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

- PS 1 - Social and Environmental Assessment and Management Systems;
- PS 2 – Labor and Working Conditions;
- PS 3 – Pollution Prevention and Abatement;
- PS 4 – Community Health and Safety;

The following Guidelines are applicable to this project:

- IFC’s General Environmental, Health and Safety Guidelines, dated April 30, 2007; and
- IFC’s Environmental, Health and Safety Guidelines for Health Care Facilities, dated April 30, 2007; and

This ESRS assesses the project against the above Performance Standards and Guidelines. The Project does not trigger PS 5 – Land Acquisition and Involuntary Resettlement; PS 6 Biodiversity Conservation and Sustainable Natural Resource Management, PS 7 on Indigenous People or PS 8 on Cultural Heritage as both hospitals will be located in leased premises, in existing buildings that are renovated according to the requirements of the company. The project does not involve the harvesting of natural resources or impacts on natural habitat, and it does not impact on either Indigenous Peoples or known Cultural Heritage.

This is a Category B project under IFC’s Environmental and Social Review because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, design criteria, local regulations and industry certification schemes. Environmental, social, health and safety issues which may be associated with this type of project, and which were reviewed during appraisal, included: site selection and land acquisition; management systems for environmental, health and safety (EHS), communicable diseases and potential outbreaks, and life and fire safety issues; compliance with local and IFC requirements for air emissions, wastewater treatment and disposal, solid waste management and transportation, including medical and bio-hazardous waste; emergency preparedness and response; indoor air quality; noise; energy, water, refrigerants and other material use and efficiency; labor and workplace conditions; and community engagement.

SOCIAL AND ENVIRONMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS

Environmental and Social Assessment
In the establishment of its existing and planned facilities, UFH conducts environmental and social assessments in compliance with Chinese requirements and PS 1.

The Company has a team that concentrates on new projects. It specifies corporate standards for the site selection, design and construction, including interior design and finishes. They work with architects and contractors who have proven experience of designing and constructing international standard facilities.

Management Program and Organization
All UFH facilities adopt management systems and implementation capacity in line with international best practice. UFH facilities are certified to standards developed by the Joint Commission International Accreditation (JCIA), a division of the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) that is the largest accrediting body for healthcare organizations in the United States of America (USA). JCIA is an authoritative organization specializing in accrediting hospitals that are outside the USA. The JCIA Standards for medical quality and service quality are the highest standards presently achievable for a hospital and this is recognized internationally by the industry and the World Health Organization (WHO). In compliance with the standard, UFH develops policies, systems and procedures to manage environmental, health and safety and social issues and generally for hospital management. These areas are addressed under the following standards of JCIA: patient care; safety; rights and education; prevention and control of infection; facility management and safety; staff qualifications and education; governance and leadership; and management of information. JCIA certification is renewed every three years and UFH rigorously checks and reviews the ongoing implementation of its system. All UFH hospitals and clinics are JCIA certified with the exception of Tianjin United Family Hospital, which did not open before the certification round in 2011. UFH plans for the Tianjin and Rehab Center to be certified in the certification renewal round in 2014.

As part of the JCIA management system, all UFH facilities assign responsibility for EHS, fire safety, disease prevention and outbreak control to responsible staff.

Training
UFH employs a full-time training department that provides induction and on-going training for medical and non-medical staff. Training includes but is not limited to: service excellence; infection control; risk management; patient rights; English and Chinese language training; and life support. Supervisors conduct regular meetings with staff to discuss and review performance. Extensive training is provided to all of UFH’s nurses, who are locally-hired, to ensure they meet international JCIA standards. 80% of the company’s nurses also have overseas experience. UFH is the only facility to provide midwifery training and services in China. It also provides training to external companies and CPR training is provided to patients.

Community Engagement
The Company’s initiatives are described in the section “Community Engagement” below.

Monitoring and Reporting
UFH’s facilities are required to conduct regular monitoring of wastewater discharges and the disposal of medical and other wastes. Results are reported to management and local environmental authorities who also conduct their own inspection of UFH’s electricity, sewage and water, fire protection and lighting systems, elevators, boilers, pressure containers and measuring devices.

Internal monitoring of performance is also conducted regularly in line with JCIA requirements. Staff are encouraged to submit occurrence reports anytime there is a nonconformance with required procedures or an incident. The occurrence reports are reviewed at regular meetings of the Risk Management Committee and corrective actions are identified and implemented as needed. The Committee reviews trends over time and improves procedures and training as needed. Departmental meetings and both internal and external Peer Reviews are conducted to assess performance and identify areas for improvement. Each department has quality indicators based on the 20 performance areas designated by JCIA.


LABOR AND WORKING CONDITIONS

Currently UFH has around 1800 staff, including some part-time staff. It outsources catering, security maintenance and operation of the boilers.

Human Resource Policy and Management
The UFH has a comprehensive human resources (HR) policy and documented procedures for managing HR issues, ranging from working hours, to maternity and paternity leave, to training and staff development. The Company’s HR policies, management system, conditions of employment and working conditions are in compliance with national law and PS2. An annual survey of staff is conducted to assess satisfaction levels and identify areas for improvement. Staff engage in a commitment setting process and performance review every year, which informs the provision of staff bonuses. The Company’s internal grievance mechanism encourages staff to raise issues through direct discussions with immediate supervisors or managers and by e-mail directly to management.

Worker’s Organizations
As in its existing facilities, the Projects will establish staff unions in compliance with local Chinese and IFC requirements. Meetings are held throughout the year, and UFH pays a Union Fee of 2% of the salaries of all Chinese-national employees.  Hospitals also set up a mandatory separate bank account to hold funds to be used specifically for “employee recreation” purposes.

Non-discrimination and Equal Opportunity
UFH’s policies and procedures outline the Company’s human resource policy, commitment to non-discrimination and equal opportunity.

Retrenchment
UFH will be hiring new employees, primarily local physicians and staff, for its expansion facilities.

Protecting the Work Force
The company does not engage children or forced labor and it complies with local labor laws and related PS2 requirements to protect the workforce. All employees are over the age of 21, which is above the minimum required age of 18. All overtime must be pre-approved except in emergency cases. Management is not entitled to overtime pay and physicians receive compensation leave in lieu of overtime pay. Nursing and non-managerial administrative staff receive 1.5 times regular pay for any approved overtime worked. Nursing staff may not work more than 16 hours in one, 24-hour period. Staff receive compensation above the minimum wage and commensurate with their job responsibilities and experience. UFH has a zero accident and fatality rate for its operations.

Occupational Health and Safety
UFH’s JCIA-compliant management system includes policies and procedures for managing occupational health and safety issues within its facilities. A number of initiatives are undertaken by UFH to safeguard the health of employees and patients. Examples include: an Infection Control Plan to prevent, identify and control healthcare associated infections; education of all employees on the importance of “standard precautions” in the hospital to reduce the risk of work-related exposures (e.g. hand hygiene, personal protective equipment, handling sharps, emergency eye washers and showers, appropriate cleaning procedures); provision of an employee health program that screens new employees to prevent, monitor, investigate potentially harmful infectious exposures and outbreaks among personnel and provides care for personnel for work-related illnesses or exposures; a JCI-compliant radiation exposure control plan, which outlines measures to control and monitor exposure of staff to radiation sources; and implementation of a policy to manage healthcare workers exposed to blood and body fluids.

Non-Employee Workers
The company requires evidence that appropriate payments are made to the government for contract workers and verifies that their living accommodation is satisfactory. The health and safety practices of construction and maintenance workers are monitored regularly and the company has rented and renovated accommodation for security staff and provides them with appropriate training.


POLLUTION PREVENTION AND ABATEMENT

Pollution Prevention, Resource Conservation and Energy Efficiency
As noted above, UFH has a template which used for the design, construction and operation of all of its new healthcare facilities. The template consolidates the Company’s existing operational practices, standards and expectations into a common framework, including but not limited to: sustainable materials in the construction process; design requirements for fire safety, disease prevention and isolation; energy-efficient plant and systems; and segregation of medical and other wastes.

The renovation of the New Hope Oncology Centre was undertaken to LEED silver standard and although the company does not intend to achieve this standard for all its hospitals in the future, it has taken some of the lessons learnt and incorporated them into the Company’s design template.

For the Company’s existing facilities, electricity is provided from the grid and the boilers are powered by natural gas. Bottled water is used for drinking or medical purposes. Water used for the operation of the boilers and facility cleaning is sourced from the municipal water supply and treated by ultra filtration and deionization water systems. Wastewater discharges are pre-treated with chlorine disinfectant prior to their discharge to municipally-operated sewage and water treatment plants. Wastewater discharges are compliant with local and IFC requirements at UFH’s existing facilities.

Waste and Hazardous Materials
Clinical and hazardous wastes are collected in specially identified containers within UFH’s premises and removed multiple times daily by the housekeeping staff and placed inside bins in a locked temporary storage area. Housekeeping staff wear appropriate protective equipment and follow UFH’s infection control policy when disposing of clinical waste. The management of hazardous, clinical and radioactive wastes are controlled through UFH’s JCI-compliant management system. All wastes, including solid waste, are removed daily from the storage area by a government-approved contractor. The contractor is responsible for the offsite incineration of all clinical and hazardous waste. Radioactive wastes, comprising waste film developing solution, are appropriately stored for collection and disposal by an authorized contractor. UFH investigates the final disposal points for its wastes to ensure the proper disposal of all materials. No incineration is conducted on-site.

Emergency Preparedness and Response
Stringent disease prevention measures are in place, ranging from proper sanitation, use of PPE and equipment sterilization to the regular testing of air cultures, and the provision of negative pressure rooms for ICU patients, as well as facilities and systems to manage infectious diseases.

UFH operates a color-coded system to respond to emergencies in all of its facilities and staff are regularly trained on emergency and fire response procedures. The system covers a red alert for fire, yellow for violent patients, green for general security and pink for child abductions (security staff guard entrances to maternity/pediatric units and staff must enter specified codes to enter these rooms).

Green House Gas Emissions
UFH’s operations do not generate GHGs in excess of 100,000 tons of CO2 annually.

Pesticide Use and Management
The company does not use or manage pesticides.


COMMUNITY HEALTH, SAFETY AND SECURITY

Community Health and Safety
UFH has both facilities and management procedures to prevent and manage patients with infectious diseases and to handle outbreaks that have the potential to impact on community health and safety. Temperature checks of patients are routine and patients with fevers are isolated in negative pressure rooms. At the entry to each of its hospital facilities, a separate building is established to register and check patients for fever. UFH has procedures, equipment and isolation facilities/systems, and has provided training to staff, to respond to potential emergencies that could result in potential internal or external impacts.

Emergency Preparedness and Response
As part of its accredited JCIA system, policies and procedures are in place to specifically address life and fire safety issues in compliance with IFC guidelines. Mandatory fire safety training is provided for all new and existing hospital employees and drills are carried out regularly in accordance with the plan. UFH has duty engineers available on-site 24 hours per day who are in charge of monitoring fire safety equipment. UFH’s operations and facilities are in compliance with all local fire safety laws and regulations and the local government monitors compliance annually. To verify that BJU2 and the Rehab Centre comply with IFC’s life and Fire Safety requirements, the company will provide evidence to IFC’s satisfaction that the hospitals meet JCI’s certification criteria.

An emergency preparedness and response plan covers potential incidents associated with UFH’s operations. It is tested twice a year and prepares the staff for internal emergencies such as flooding and power failures, as well as external emergencies such as earthquake or plane crash. A monitoring and reporting system is in place to engage local government as needed in the event of an emergency and arrangements exist to engage assistance from the public, fire brigade and the local health and environmental authorities as needed.

Security Personnel Requirements
Professionally managed and trained security personnel are hired to guard UFH’s facilities 24 hours a day, 7 days a week. Contracts include requirements to meet national laws and to provide appropriate training. Guards implement a visitor registration system and, as noted above, security staff guard entrances to maternity/pediatric units to ensure the safety of patients.

Prior to the establishment of its facilities, the company consults with local governments surrounding businesses and communities. The company maintains communication channels and consults regularly with local authorities. Each facility implements grievance mechanisms for receiving and addressing grievances raised by the local community. The relationship with the local communities is managed carefully. For example, in the neighborhood of BJU2, the company provides free medical talks, employs locals where possible, and holds consultation meetings with local residents committees.

As part of its corporate responsibility and community engagement initiatives UFH donates 1% of its revenue to its own foundation that provides free medical care to children in orphanages in China. It also organizes charity events to support healthcare programs and toy and clothes drives for orphans; coordinates a dental club for local dentists and nurses to share experience and learn new practices; and implements community blood drives in cooperation with the Red Cross China and charity events to support American Education and Health Foundation.

Client’s contact information and location of Client’s Environmental and Social Review Summary:
Mrs. Roberta Lipson
UFH President
United Family Hospital
#2 Jiangtai Lu, Chaoyang District
Beijing 100016
Telephone - +86-10-59277020
Fax +86-10 59277220
Email – mailto:rlipson@chindex.com

Website - http://www.unitedfamilyhospitals.com/