supervisor are fully informed on any E&S issues;

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• Carries out regular project site audits and inspections in line with the program requirements; • Carries out regular regulatory register review and updates E&S requirements of the project as applicable; • Ensures all E&S incidents and non-compliances and non-conformances are properly addressed; • Ensures Complaints and Grievance Redress Mechanism is adhered to; • Ensures all E&S documentation is up-to-date and is representative of the Project circumstances. 8.4 Project Site Manager • Holds overall responsibility for the implementation of the E&S Impact and Mitigation Matrix of this IEE on-site requirements; • Ensures that all E&S incidents are reported and dealt with effectively; 8.5 H&S site officer • Conducts daily project site HSSE walk and facilitate monthly HSSE inspections; • Conducts daily HSSE toolbox talks; • Develops and maintains HSSE inspection checklist, HSSE incident register, alcohol and drug testing register; • Develops and maintains Hazardous Material inventory and assures all relevant MSDSs are available; • Ensures proper housekeeping and waste management on the project site 8.6 Site Personnel and Workforce • Complies with the requirements of the E&S Impact and Mitigation Matrix of this IEE;

• Reports any E&S issues noted during the work process; • Participate in daily toolbox talk.

9. ANALYSIS OF ALTERNATIVES The section of the IEE describes the potential alternatives for the Project. In the process of preparation of this IEE at the feasibility phase, the only one alternative was considered for the Project, which is the “no project” alternative. The “no project” alternative suggests incomplete developing areas to be

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retained with certain social and urban landscape impacts as well as the already utilized investments loss and incremental costs of the Project conservation. There were two most significant criteria used during the comparative analysis of “with project” and “no project” alternatives, which are minimization of the environmental impacts and optimization of the capital costs. The major positive impact of the “with project” alternative is considered completion of the Project that has been delayed for certain time, thus depriving customers from owning the residential premises.

10. INFORMATION DISCLOSURE, CONSULTATION, AND PARTICIPATION20 Most of the main stakeholders have already been identified and consulted with by the Company prior to the development re-initiation during previous stages of the project development, and discussion completed with ADB as part of the preparation of this IEE. Any others that are identified during project implementation will be brought into the process in the future as required for the activities that include IEE and ESCAR disclosure, community H&S awareness, engagement with residents that are part of the temporary relocation plan, community Grievance Redress mechanism requirements, its awareness enhancement and other similar ones. Stakeholders currently identified for this project include: o People who live, and work near construction sites o Government regulatory institutions o Municipality of Tbilisi o The beneficiaries of the project; and o The ADB, as the prospective funding agency. “At the re-initiation of the project the Company conducted the meetings with the resident stakeholders where the details of the project including introduced changes where discussed. The presentation used during the meeting is provided within the IEE appendices.21 This IEE Report in Georgian language to be available for the interested public. There are 35 apartments that are currently occupied by owners or owner representatives, and 4 apartments that have been modified to prepare for occupation. Due to the need to a) complete the apartment blocks to meet

20 Including Stakeholder Engagement 21 Presentation is in Georgian language

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purchase contract agreements with owners; and b) undertake such work creating an unsafe environment for current residents, the occupants of the apartments will need to temporarily relocate. The relevant stakeholder engagement had been conducted by the Company witnessed by the Consultant. Residents have agreed to voluntarily relocate at their own expense for the agreed time required to complete the apartments. Detailed information on memorandum of Understanding and the Socio-Economic research completed as part of the stakeholder engagement is provided in Appendix 12.7 Temporary Relocation Plan.

11. GRIEVANCE REDRESS MECHANISM In accordance with the ADB SPS 2009 requirements Projects shall establish a grievance redress mechanism to receive and facilitate resolution of the affected people’s concerns and grievances regarding the project’s environmental performance. The grievance redress mechanism should be scaled to the risks and impacts of the project. It should address affected people's concerns and complaints promptly, using an understandable and transparent process that is gender responsive, culturally appropriate, and readily accessible to all segments of the affected people. It should also allow for the anonymous lodging of grievances. There are two separate Grievance Redress Mechanisms available for the project, one is the Community Complaints and Grievance Redress Mechanism for external stakeholders and another – Employee Complaints and Grievance Redress Mechanism of relevant internal issues management. Community Complaints and Grievance Redress Mechanism is set up for the Project to deal with both the environmental and social concerns stemming from the Project (External GRM) and Employee Complaints and GRM procedure for employees of the Company and any related project contractors. Grievance redress registry is also in place and appended to the both, however not utilized to-date and no grievance recording was demonstrated by the Company. A Community Complaints and Grievance Redress Mechanism allows an Affected People (AP) to appeal any disagreeable decision, practice or activity arising from project implementation. APs will be fully informed of their rights and of the procedures for addressing complaints whether verbally or in writing during planning and implementation of the project. Care will always be taken to prevent grievances rather than going through a redress process. This is achieved

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by ensuring full AP participation and consultation, and by establishing extensive communication and coordination between AP, the Company, and the local government. The affected population and stakeholders may send their grievances, related to the project induced environmental impacts and nuisance to the Company or directly to the administrative bodies responsible for the environmental protection. The MEPA and concerned municipalities are obliged to respond on the grievances, which have been received from population or other interested parties in accordance with the Administrative Code of Georgia. 9.1 Employee Complaints and Grievance Redress Mechanism procedure

Employee Complaints and Grievance Redress Mechanism Procedure aims to prevent, mitigate and compensate potential negative impacts and enhance and promote potential positive impact that are likely to arise from the job creation and the issues workers may have. The document defines roles and responsibilities for managing internal processes, establishes the objectives to implement the requirements of this document. The purpose of this Employee Complaints and Grievance Redress Mechanism Procedure is to describe Company’s approach to managing project-related employees issues including grievance of the workers. The requirements set out in this document apply to all employees of the Company, including Contractor employees. The procedure is the working document subject to annual renewals/revision. The major roles and relevant responsibilities applicable to the document implementation and maintenance are provided in the table below. Table 9.1: Roles and Responsibilities Role Responsibility Company Holds overall responsibility over the implementation of the Employee CEO Complaints and Grievance Redress Mechanism and for the management of Human Resources processes, training and development initiatives; Ensures compliance with the Worker legislation of Georgia and implementation of Company Employee Grievance Mechanism Issues;

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Approves this document and resources required for its implementation; Updates and revises this document for operations or on as ‘as required’ basis; Human Ensures the implementation of the Employee Complaints and Resources Grievance Redress Mechanism requirements; Maintains human resource records and processing human resource transactions; Holds overall responsibility for the recruitment and selection governance of new employees and working with line managers to develop and review job descriptions; Is obliged to provide monthly reports, which covers all recruitment and HR related issues as well as look ahead on recruitment and plans for future recruitment to the Company; Investigates, reports and follows up on issues, complaints and procedural breaches related to employees and human resources (keeps an Employee Grievance registry – attached to this document); Acts as a female grievance officer (‘confidant’) for gender sensitive issues; Interfaces with contractors and contractor employees in relation to human resources and employee matters; Monitors the implementation of this document and Human Resources processes

In line with Company polices, national legislation of Georgia and ADB SPS 2009, the following provisions for handling the grievance from the Company and related contractors’ employees will be used: 1. An employee has a right to submit open or unanimous, verbal, e-mail and/or written complaint to his/her immediate supervisor (manager), to the HR Management Department or the General Director of the Company. Grievance Submission Form is appended to this document. The following contact information shall be used as the hot lines: [email protected], www.w2.ge, https://www.facebook.com/tetri2/, phone 032444111;

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2. Anonymous grievance boxes shall be installed at the site facilities and Company offices. The boxes will be checked on weekly basis;

3. The employee’s complaint is reviewed within 21 (twenty-one) calendar days in strictly confidential manner;

4. When reviewing the employee’s complaint, the principles of legality and fairness must be observed, so that the honour, dignity and business reputation of both the complainant and the person(s) referred to in the complaint are not violated;

5. After reviewing the employee’s complaint, a decision shall be made either on full or partial satisfaction of the complaint or on refusal to satisfy the complaint;

6. If the employee’s complaint is satisfied, the relevant person shall take appropriate measures to eliminate the wrongful acts described in the complaint and to react to such actions (including by way of imposition of the disciplinary sanctions); 7. If necessary, a General Director and/or a Lawyer of the Company may get involved in reviewing and examination of the employee’s complaint; 8. In any case, an author of the complaint, his/her immediate supervisor (manager), the General Director of the Company as well as the Company’s legal director will be notified of the result of examination of the employee’s complaint. Company CEO or delegate will be responsible for revision and update of this document annual or on-need as necessary; the document can be also updated in case of material changes to operating procedures. Conformance with the employee complaints and grievance redress mechanism procedure will be subject to internal and external audits. Any incidents identified during these audits will be reported. This procedure shall be communicated to relevant senior managers via structured emails and distribution lists and is cascaded down their organisations at their discretion in addition to every employee, after recruitment; it should be a part of an induction training. This document shall be made available to all employees.

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The Company management shall periodically discuss the document implementation progress and ensure that any relevant employee-related updates and actions for implementation are subsequently circulated to all relevant team members and other stakeholders. Table 9.2 Grievance Submission Form

Grievance Submission Form Name, Last name

Contact Information ฀ Mail: ______Please indicate the ฀ Mobile:______preferable means of ____ communication (Mail, ฀ E- Telephone, E-mail) mail:______

The language desirable for ฀ Georgian the communication ฀ English

Describe the grievance/claim: What is the complaint about? What is the claim?

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Date of Negotiation: Resolution of Negotiation:

What is the basis of your claim?

Signature: ______Date: ______

9.2 Community Complaints and Grievance Redress Mechanism procedure

Community Complaints and Grievance Redress Mechanism Procedure aims to prevent, mitigate and compensate potential negative impacts and enhance and

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promote potential positive impact that are likely to arise from the project impact to the external stakeholders. The following stakeholders are identified for the purposes of the project activities: project customers including legacy from Sveti, nearby communities, any Environmental and Social non-governmental organisations. The document defines roles and responsibilities for managing external processes, establishes the objectives to implement the requirements of this document. The purpose of this Community Complaints and Grievance Redress Mechanism Procedure is to describe Company’s approach to managing project-related community issues including grievance of the external stakeholders. The procedure is the working document subject to annual renewals/revision. The major roles and relevant responsibilities applicable to the document implementation and maintenance are provided in the table below. Table 9.3: Roles and Responsibilities Role Responsibility Company Holds overall responsibility over the implementation of the CEO Community Complaints and Grievance Redress Mechanism and for the management of Social processes and public consultations; Ensures compliance with the relevant legal standards and implementation of Company Community Grievance Mechanism Issues; Approves this document and resources required for its implementation; Updates and revises this document for operations or on as ‘as required’ basis;

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Environmen Ensures the implementation of the Community Complaints and tal and Grievance Redress Mechanism requirements; Social Maintains complaints records; Manager Is obliged to provide monthly reports, which covers all complaints and grievance related issues; Investigates, reports and follows up on issues, complaints and procedural breaches related to community (keeps a Community Grievance registry – attached to this document); Monitors the implementation of this document and related processes

In line with Company polices, national legislation of Georgia and ADB SPS 2009, the following provisions for handling the grievance from the Company and related contractors’ employees will be used: 1. An external stakeholder has a right to submit open or unanimous, verbal, e-mail and/or written complaint to the project site manager, the Company Environmental and Social Manager or the General Director of the Company. Grievance Submission Form is appended to this document. The following contact information shall be used as the hot lines: [email protected], www.w2.ge, https://www.facebook.com/tetri2/ , phone 032444111; 2. Anonymous grievance boxes shall be installed at the outer perimeter of the site facilities and Company offices. The boxes will be checked on weekly basis; 3. The community complaint is reviewed within 21 (twenty-one) calendar days in strictly confidential manner; 4. When reviewing the community complaint, the principles of legality and fairness must be observed; 5. After reviewing the community complaint, a decision shall be made either on full or partial satisfaction of the complaint or on refusal to satisfy the complaint; 6. If necessary, a General Director and/or a Lawyer of the Company may get involved in reviewing and examination of the community complaint;

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Company CEO or delegate will be responsible for revision and update of this document annual or on-need as necessary; the document can be also updated in case of material changes to operating procedures. Conformance with the community complaints and grievance redress mechanism procedure will be subject to internal and external audits. Any incidents identified during these audits will be reported. This procedure shall be communicated to relevant senior managers via structured emails and distribution lists and is cascaded down their organisations at their discretion in addition to every employee, after recruitment; it should be a part of an induction training. This document shall be made available to all employees. The Company management shall periodically discuss the document implementation progress and ensure that any relevant employee-related updates and actions for implementation are subsequently circulated to all relevant team members and other stakeholders. Table 9.4 Grievance Submission Form

Grievance Submission Form Name, Last name

Contact Information ฀ Mail: ______Please indicate the ฀ Mobile:______preferable means of ____ communication (Mail, ฀ E- Telephone, E-mail) mail:______

The language desirable for ฀ Georgian the communication ฀ English

Describe the grievance/claim: What is the complaint about? What is the claim?

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Date of Negotiation: Resolution of Negotiation:

What is the basis of your claim?

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Signature: ______Date: ______

Any future stakeholder engagements will be conducted using engagement logs and appropriate Minutes of Meetings (MoM).

12. APPENDICES Appendix 12.1 – Noise and Dust monitoring report

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Appendix 12.2 – Noise and Dust monitoring equipment calibration

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Appendix 12.3 – Tree cutting permits – “Chkondideli” and “Mirtskhulava” project sites

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Appendix 12.4 – Stakeholder meeting presentation

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Appendix 12.5 – Sample of Memorandum of Understanding on temporary resettlement (Chkondideli project site)

Memorandum of Understanding

Tbilisi ------2021

From one side, “Optima” LLC (the Company), represented by its director name XXXXX, acting on the basis of the civil regulations, and on the other side name XXXXX/personal number XXXXX (Owner/Resident), agree upon the below.

1. As the Owner/Resident currently resides in an unfinished residence which was constructed by previous developer, the Company will undertake overall completion of the project construction located at 22, Chkondideli street, Tbilisi, Georgia in accordance with the Georgia laws and regulations, and in accordance with the approved construction Permit (Project), the parties agree upon:

1.1. With the 1-month prior notification from the Company, the Owner/Resident agrees willingly and voluntarily to vacate the premises (reference to premises – building, floor, apartment No), removing all personal belongings and to transfer the physical possession to the Company for completion of the construction activities. 1.2. The Company takes responsibility to: a) Prior to signing this Agreement, to fully and transparently explain to the Owner/Resident and its household members the Project and associated activities to be undertaken and why the property is required to be vacant for the period stated in this Agreement; b) Provide regular feedback to the Owner/Resident on progress with the Project (in person, writing, or by telephone), to be undertaken on a quarterly basis as a minimum; c) Provide a point of contact for Owner’s/Resident’s to raise any queries or concerns regarding the Project, which will be responded to in a reasonable amount of time; d) Provide additional reasonable support in the relocation of the Owner’s/Resident’s property and persons, where this is deemed to be appropriate due to Owner/Resident hardship or physical or mental disability; e) Reinitiate the premises development and complete construction activities no later than 30th August 2022; f) In case the construction activities negatively affect the present conditions of the premises, the Company is required to bring them to the initial conditions (as recorded in pre-construction audit and captured in photo format); g) In one month upon completion of the construction activities the Company takes responsibility to transfer the ownership of the premises back to the Owner/Resident no later than 30th August 2022. h) Provide at least 3 months-notice to the Owner/Resident that any delay in completion of the Project and return of the property to the Owner/Resident. For avoidance of any doubt, this clause envisages obligation of the Company to make relevant notice to Owner/Resident and does not grant any right to the Company to prolong the completion term of the construction;

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i) All other terms and conditions are regulated by existing Share Purchase Agreement between the Company and the Owner/Resident.

2. Owner/Resident confirms and agrees to the activities to be undertaken by the Company to complete the Project. That this agreement is willingly and voluntarily entered into by both parties for the stated purpose of the Project.

3. That this Agreement is signed in three parts, by the Owner/Resident, Company and third party witness, with equally valid copies provided to the Company and the Owner/Resident of the premises.

4. The language of the agreement is Georgian.

Parties requisites and signatures

Company „Optima“ LLC Owner Name

Identification code: 405160819

Address: 15 Kazbegi Street, Block D, I Personal #: XXXXXXXXXXX floor, Tbilisi, Georgia Address.: XXXXXXX

______/------/ ______/------/ Witnessed by:

Name:

Signature

Date:

S e T a n x m e b a

q. Tbilisi ------2021 weli

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erTi mxriv, Sps „optima“ (SemdgomSi kompania) , warmodgenili misi direqtoris ------saxiT, romelic moqmedebs sazogadoebis wesdebis safuZvelze da meore mxriv, f/p [----] (SemgomSi mesakuTre), winamdebare SeTanxmebis safuZvelze vTanxmdebiT Semdegze:

1. q. TbilisSi, Wyondidelis q. #22-Si mdebare sacxovrebeli komleqsis mSeneblobis srulad dasrulebis da saqarTveloSi moqmedi kanonmdeblobis moTxovnaTa dacvis mizniT mxareebi Tanxmdebian Semdegze: 1.1. mesakuTre iRebs valdebulebas winamdebare kompaniis gafrTxilebis miRebidan 1 (erTi) Tvis vadaSi Tavis nebiT dacalos q. Tbilisi, Wyondidelis q. #22-Si ,,--” korpusSi ,,- --“ sarTulze mdebare #-- bina sakuTari nivTebisagan da Tavisufal mdgomareobaSi gadasces kompanias miTiTeul korpusSi samSeneblo samuSaoebis dasrulebis mizniT. 1.2. komp ania iRebs valdebulebas: a) ganaaxlos q. Tbilisi, Wyondidelis q. #22-Si mdebare – korpusis samSeneblo samuSaoebis Sesruleba, romlebic unda dasruldes araugvianes 2023 wlis martisa; b) im SemTxvevaSi, Tu binaSi kompania Seasrulebs raime samuSaoebs da daziandeba mesakuTris mier ganxorcielebuli remonti, kompania iRebs valdebulebas aRadginos yvela xarvezi; g) samSeneblo samuSaoebis dasrulebidan 1 (erTi) Tvis vadaSi gadasces mesakuTre s bina mxareTa mier damatebiT SeTanxmebuli pirobebis Sesabamisad faqtobriv mflobelobaSi. 2. mxareebi aseve Tanxdebian, rom kompaniis valdebulebebi ZalaSi Sedis mas Semdeg rac yvela mesakuTre datovebs q. Tbilisi, Wyondidelis q. #22-Si mdebare – korpuss maTTan gaformebuli SeTanxmebebiT dadgenil vadaSi. Tu romelime mesakuTre daarRvevs binis daclis vadas, kompaniis valdebuleba gadaiwevs mesakuTris mier Tavisi valdebulebis Sesrulebis vadis proporciulad. 3. winamdebare SeTanxmeba Sedgenilia 2 egzempliarad qarTul enaze.

mxareebis rekvizitebi da xelmowerebi

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Sps ,,optima” N f/p

sainden. kodi: 405160819

iur. mis.: q. Tbilisi, yazbegis gamz. #15, d bloki, Piradi #: 204873388

4 sarTuli iur. mis.: q. Tbilisi, vanis 6

______/------/ ______/------/

Appendix 12.6 – Noise and Dust monitoring Method Statement

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White Square Affordable Housing Project, Tbilisi, Georgia Environmental and Social Due Diligence

Baseline Environmental Noise and Dust Monitoring Methodology

Mirtskhulava and Chkondideli Construction Sites

Details of document preparation and issue:

Version Prepared by Date Approved by Issue Date Revision 1 Lasha 07.03.2021 ADB 11.03.2021 Bibichadze/Kristina Khabalashvili

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Table of Contents

1. Introduction ...... 186 ...... Project Background ...... 186 ...... Georgian and IFC Standards ...... 186 ...... Noise Standards ...... 186 ...... Dust (PM2.5 and PM10) Standards ...... 186 2. Monitoring Locations ...... 187 3. Noise Monitoring ...... 188 ...... Monitoring duration ...... 52 ...... Monitoring Equipment ...... 53 ...... Monitoring Methodology ...... 53 4. Dust Monitoring ...... 190 ...... Monitoring Duration ...... 42 ...... Monitoring Equipment and Monitoring Methodology ...... 44

List of Figures

Figure 2-1 Monitoring locations at Mirtskhulava site ...... 187 Figure 2-2 Monitoring locations at Chkondideli site ...... 188 Figure 3-1 Noise Meter and Noise Meter Calibrator ...... 53 Figure 4-1 Dust monitoring equipment ...... 45

List of Tables

Table 1-1 IFC and Georgian Noise Standards ...... 51 Table 1-2 IFC/WHO Air Quality standards ...... 41

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List of Abbreviation

Abbreviation Definition dBA A-weighted decibels EHS Environmental, Health and Safety IEE Initial Environmental Examination IFC International Finance Corporation PM Particulate Matter WHO World Health Organization

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Introduction

Project Background

The White Square affordable housing project comprises of development of three residential areas, out of which two – “Mirtskhulava” and “Chkondideli” sites – are currently assessed through Environmental and Social Due Diligence, with Initial Environmental Examination (IEE) to be one of its two agreed outcomes. The White Square “Mirtskhulava” and “Chkondideli” project sites are both located in Didube district of Tbilisi, on the streets with the same respective names, which are both heavily settled residential area. At the time of the site visit, most of the construction activities covering 9 residential buildings at Mirtskhulava and 11 residential buildings at Chkondideli were under construction, while 1 building construction at each site and the landscaped areas and playgrounds were not initiated. The project management office reported that the overall Project is expected to be completed in 2023. The baseline noise and dust monitoring will be conducted by Paragon Ltd as part of the data collection for the Initial IEE. Georgian and IFC Standards

Noise Standards

Technical Regulation N398 - "On the norms of acoustic noise on the premises of residential buildings and public / public institutions. August 2017 Government of Georgia defines the reference criteria for background noise in and around work place and residential buildings. It establishes noise thresholds for the daytime evening and nighttime. These threshold values apply to the boundaries of residential areas. The boundary noise level during construction period is exempt from the Georgia Standard of Environment Noise during the day-time (see article 1 section 2) therefore combination of the IFC Environmental Noise Management Guideline and Georgia Noise Standards (which are at cases more stringent) were utilized with the project applicable standards provided within the table below Table 12-1 IFC and Georgian Noise Standards

Receptor IFC Noise Georgian Noise standard Applicable Noise standard standard (dBA) (dBA) (dBA)

day night day evening night day evening night

Residential 55 45 50 45 40 55 45 40

Noise impacts should not exceed the levels presented in Table above, or result in a maximum increase in background levels of 3 dBA at the nearest receptor location off-site.

Dust (PM2.5 and PM10) Standards

The dust concentration is subject to World Health Organization (WHO) standards, which are also referenced by International Finance Organization (IFC). In addition to that the Environmental Quality Condition Normative, Technical Regulation N 297/N addition 38/N is available in Georgia, however listing air quality standards per specific chemical composition

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rather than Particulate Matter size, therefore WHO standards are considered to be applicable for the purposes of the monitoring.

Table 12-2 IFC/WHO Air Quality standards Parameter Averaging Period Guideline Value in g/m3 Particulate Matter PM 10 1 year 70 (Interim target-1) 50 (Interim target-2) 30 (Interim target-3) 20 (guideline)

24 hours 150 (Interim target-1) 100 (Interim target-2) 75 (Interim target-3) 50 (guideline) Particulate Matter PM 2.5 1 year 35 (Interim target-1) 25 (Interim target-2) 15 (Interim target-3) 10 (guideline)

24 hours 75 (Interim target-1) 50 (Interim target-2) 37.5 (Interim target-3) 25 (guideline)

Monitoring Locations

Two residential areas have been identified at each Mirtskhulava and Chkondideli constructions sites for the purposes of dust and noise baseline levels monitoring in consideration with their closest location to the construction site boundaries. Figure 12-1 Monitoring locations at Mirtskhulava site

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Figure 12-2 Monitoring locations at Chkondideli site

Noise Monitoring

Monitoring duration

As per IFC 2007 General EHS Guidelines (1.7 Noise), Noise monitoring programs should be designed and conducted by trained specialists. Typical monitoring periods should be sufficient for statistical analysis and may last 48 hours with the use of noise monitors that should be capable of logging data continuously over this time period, or hourly, or more frequently, as

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appropriate (or else cover differing time periods within several days, including weekday and weekend workdays). Project’s as well as any other non-essential night activities are currently restricted by pandemic related governmental regulations with curfew established for the timeframe of 9 pm – 6 am. Hence around-the-clock continuous monitoring would be challenging for completion, while monitoring covering differing time periods within several days, including weekday and weekend workdays is suggested to be conducted during the hours not restricted by the curfew. The projects’ working hours are set for the specific timeframe from 9 am to 6 pm. The expected pick hours in relation with noise in urban area are 9 am – 11 am and 4 pm – 6 pm. Taking that into consideration and from the pandemic constraints described above, the following monitoring scheme is suggested to apply to the project site baseline noise monitoring data collection to assure the measurement obtained is representative of the project activities variations: • Conduct noise monitoring at each point of each project site during a weekday • Conduct noise monitoring at each point of each project site during a weekend • Ensure the monitoring period of continuous 1-hour measurement will be cower expected pick hours and period between picks at all locations (3 session of the monitoring with 1 hour duration will be performed at each location) Monitoring Equipment

All noise data will be measured using a Rion NL52 integrated sound level meter class 1 and class 1 field calibration Rion NC 74 (Figure 3-1). Figure 12-3 Noise Meter and Noise Meter Calibrator

Monitoring Methodology

Noise is defined as unwanted sound. The unit of measurement is the decibel. Readings are taken on a logarithmic scale. This means that 85dB is ten times the intensity of 80dB and a hundred times more than 70dB. A rise of 3dB is roughly the equivalent of doubling the noise output. The effects of noise are deafness, either temporary or permanent, and irritation or annoyance. Loud explosive noises can produce instant and short-term deafness, which could cause

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permanent damage as can, prolonged exposure. Long exposure can wear people down and effect their ability to function properly. The following noise indices to be measured during the monitoring: • LAeq – the equivalent continuous sound pressure level over the measurement period. • LAmax – the maximum sound pressure level occurring within the defined measurement period. • LAmin – the minimum sound pressure level occurring within the defined measurement period. • LA90 – the sound pressure level exceeded for 90% of the measurement period and is used within BS 4142 as a descriptor of background noise level. • LA10 – the sound pressure level exceeded for 10% of the measurement period. To receive accurate readings, calibration of the equipment will be conducted before each measurement. All measurements will be taken with a windscreen on the microphone. Minimum 3.5m distance from monitoring point and any reflective surfaces at all locations to be maintained and the monitoring equipment will be set on tripod at minimum 1.5m high from the ground level. Noise measurements will not be undertaken in windy weather conditions (up than 5m/s). Wind speed will be measured by portable meter during whole season of monitoring. Site management to ensure that all site activities are shut down during the monitoring period. All collected data will be logged in the software for further analyses and interpretation. Consultant will ensure that interpretive noise monitoring report is developed based on the measurements obtained

Dust Monitoring

Monitoring Duration

As it was pointed in chapter 3.1, night activities are currently restricted by pandemic related governmental regulations with curfew established for the timeframe of 9 pm – 6 am. The projects’ working hours are set for the specific timeframe from 9 am to 6 pm. Therefore, points of interest for monitoring are the time period when construction activities will be undertaken in future. The proposed methodology includes three 1-hour measurements at all monitoring locations. The Average values for all three measurements are considered to be an average 24-hour value.

Monitoring Equipment and Monitoring Methodology

During monitoring activities consultant’s field team will use dust monitoring tool Dust Trak DRX Desktop aerosol monitor – 8533. This equipment simultaneously allows the measurement of the PM10 and PM2.5. All collected data will be logged in the software for further analyses and interpretation. To collect representative samples, monitoring will be undertaken in dry weather conditions. Site management to ensure that all site activities are shut down during the monitoring period. All collected data will be logged in the software for further analyses and interpretation. Consultant to ensure that interpretive noise monitoring report is developed based on the measurements obtained.

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Figure 12-4 Dust monitoring equipment

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Appendix 12.7 – Annex on “Chkondideli” Temporary Relocation Plan White Square Affordable Housing Project

“Chkondideli” Temporary Relocation Plan

1. Introduction

This Temporary Relocation Plan (Plan) provides information regarding Optima’s LLC (the Company) current and planned undertakings with regard to the management of risks and impacts associated with the temporary vacation of residents occupying 40 (39 households) unfinished apartments in the “Chkondideli” project site.

The need for the current residents to vacate the apartments has arisen because:

• The Company is currently under contract to complete the apartment blocks to the specified standard (as agreed in contract dated 27 August 2019 between the Company and pervious developer Sveti LLC) • The Company has determined that the buildings are currently inappropriate for habitation due to the absence of proper Health, Safety, Social and Security conditions causing the consequent risks • In order for the Company to complete the works as agreed, it requires the area to be cleared of residents to avoid H&S impacts associated with construction works

In order to avoid triggering ADB’s involuntary resettlement safeguard requirements, the Company has sought to plan and manage this issue along the lines of a ‘negotiated access’ approach, which precludes resorting to expropriation through eminent domain / expropriation, but which requires complete and uncoerced agreement from the residents to voluntarily vacate the premises. However, it is also recognised that for residents to remain in their properties, this would a) prevent the project from proceeding prompting complicated legal proceedings, and b) put residents who wished to remain in a health and safety high risk environment until project completion. As such the Project also merits consideration as constituting involuntary displacement as a result of residents not being able to safely occupy their residences. In roder to address this situation, the Company has developed this plan which requires the Company to agree with ADB:

• the processes, policies and laws that are applicable • the negotiation strategy to ensure negotiations with displaced persons openly address the risks of asymmetry of information and bargaining power of the parties involved • to engage an independent external party to document the negotiation and settlement process and provide third party validation

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• mechanisms for calculating replacement costs of assets (for example, damaged in the process of building work while property is vacated) • measures with affected residents for compensation or additional support associated with delayed return of properties making households ‘less better off’ as a result (including assessment of affected persons residential and socio-economic situation at the time of notification of delay) • record keeping requirements

The Company has developed a Memorandum of Understanding (MoU) to register written agreement between residents and the Company (witnessed by “Paragon” LLC – the Consultant) on the terms of the vacation of the property; provided residents with a commitment to obtain regular updates of progress; agreed a deadline for the properties to be ready to return to residents for re-habitation; contact details to raise grievances or complaints; and also committed to working to support residents if their alternative accommodation arrangements become unavailable and / or if the deadline for return of the completed apartments is exceeded and additional support is needed by the residents.

In parallel with the collection of the signatures of MoUs, the Company (also witnessed by the Consultant) has undertaken household socio-economic surveys to determine if there are any vulnerable households or parties currently residing in the apartments. An additional purpose of the socio-economic survey was to obtain details on individual households to determine any risks associated with costs for additional housing as they are vacating the “Chkondideli” project site apartments. For the above determination, the socio-economic checklist was filled in by individual household upon which the Company has agreed to undertake additional support measures on a case by case basis and where required. The template of the checklist is provided as an Appendix A to the Annex.

2. Background As reflected within the Initial Environmental Examination section 5.4.1 Demography, 5.4.1.1 Socio- economic analysis, some residential apartments of the incomplete buildings of “Chkondideli” project site have been identified as being occupied by owners, owner family members and / or representatives (the “households”). Upon the previous developer Sveti ceased the project implementation, the number of households of the “Chkondideli” project sites made a decision in 2017 to move into the incomplete apartments in fear of losing their investments and to prevent any third parties from moving in.

The conditions of the incomplete apartments were the so called “black frame”, i.e. only carcass of the buildings was available (walls, floor, ceilings). There was the lack of major utilities and infrastructure such as water, sewage disposal system, gas or electricity. The following major health, safety, social and security risks were identified as part of the “Chkondideli” project site audits:

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Health and Safety (H&S): Health and Safety aspects are challenging and difficult to mitigate due to current stage of project development with details described throughout this note.

Security: The area isn’t fenced and building entrances have no doors, which leads to trespassers, some of those (including drug users), taking shelter in the empty areas of the buildings. Areas are used as dumping grounds for garbage and faeces.

Utilities infrastructure availability: Lacking basic infrastructure, the wastewater was discharged into the underground parking areas that created unsanitary conditions. The clean-up of the area had been conducted monthly (GEL 1,000 per visit service). Current residents are still connected to electricity and water lines informally.

Utilities payments: An informal connection to the electricity and water utilities causes the payments to be done based on the commercial tariffs which is for electricity - 70% higher and for water - 10 time greater than residential tariff until the building is commissioned.

Below provides some understanding on the utilities cost. Commercial Tariffs x Average Consumption per family (water + electricity):

• Electricity 800kw * 0.33 = 264 GEL (per family) – commercial • Electricity 800kw * 0.19 = 152 GEL (per family) – residential • Monthly averaged utility saving per family – 112 GEL • Water 24 m³/month * 6 GEL = 144 GEL (per family) – commercial • Water 24 m³/month * 0.5 GEL = 12 GEL (per family) – residential

Basic infrastructure availability

•Roof is not available or not in proper condition with rainwater penetrating the building

•Building façade is incomplete causing the risk of materials falling from the building

•Façade hydro and thermo isolation isn’t complete

•Rails on balconies and stairwells aren’t installed

•Fire safety provisions aren’t available anywhere in the building

•Lifts are not installed, and shafts are currently open

•Doors aren’t installed at the entrances

•Ventilation system isn’t available in the apartments

•Utility infrastructure system and proper equipment storage spaces aren’t available

•Access to parking area isn’t constructed

•Outdoor spaces infrastructure and landscaping isn’t available

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The following mitigation measures to address the identified risks are split between those already implemented, those to be implemented as soon as practically possible (and before waiting for the temporary relocation to be initiated), and those that would be implemented upon recommencement of the project activities as requiring special equipment to be used and thus adding to the unsafe condition for the current residents of the project site.

1.Mitigation measures already implemented:

•The temporary connection to the wastewater system that’s been already completed for the buildings with current residents to prevent unsanitary conditions. The mitigation was implemented in April 2021 and the cost for it was GEL 36,000

•Fencing of the project area for security purposes. Permit application was filed to the Tbilisi municipality at the beginning of June and is expected to be ready by 21st of June. Contract (cost of USD 8,800) is in place with the company to be completing the fencing. The fencing is planned to be completed by the end of June.

2.Mitigation measures to be implemented as soon as practically possible by 30th of June for the first two points and 15th of July for the third point:

•Balconies and stairwells where people currently reside will be barricaded

•The lift shafts within the buildings where people currently reside will be barricaded

•The connections to the electrical line for the buildings where people currently live will be inspected and mitigation measures applied as soon as practically possible to eliminate electrical fire hazard and electrocutions risks.

3.Mitigation measures to be implemented as part of the overall project completion:

•Roofs installation/repair.

•Building façade completion.

•Façade hydro and thermo isolation.

•Fire safety system installation.

•Lift shafts – lifts installations.

•Doors at each entrance installations.

•Ventilation completion.

•Utility infrastructure system and proper equipment storage completion.

•Access to parking area completion.

•Outdoor spaces infrastructure and landscaping completion.

•All internal utilities infrastructure for gas, water, wastewater, electricity connections.

•Residents registration with utility companies to switch to the residential tariffs instead of commercial, once these connections are available.

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•Any other mitigations required as part of the overall completion of the project as per approved design.

3. Household Socio-economic characteristics and analysis

During the development of the IEE 26 households were identified as permanently residing at “Chkondideli” project site. During the subsequent process of the collection of the signatures for the MoU, nine additional households have been identified as having the premises occupied after the latest update on the case was conducted and 4 households having their premises slightly refurbished and locked, while residing elsewhere. There is one household that owns two apartments. Thus, a total of 39 households signed the MoU for 40 residential areas (apartments).

The list of the households is provided in the table below together with the information on whether they currently live in the incomplete buildings of the “Chkondideli” project site, premises references and date the MoUs were signed.

# Household Status Signature Date Building Apartment #

1 Khatuna Berukashvili Currently resides in building 13/05/2021 4 24

2 Margalita Chelidze Currently resides in building 11/05/2021 4 32

3 Natia Charashvili Currently resides in building 19/05/2021 4 8

4 Inga Mamasakhlisi Currently resides in building 11/05/2021 4 68

5 Lela Biashvili Currently resides in building 10/05/2021 4 69

6 Giorgi Magradze Currently resides in building 11/05/2021 4 30

7 Marine Gvanidze Currently resides in building 19/05/2021 4 57

8 Suliko Sandodze Currently resides in building 11/05/2021 4 27

9 Ana Kiria Currently resides in building 19/05/2021 4 74

10 Tsutsa Tsakadze Not resident in building 13/05/2021 4 14

11 Keti Gangia Not resident in building 11/05/2021 4 54

12 Maia Barkaia Currently resides in building 11/05/2021 4 37

13 Giorgi Diasamidze Currently resides in building 13/05/2021 4 35

14 Giorgi Shamanauri Currently resides in building 19/05/2021 4 50

15 Aleksandre Kituashvili Currently resides in building 10/05/2021 3 11

16 Lika Razmadze Currently resides in building 11/05/2021 3 16

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17 Beka Tsiklauri Currently resides in building 11/05/2021 3 15

18 Sergo Sxiladze Currently resides in building 11/05/2021 3 9

19 Besik Kostava Currently resides in building 13/05/2021 3 12

20 Guram Kituashvili Currently resides in building 11/05/2021 3 2

21 Lela Kutalia Currently resides in building 11/05/2021 5 7

22 Eter Mikeladze Currently resides in building 11/05/2021 5 3

23 Malkhaz Tsintsadze Currently resides in building 11/05/2021 4 18

24 Nana Javakhidze Not resident in building 11/05/2021 4 58

25 Archil Gangia Currently resides in building 11/05/2021 4 46

26 Sophio Gobejishvili Currently resides in building 11/05/2021 4 43

27 Shorena Tsertsvadze Currently resides in building 11/05/2021 4 60

28 Darejan Kapanadze Currently resides in building 11/05/2021 4 98

29 Mariam Gelashvili Currently resides in building 11/05/2021 4 6

30 Giorgi Gurashvili Currently resides in building 11/05/2021 4 56

31 Marina Jabidze Currently resides in building 10/05/2021 2 1

32 Neli Maisuradze Currently resides in building 10/05/2021 5 2

33 Kristine Mamardashvili Currently resides in building 19/05/2021 4 44

34 Irine Gelbakhiani Currently resides in building 13/05/2021 4 11

35 Eldar Kuljanishvili Currently resides in building 13/05/2021 4 21

36 Vazha Giorgadze Currently resides in building 13/05/2021 4 19/20

37 Sophio Gobejishvili Not resident in building 13/05/2021 4 38

38 Malkhaz Meckhvarishvili Currently resides in building 19/05/2021 4 31

39 Tornike Barnovi Currently resides in building 13/05/2021 4 67

Based on the filled in checklists, the analysis of socio-economic status of the individual households residing at “Chkondideli” project site was conducted. The analysis revealed there were no vulnerable households identified, i.e., no socially vulnerable, disable people, single unemployed parents, female- headed or elderly care-givers. None of the household or their family members were categorised as IDP (Internally Displaced People).

As a minimum one member of each household was identified to be employed. The responses to the questions on the income allowed to average it per household to be ca. GEL1600, while response on

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the outcome – the latter to be ca. GEL1080. It is noted that households are required to have a regular income in order to meet the regular payments for the apartments. The discussions with the households prove no business activities taking place within the premises, which was also reflected within the checklist.

It’s been identified that 11 out of 39 households have already fully paid for their apartments, while the rest of the households are using internal (the Company) phased payment approach.

In total there are 111 people currently residing within the “Chkondideli” project site. Out of those 18 are children, aged between infant (1.5 m.o) and teenager (14 y.o.) and 4 people of pension age of 76, 86, 67, 70 y.o. with none of them being a single resident, but all living with the providing families, and therefore not considered as vulnerable as a result of project activities.

As indicated above, out of 39 households, 4 have never moved in the “Chkondideli” apartments, though they had these apartments slightly refurbished (entrance door and windows installed), while living elsewhere. Out of the remainder 35 households, 27 already made a decision to rent apartments upon vacating “Chkondideli” and until the construction is completed, while 8 households are still undecided on whether to rent, move to the relatives or their owned suburb hometowns. Consequently, all households will have alternative accommodation for the duration of the agreed property vacation term.

4. Stakeholder engagement

4.1 MoU communication and socio-economic checklist completion There were three meetings with the residents as part of the MoU signatures collection and socio- economic checklist completion, which took place on the 10th, 11th, 13th and 19th of May 2021, conducted by the Company representatives witnessed by the Consultant representatives. The Company representatives communicated to the residents the detailed content of the MoU. The communication described a process related to the premises' vacation activities and the requirement for the Company to have access to the premises with consent from the owner.

All MoUs have been signed by the households upon their availability during the first three meetings. There were 7 MoUs initially signed by the formal representatives of the households in absence of the latter. However, 6 out of those 7 households signed the MoUs during the last meeting on 19th of May and the 7th remaining household confirmed via an email the signature made by a third-party formal representative.

Taking the inappropriate conditions of the buildings into the consideration, the communication on the project re-commissioning from the Company to the residents demonstrated the eagerness of the latter to voluntarily vacate premises to allow for their development completion. The communication

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was assessed as excessively positive with the residents satisfied with the long-awaited construction processes renewal and defined project completion timeframe, expressing the aspiration for the acceleration of the process if such necessity occurs. The latter has been demonstrated by the swift collection of the agreement signatures.

The major reason for such positive reaction from the residents was the conditions their families currently live in, including lack of safety precautions already described above, basic household-rated utilities and necessary infrastructure. In addition to that the cost paid for the commercially rated utilities is seen to suffice coverage of the rental where it would be required. Another reason communicated by the households is the expectation for the residential areas’ cost to become competitive against real estate market upon completion of the project.

All meetings and discussions between the Company and the residents have been conducted in a friendly, cooperative manner. All questions and inquiries from the residents have been answered and clarified by the Company. Process was reflected within the relevant Minutes of Meeting (MoM) made available along with the current Annex and to be provided as an Appendix to the IEE as well as the relevant photographs which have also been taken during the meetings.

5. Household agreements / Implementing the agreement In accordance with the MoU, the Company will undertake overall completion of the project construction located at 22, Chkondideli street, Tbilisi, Georgia, in accordance with the Georgia laws and regulations, and in accordance with the approved construction Permit (Project) and contract with the households.

It’s been agreed that the households with the 1-month prior notification from the Company will willingly and voluntarily vacate the premises while the Company takes responsibility to reinitiate the premises development and complete construction activities no later than 30th August 2022, and in case the construction activities negatively affect the present conditions of the premises, to bring them to the initial conditions (as would be recorded in pre-construction audit and captured in photo format).

The template of the written MoU is provided as an Appendix B to the Annex.

The Company expressed the readiness to provide the support with relocation in case any vulnerable household would be identified, however none such case was demonstrated. Nevertheless, this option remains available till the actual vacation of the premises takes place (if any household determined in the intervening period that they are unable to move out due to no alternative accommodation due to cost / job loss, etc.)

5.1 Post-relocation monitoring, engagement and complaints handling

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As per the MoU to provide regular feedback to the households on progress with the construction activities (in person, writing, or by telephone) communication will be undertaken on a quarterly basis as a minimum and a record of the engagement and any issues maintained in an issues log.

To raise any queries or concerns regarding the project development, the Community Complaints and Grievance Redress Mechanism reflected within the IEE will be used by the households.

5.2 Return of the property – what is the process As per MoU, in one month upon completion of the construction activities and no later than 30th August 2022, the Company takes responsibility to transfer the ownership of the premises back to the households and does not grant any right to the Company to prolong the completion term of the construction.

In an unlikely event, these buildings completion is delayed beyond the August 2022 timeframe as indicated within the MoUs, the Company takes responsibility to revisit the individual households’ needs on a case-by-case basis. The Company commits that 2 months prior to August 2022 timeframe, if the construction schedule is projected to run past August 2022 that company will contact each temporarily relocated household individually and provide necessary support where required such as renting cost and utilities cost cover for the delayed period.

As part of this delay notification process and general engagement over the completion process, the Company will undertake specific assessment of each household’s employment and general socio- economic status, taking into consideration the following vulnerability indicators:

• Employment status • Negative changes in household income and purchasing ability • Unanticipated risk associated with rent increases in temporary relocation residence • Increase in vulnerable people within the household • Risk to livelihood / employment status as a result of increased travel time • Risks to living standards as a result of increased distance required to travel to access public services • Risks to safety as a result of unsafe living conditions (due to security concerns, for example)

Te Company will review the results of this assessment and ensure no residences are worse off as a result of the projects impacts associated with relocation. The results of this assessment will be recorded and shared with ADB.

Property owners (including those which are not currently residing in the project buildings) all have legal recourse for delayed finalisation and handover of their properties to which the Company is liable as defined in the contract between the developers and the property owners. All residents were made

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aware of this and the grievance mechanism during the MoU signing with this provision being stated in the MoU document (refer 1 (i)).

6. Appendices 6.1 Appendix A – Socio-economic checklist (questionnaire)

Tbilisi Affordable Housing project - “Optima” LLC

“Chkondideli” project site – IEE social data

May 2021

Owner’ family name______

Apartment reference/m²______

No Item Yes No Comment

1 Is the household classified as unemployed?

2 Is the household classified as below national poverty line?

3 Any disabled members of a household (physically/mentally) or members with long term illnesses?

4 Is the household female-headed?

5 Is the household provided for by single unemployed parent?

6 Is the household provided for by elderly?

7 Is the household categorised as IDP (Internally Displaced People)?

8 Household members: How many people currently reside in the property, what are their ages, gender

9 Employment status: How many occupants are working? How many have formal permanent jobs?

10 Income / Expenditure: average monthly HH income. Average household expenditure

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11 Have you completed the payment for the apartment? If not, please indicate within the comment how many months of payment is remaining.

12 Do any HH members undertake income generating activities in the apartment?

13 Please describe the reasons why you moved into this property before it was completed

14 Has the Company provided you with the option to remain in the property:

a) While the work is done on your property?

b) And not have the work done at all?

15 Please provide details about where you will relocate to (family, new rental location, other)

16 Will you be paying rent at the relocation destination

17 Will you be staying at the temporary location for the duration of the renovation period?

18 Has the communication and engagement with Company about vacating the property been satisfactory?22

6.2 Appendix B – Memorandum of Understanding (MoU)

Memorandum of Understanding

Tbilisi ------2021

From one side, “Optima” LLC (the Company), represented by its director name XXXXX, acting on the basis of the civil regulations, and on the other side name XXXXX/personal number XXXXX (Owner/Resident), agree upon the below.

22 Please provide any comments or feedback.

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5. As the Owner/Resident currently resides in an unfinished residence which was constructed by previous developer, the Company will undertake overall completion of the project construction located at 22, Chkondideli street, Tbilisi, Georgia in accordance with the Georgia laws and regulations, and in accordance with the approved construction Permit (Project), the parties agree upon:

5.1. With the 1-month prior notification from the Company, the Owner/Resident agrees willingly and voluntarily to vacate the premises (reference to premises – building, floor, apartment No), removing all personal belongings and to transfer the physical possession to the Company for completion of the construction activities. 5.2. The Company takes responsibility to: j) Prior to signing this Agreement, to fully and transparently explain to the Owner/Resident and its household members the Project and associated activities to be undertaken and why the property is required to be vacant for the period stated in this Agreement; k) Provide regular feedback to the Owner/Resident on progress with the Project (in person, writing, or by telephone), to be undertaken on a quarterly basis as a minimum; l) Provide a point of contact for Owner’s/Resident’s to raise any queries or concerns regarding the Project, which will be responded to in a reasonable amount of time; m) Provide additional reasonable support in the relocation of the Owner’s/Resident’s property and persons, where this is deemed to be appropriate due to Owner/Resident hardship or physical or mental disability; n) Reinitiate the premises development and complete construction activities no later than 30th August 2022; o) In case the construction activities negatively affect the present conditions of the premises, the Company is required to bring them to the initial conditions (as recorded in pre-construction audit and captured in photo format); p) In one month upon completion of the construction activities the Company takes responsibility to transfer the ownership of the premises back to the Owner/Resident no later than 30th August 2022. q) Provide at least 3 months-notice to the Owner/Resident that any delay in completion of the Project and return of the property to the Owner/Resident. For avoidance of any doubt, this clause envisages obligation of the Company to make relevant notice to Owner/Resident and does not grant any right to the Company to prolong the completion term of the construction; r) All other terms and conditions are regulated by existing Share Purchase Agreement between the Company and the Owner/Resident.

6. Owner/Resident confirms and agrees to the activities to be undertaken by the Company to complete the Project. That this agreement is willingly and voluntarily entered into by both parties for the stated purpose of the Project.

7. That this Agreement is signed in three parts, by the Owner/Resident, Company and third party witness, with equally valid copies provided to the Company and the Owner/Resident of the premises.

8. The language of the agreement is Georgian.

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Parties requisites and signatures

Company „Optima“ LLC Owner Name

Identification code: 405160819

Address: 15 Kazbegi Street, Block D, I Personal #: XXXXXXXXXXX floor, Tbilisi, Georgia Address.: XXXXXXX

______/------/ ______/------/ Witnessed by:

Name:

Signature

Date:

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