The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the attached Environmental and Social Action Plan.
- PS1: Social and Environmental Assessment and Management Systems
As required by the Ministry of Environment, Energy and Water (MEEW), the Sponsor commissioned an independent Environmental Impact Assessment (EIA) for the proposed development (dated May 2006), including a detailed mitigation and monitoring program covering both the construction and operational phases of the project. Although not required by MEEW, the Sponsor also commissioned a separate independent EIA (March 2006) to guide both the demolition of the first, partially completed resort development that was halted on 17 May 2000 as well as site preparation activities for the new project. IFC has reviewed both EIAs, both of which received MEEW approval in June 2006 (Phase 1 EIA approval 11June and Phase 2 EIA approval on 14 June). Shangri-La will implement the mitigation and monitoring programs recommended in the EIAs in accordance with its corporate Environmental Management System (EMS), which is implemented at all of the company’s properties to manage and monitor environmental and social performance on an ongoing basis. The company has established a program to obtain ISO 14001 certification for all its EMSs; to date, 20 properties have been certified. ISO auditors (Lloyd''s Register of Quality Assurance) inspects each of the hotels twice yearly to ensure not only that the EMS is being maintained but that continual environmental improvement is achieved through ongoing monitoring and the setting of new environmental objectives and targets.
All of the ISO certified properties (about 20 properties in the Group) have designated Environmental Managers or an Engineer to oversee EMS related matters, who report to the Resident Manager of the hotel or the Director of Engineering, depending on the size of the property. Shangri-La Maldives Resort & Spa will have an Environment and Fire Life Safety Manager who will report to the Director of Engineering and will be responsible for the implementation and subsequent assessments/audits of the EMS for the resort. Lloyd’s Register of Quality Assurance sends a representative to inspect the hotels every six months to ensure not only that the system is being maintained but that continual environmental improvement is achieved by setting new environmental objectives and targets. Additionally, Engineering Audits conducted by the Regional or Area Directors of Engineering under the guidance of the Group Director of Engineering at Shangri-La’s corporate office also review the EMS procedures to ensure compliance with standards and EMS Manual. Government of the Maldives law requires operators to obtain a number of permits/approvals before they can commence operations, including an EIA Decision Note, electricity generation permit, and waste water disposal permit. In addition, all desalination plants must be registered with the Maldives Water and Sanitation Authority. Shangri-La has provided IFC with copies of those permits/registrations that have already been obtained and has agreed to provide copies of subsequent permits/authorizations to IFC within 30 days of receipt from the relevant Government authority.
- PS2: Labor and Working Conditions
The Shangri-La Group has in place a comprehensive human resources (HR) policy and procedures, and places considerable emphasis on recruiting, training and retaining staff. The company’s HR policy contains an explicit commitment to be an equal opportunity employer that does not discriminate on the basis of race, religion, gender, age, family status or disability. The policy allows for the formation of worker’s organizations, and contains specific provisions regarding the protection of the workforce, including detailed occupational health and safety procedures and requirements. HR practices are designed to “ensure fairness and opportunities for growth, and to provide the environment, processes and motivation to enable employees to fulfill their potential.” The HR procedures include a mechanism for employees to raise and seek redressal for grievances. All employees are given internal career counseling, annual performance assessments, and job/career management guidance. Each property is required to allocate a specific budget for training and development, and the General Manager is personally responsible for ensuring that all the allocated funds are spent each year. Both employee retention rates (80%) and career mobility within the Group are among the best in the industry. Corporate HR Policies as well as training programs are posted on the Group’s intranet for the guidance of all hotels/resorts in the Group. HR policies and procedures specific to Shangri-La Maldives are currently being prepared. These will be based on those of Corporate HR guidelines as well as the requirements of the local labor laws.
Shangri-La adheres to stringent life and fire safety standards at all of its properties. The company has reviewed IFC’s Life and Fire Safety (L&FS) guidelines and indicated that the Villingilli development will comply fully with these. In accordance with the L&FS Guidelines, the company will submit an L&FS Master Plan to IFC that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures as a condition of first disbursement. The L&FS Master Plan will be prepared by a suitably qualified professional acceptable to IFC who will certify that the design meets the requirements of IFC’s guidelines. On the basis of the Master Plan, IFC will determine whether additional conditions in a Corrective Action Plan (CAP) are needed, and agree with the company on a mutually acceptable time frame for implementing these conditions. The qualified professional who prepares the L&FS Master Plan will also undertake a review at the time of L&FS systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design. Findings and recommendations of this review may also be incorporated into the CAP, as needed, along with a mutually acceptable time frame for implementation.
Shangri-La has undertaken a corporate program to identify and work closely with ‘preferred’ suppliers who share their corporate commitment to quality, ethical behavior and transparency. Corporate Purchasing Policy includes guidelines issued to hotels in the Group for developing environmentally responsible procurement practices.
Shangri-La has included specific occupational health and safety (OHS) provisions in the contracts it enters into with construction contractors to ensure that these contractors comply with both Government of India and World Bank Group (WBG) occupational health and safety requirements. On-site management of construction contractors is carried out by Shangri-La’s projects management team resident at Villingilli island.
- PS3: Pollution Prevention and Abatement
Shangri-La Hotels and Resorts is a founding member of the Asia Pacific Hotels Environmental Initiative. In accordance with the Group''s Environmental Policy, all Shangri-La and Traders hotels have implemented “Green Programs” to identify ways to reduce waste, eliminate practices that damage the environment and promote environmental awareness throughout their operations and with key suppliers. As at all of its properties, the pollution prevention and abatement program implemented at the Maldives property will be based on the principles set forth in Shangri-La’s corporate EMS, with the goal of ensuring regular, ongoing performance monitoring and continual improvement. The power requirement during construction and operation will be provided by four x 2000 kVa diesel generator sets, two of which will be in use at any given time. Light diesel fuel (sulfur content of less than 0.5%) will be used. Generators will be housed in soundproof buildings to ensure compliance with WBG noise limits. Consistent with Shangri-La’s corporate energy efficiency efforts, waste heat recovered from flue gas will be used to generate hot water for facilities near the generator plant. Solar collectors equipped with storage capacity will be installed on guest rooms/villas and used to preheat water. Shangri-La’s EMS stipulates that all lighting fixtures will utilize energy saving light bulbs and energy efficient machinery and appliances will be sourced wherever possible. All chilling and air conditioning units will utilize refrigerants allowed under the Montreal Protocol. High efficiency air conditioners and chillers will be installed, in accordance with a corporate-wide program to replace low efficiency refrigeration and chilling equipment at all properties, an initiative that has achieved energy savings of 20%.
As is the case throughout the Maldives, water for both the construction and operation phases will be obtained from desalination plant (100 cubic meters per day capacity) that draws from boreholes drilled to a depth below the freshwater level. Extracted seawater will be treated by pre-filtration and reverse osmosis (RO) to produce potable water that meets both national and WHO drinking water standards. Shangri-La requires that rainwater harvesting facilities are installed at all of its properties. Water consumption will be monitored on a monthly basis and programs to minimize water use will be implemented, in accordance with Shangri-La’s corporate EMS initiatives and requirements. All waste water (including backwash from swimming pools) will be treated in an on-site waste water treatment plant that will meet or exceed WBG discharge standards for all relevant parameters.
In accordance with its corporate environmental policy, Shangri-La has set up a comprehensive waste minimization and management program for both the construction and operational phases of the project. Shangri-La’s onsite construction management team conducts weekly monitoring of all solid and liquid wastes generated, and maintains written records of volumes of each type of waste and the manner of disposal. Once operations commence, the company will implement a comprehensive waste minimization, separation, management, and disposal program in accordance with the requirements of its corporate EMS, as well as the strict laws and regulations established by the Government of the Maldives regarding waste management.
- PS4: Community Health, Safety and Security
Although the project is not expected to pose significant risks to community health, safety and security, Shangri-La will nonetheless include an Emergency Preparedness and Response Plan in its EMS, covering actions that will be taken in the event of an emergency and defining the requirements and standard operating procedures of security personnel.
- PS6: Biodiversity Conservation and Sustainable Resource Management
The development will comply fully with all Government of Maldives laws and regulations related to conservation and natural resource management, including the National Biodiversity Strategy and Action Plan (adopted in 2002) and the Protected Areas and Sensitive Areas provisions of the Environment Protection and Preservation Act, as well as the United Nations Convention on Biological Diversity. The EIA found that a unique feature of Villingilli island is the presence of three natural brackish wetlands, which have enhanced the island’s biodiversity, including the range of naturally occurring vegetation and observed local bird populations. The EIA found that, while not considered to be critical habitats, the wetlands are ecologically sensitive and warranted a detailed baseline assessment, the results of which will be used to monitor key parameters such as types, dispersion and abundance of vegetation, including mangrove forests; water depth, quality, and pond sedimentation; and island’s terrestrial fauna and nesting areas. The island contains a number of mature Banyan (Ficus benghalensis) trees considered to be unique and sparsely distributed. Shangri-La’s onsite construction supervision team has confirmed that no mature trees of any types have been felled during construction. Where possible, structures have been moved to accommodate the trees; where not possible, the trees have been transplanted (with a 100% survival rate to date) to accommodate the structures.
With respect to the marine environment, the key areas assessed were the coral reefs, seagrass beds, fish populations, and lagoon system. Most impacts will occur during construction, with minimal impacts during the operational phase. Removal of a portion of the seagrass beds, which will occur as part of the demolition of existing infrastructure from the first, partially completed development, is the only major adverse impact that will be permanent and largely irreversible. The EIA identified a number of mitigation measures to limit the impact of this activity, including minimizing the areas of seagrass removed to those along the shore; installing silt screens in these areas prior to the start of structural demolition and removal activities; and undertaking seagrass removal during low tide, using manual methods and over the shortest time period possible. Shangri-La’s onsite project management team has conducted training for workers involved in seagrass removal/demolition on how to carry out this activity so as to minimize impacts, and monitors the progress on a daily basis. All other impacts on the marine environment, during both construction and operation, were deemed to be short term and reversible.
The EIA includes a mitigation and monitoring plan for managing these impacts, and Shangri-La has committed to implementing the plan fully, and to monitoring and reporting on all key impacts at specified frequencies, including every 24 to 48 hours for key parameters such as marine water quality and visibility, and waste management during construction, and quarterly thereafter. Monitoring of fish populations and coral reef cover will be undertaken quarterly during construction and annually thereafter. Many of the reefs in the Maldives sustained significant damage during a widespread coral bleaching event in 1998 that reduced coral cover to 2-3% of its prior levels and affected 90% of the country’s shallow reefs. Several resorts in the Maldives have undertaken experimental coral replanting programs with considerable success, the results of which were reported at the “First National Workshop on Resort Reef Management: Coral Recovery and House Reef Enhancement Methods” held in Malé, the Maldives, in September 2006, and Shangri-La has committed to implementing a similar program at Villingilli island. In addition, the company will commission an independent, post-construction environmental audit against the EIA mitigation and monitoring requirements, preferably carried out by the team that prepared the EIA, to establish an operational baseline against which annual performance can be monitored. A copy of the audit report will be provided to IFC in accordance with the schedule set forth in the attached ESAP. During operation, guest brochures in each room will provide details on the unique geography and biodiversity of the Maldives in general and Villingilli island in particular, as well as guidelines for actions guests and staff can take to protect and conserve these resources.
- PS8: Cultural Heritage
The EIA found that there were no monuments, temples or other cultural property or sites located on Villingilli island that would be covered under PS8. However Shangri-La will establish a procedure for assessing cultural heritage ‘chance finds’ that may be identified during either construction or operation to ensure that any such finds are not disturbed until they have been assessed and documented by a competent specialist.
