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Environmental & Social Review Summary
Project Number
26360
Company Name
MAGRABI HOSPITALS AND CENTERS LTD
Date ESRS Disclosed
Oct 30, 2007
Country
Middle East, Pakistan, and Afg Region
Region
Middle East
Last Updated Date
Aug 6, 2021
Environmental Category
B - Limited
Status
Completed
Previous Events
Approved : Jan 10, 2008
Signed : Jan 27, 2008
Invested : Mar 19, 2009
Sector
Hospitals and Clinics
Industry
Health, Education and Life Sciences
Department
Gbl Ind, Manufact, Agribus & Services
Project Description
The project consists of financing the expansion in Egypt and Yemen of Magrabi Hospitals & Centers (Magrabi or the Group). The company intends to expand its operations by establishing 8 hospitals and 4 centers in different cities in the MENA region.
Overview of IFC's Scope of Review
The review of this project consisted of appraising written technical, environmental and social information submitted by Magrabi Eye Hospitals in Sana`a and Cairo, site visits by IFC to the existing hospitals and future developments in both cities and meeting with head of operations in Magrabi Eye Sana`a and the management of Magrabi Group in Cairo.
Future developments of the Group in Egypt, Saudi Arabia and Sudan have been discussed as well. When the design phase of these developments is finished, IFC will review the detailed design and if necessary carry out an additional site appraisal to ensure that this phase of the project also fully comply with the IFC Performance standards and guidelines. During this EHS site appraisal, IFC will assess what PSs are applicable for any other developments that are or will be part of the project.
Future developments of the Group in Egypt, Saudi Arabia and Sudan have been discussed as well. When the design phase of these developments is finished, IFC will review the detailed design and if necessary carry out an additional site appraisal to ensure that this phase of the project also fully comply with the IFC Performance standards and guidelines. During this EHS site appraisal, IFC will assess what PSs are applicable for any other developments that are or will be part of the project.
E & S Project Categorization and Applicable Standard
While all Performance Standards (PS) 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:
- PS1: Social and Environmental Assessment and Management Systems;
- PS2: Labor and Working Conditions;
- PS3: Pollution Prevention and Abatement;
- PS4: Community Health, Safety and Security; and
- PS5: Land Acquisition and Involuntary Resettlement.
Based on information received from Magrabi regarding their future developments, the land for future developments is either acquired or is in the process of being acquired in a way that there will be no issues related to PS5. Applicability of other Performance Standards PS6 (Biodiversity Conservation and Sustainable Natural Resources), PS7 (Indigenous People) and PS8 (Cultural Heritage) will be assessed during the additional site appraisals.
- PS1: Social and Environmental Assessment and Management Systems;
- PS2: Labor and Working Conditions;
- PS3: Pollution Prevention and Abatement;
- PS4: Community Health, Safety and Security; and
- PS5: Land Acquisition and Involuntary Resettlement.
Based on information received from Magrabi regarding their future developments, the land for future developments is either acquired or is in the process of being acquired in a way that there will be no issues related to PS5. Applicability of other Performance Standards PS6 (Biodiversity Conservation and Sustainable Natural Resources), PS7 (Indigenous People) and PS8 (Cultural Heritage) will be assessed during the additional site appraisals.
This project involves:
- construction of 3 new low-cost eye hospitals in Egypt in the cities of El-fastat Cairo, Tanta and Al-Menya totaling 90 beds,
- construction of a new 30 bed eye hospital in Sana’a, Yemen,
- construction of a new 30 bed low-cost eye hospital in Khartoum, Sudan, and
- construction of Magrabi eye referral center in North Jeddah, a second Magrabi Eye hospital in Riyadh, and the first Magrabi Eye Hospital in Dubai.
Key impacts associated with the project include:
- Sites acquisition issues,
- Environmental, Health, Safety, and Social Management – air emissions and treatment, potable water supply and treatment, waste water management, health care waste management including non hazardous and hazardous medical waste,
- Labor and working conditions, employee and contractor occupational health and safety, including training and housekeeping; disinfection, sterilization, hygiene and implementation of good hospital management practices required to prevent infections among patients and employees,
- Community health and safety during construction and utilization phase,
- Life and fire safety including emergency response.
The nature of the health care operations is such that no major adverse environmental or social impacts are expected to result from the project, and that it will be possible to mitigate any minor, adverse impacts that might result. As a result, it has been categorized as a category B project.
- construction of 3 new low-cost eye hospitals in Egypt in the cities of El-fastat Cairo, Tanta and Al-Menya totaling 90 beds,
- construction of a new 30 bed eye hospital in Sana’a, Yemen,
- construction of a new 30 bed low-cost eye hospital in Khartoum, Sudan, and
- construction of Magrabi eye referral center in North Jeddah, a second Magrabi Eye hospital in Riyadh, and the first Magrabi Eye Hospital in Dubai.
Key impacts associated with the project include:
- Sites acquisition issues,
- Environmental, Health, Safety, and Social Management – air emissions and treatment, potable water supply and treatment, waste water management, health care waste management including non hazardous and hazardous medical waste,
- Labor and working conditions, employee and contractor occupational health and safety, including training and housekeeping; disinfection, sterilization, hygiene and implementation of good hospital management practices required to prevent infections among patients and employees,
- Community health and safety during construction and utilization phase,
- Life and fire safety including emergency response.
The nature of the health care operations is such that no major adverse environmental or social impacts are expected to result from the project, and that it will be possible to mitigate any minor, adverse impacts that might result. As a result, it has been categorized as a category B project.
Environmental and Social Mitigation Measures
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 countries laws and regulations, IFC Performance Standards, and IFC 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 (ESAP).
- PS1: Social and Environmental Assessment and Management Systems
- Environmental and Social Assessment:
In the establishment of its existing and planned facilities, Magrabi conducts environmental and social assessments in compliance with requirements of the host countries i.e., Egypt, Yemen, Sudan and Saudi Arabia. For any economic or physical displacement that may be expected to occur as part of various site developments, Magrabi has committed to address the consultation and disclosure requirements of PS1, as well as the land acquisition and involuntary resettlement requirements of PS5.
The company has considerable in-house capacity and project management expertise to develop, construct and operate its healthcare facilities. The designs for the future developments are referenced by a number of international and national health care standards such as JCI (international standards for hospitals), CDC (center for disease control and prevention), National Laws and Regulations and National IC guidelines. These guidelines and regulations will specify building and operational standards including but not limited to:
- sustainable materials in the construction process;
- design requirements for fire safety, disease prevention and isolation;
- clean fuels for on-site electricity generation;
- energy-efficient plant and systems; and
- segregation of medical and other wastes.
- Management Program and Organization:
Magrabi Group currently has management system and capacity to manage their health care facilities in different countries where they operate. Internal capacity in (Magrabi Eye Cairo) to manage EHS issues is the responsibility of:
- Facility Safety Unit, managed by the Engineering and Safety manager,
- Patient safety is the responsibility of all staff and
- Occupational (employee ) safety is managed by an internist with the IC officer.
Services provided by these Units include construction and renovation, utility system management (water–HVAC–electrical power supply), safety and security, fire safety, emergency preparedness, biomedical system management, hazardous material management. Work done by these units is supervised by Safety Committee.
The Magrabi Eye hospital in Cairo is applying for certification 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, Magrabi will develop policies, systems and procedures to manage environmental, health and safety and social issues and general 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.
Magrabi is planning for its other facilities, existing ones as well as the new expansion facilities, to gradually develop health care management standards according to both national and IFC guidelines and obtain certification to JCIA standards within the first years of their operation.
Management systems and internal capacity vary in different countries where the Group operates. In their current operations in Sana`a, Yemen, there is currently inadequate capacity to address EHS issues. However Magrabi is planning to establish an appropriate EHS management structure and capacity in their new expansion hospital in Sana`a. The long experience that the Group has in managing hospitals and clinics and the experience that the Group will derive from the certification process by JCIA standards will provide an excellent template for their current facilities as well as for their new expansions. In order to manage EHS issues in their eye centers across the region the Group will need to expand its existing EHS system in Magrabi Eye hospital in Cairo to other developments that are part of the Project.
- Training:
Magrabi 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; and
- patient rights.
Doctors and nurses are trained and certified in providing life support. Supervisors conduct regular meetings with staff to discuss and review performance. In addition, periodic trainings are provided to Magrabi medical staff by some affiliated US based hospitals e.g. John Hopkins, through Visiting Professor Programs. Magrabi Eye Cairo hospital is a referral training center for other hospitals of the Group.
For other facilities, for example in Sana`a, the training is organized for doctors and nurses by Magrabi Group Eye hospital doctors, which spend couple of months in Sana`a providing on the job training. Also, due to the cultural gender sensitivities, Magrabi Eye in Yemen is planning to employ experienced nursing staff from abroad with international experience.
- Community Engagement:
Prior to the establishment of its facilities, the company consults with local governments, surrounding businesses and communities. The business enabling framework differs from country to country in which Magrabi operates, ranging from very well established to very weak or non existent requirement for community engagement. Depending on local legal requirements, Magrabi keeps open communication channels and consults regularly with local authorities. Each existing facility implements, with the given local legal requirements, grievance mechanisms for receiving and addressing grievances raised by the local community. No complaints have been received from the local communities near its existing sites.
- Monitoring and Reporting:
Monitoring of air emissions, liquid effluents, and water quality varies from country to country in which Magrabi operates i.e. in Yemen there seems not to be specific Health Care Law that defines the monitoring requirements whereas Magrabi Eye facility in Cairo, as a part of gradual certification by JCIA, conducts regular internal monitoring of air emissions, wastewater discharges and the disposal of medical and other wastes. The Quality team of Magrabi Eye hospital in Cairo has already developed a set of documents as a preparation for JCIA certification and various EHS monitoring reports will be assessed during the pre-certification audit.
Results are reported to management and local environmental authorities who also conduct their own inspection of Magrabi’s electricity, sewage and water, fire protection and lighting systems, elevators, boilers, pressure containers and measuring devices.
Magrabi`s Safety Committee reviews the monitoring results and identifies corrective action. Similar reporting mechanisms will need to be established in the Group’s current and future developments in Yemen, Sudan, Egypt and Saudi Arabia.
- Magrabi is committed to:
- Update IFC on its development and use of its planned Environmental and Social Management System template for integrating environmental and health and safety issues into the design, construction and operation of its current and new healthcare facilities, and provide a copy of the ESMS template to IFC.
- Update IFC on the implementation and certification of its integrated management system for environmental, health and safety, life and fire safety and social issues at its existing and new facilities to the Joint Commission International Accreditation (JCIA) standard.
- PS2: Labor and Working Conditions
- Human Resource Policy and Management:
Magrabi Eye hospital in Cairo has a comprehensive human resources (HR) policy and documented procedures for managing HR issues, ranging from recruitment and retention, working hours, maternity and paternity leave, training and staff development, performance assessments and organization climate and culture. The company’s HR policies, management system, conditions of employment and working conditions are in compliance with national law and PS2. The HR policy provides options for flex time, compressed work hours or part time work. A number of regular trainings are held i.e on-job, in-house (patients care, time management, managing stress, team work, selling skills), and external (basic management skills and academic certificates for finance, IT, HR, Sales and Marketing). Performance management practice is a basis for awarding a wide range of regular and fringe benefits i.e Health, Social and life insurance, Education Assistance plan, Management Bonus, Incentive Scheme, Retirement Plan. Staff engages 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.
Magrabi Eye hospital in Yemen has developed an HR policy according to the Yemeni Labor Law and Magrabi Group HR policy. Due to the different management structure, different HR/Admin issues, such as performance measurement, bonuses allocation or grievances are being dealt by a senior management and on an individual basis. The salaries are high for local Yemeni standards and every year there is an average salary increase of 7-15%, based on a worker’s performance, which is assessed by a HR/Admin manager. Two years ago a law on social requirements has been enacted in Yemen requiring each employer and employee to contribute 15 % total from the annual gross salary (9% and 6% respectively) into the “employer’s social / pension package”.
- Worker’s Organization:
Magrabi Eye Hospitals comply with national laws in the countries they operate. Although the work force in Magrabi have individual contracts, establishment of workers association is not prohibited or discouraged by the Magrabi and if so requested by workers Magrabi will establish a staff union in compliance with local and IFC requirements.
The Group’s developments in other countries should be ready to set up similar arrangements.
- Non-Discrimination and Equal Opportunity:
Magrabi’s policies and procedures outline the company’s human resource policy, commitment to non-discrimination and equal opportunity.
- Retrenchment:
Magrabi will be hiring new employees, primarily local physicians and staff, for its expansion facilities. Also, due to the cultural gender sensitivities, Magrabi Eye in Yemen is planning to employ experienced nursing staff from abroad with an international experience. Staff turnover is higher in, for example Cairo that in Sana`a, as a reflection of existing / non existing market for the doctors / nurses in these cities. In case of retrenchment, a worker is provided with a package of 2-6 months salary
- 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 minimum required age of 18.
- Occupational Health and Safety:
Magrabi Eye hospital in Cairo and its JCIA -compliant management system includes policies and procedures for managing occupational health and safety issues within its facilities. Major components of occupational health program are administrative policies and procedures and operational policies and procedures:
- screening -periodic testing for all personnel,
- health education and counseling - training for occupational hazards, posters and newsletters, hand disinfection tools availability,
- occupational illness and injury treatment - personnel protective equipment, needle stick injury prevention, tracking and follow-up, vaccination program,
- non occupational illness treatment - health insurance system,
- environmental assessment and control - high risk areas biological monitoring, water quality monitoring,
- record keeping - employee health records, needle stick injury logbook.
For other Group’s existing hospitals and new expansions in different countries in development of OHS system the Group will need to use the template that is developed for Cairo operations.
Magrabi will use its well developed HR policy and documented procedures for managing HR issues and implement it in its future expansions so that the Group HR policies, management system, conditions of employment and working conditions are in compliance with PS2 and with national laws of countries in which Magrabi will expand its operations.
- PS3: Pollution Prevention and Abatement
- Pollution Prevention, Resource Conservation and Energy Efficiency:
Magrabi Group is developing a template to be used for the design, construction and operation of all of its new healthcare facilities. The template will be consolidating the Group’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, and its appropriate management.
- Magrabi Eye Cairo:
For the company’s existing facilities in Cairo electricity is provided from the grid and generated on-site from diesel generator. Electricity is available for all hospital areas 24 hours daily and uninterrupted in high risk area as operating theatre, recovery room and outpatient clinics through main power supply (2 high voltage lines, 2 medium voltage switch gears, 2 transformers, a pass coupler (connecting both lines in case of power disruption), generator, power factor correction, UPS unit, earthing cables for electrical and biomedical safety). Diesel generator is Caterpillar model with high energy efficiency. Energy-efficient systems and equipment are incorporated into the design of all of its current facilities, and for all future developments. Air emissions are compliant with local and IFC requirements at Magrabi’s existing facilities.
Bottled water is used for drinking or medical purposes. City Utility supplies the Hospital with the potable water. There are three water tanks available for main hospital (80 cubic meters), operating room (12 cubic meters), low pay hospital (64 cubic meters).
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 storage tanks are cleaned regularly according to hospital policy and the quality of water is sampled periodically to check for bacterial contamination.
Wastewater discharges are pre-treated with chlorine disinfectant prior to their discharge to municipally-operated sewage and water treatment plant in Cairo. Wastewater discharges are compliant with local and IFC requirements.
- Magrabi Eye Sana`a:
Magrabi Group is planning to construct new eye hospital in Sana`a with all the latest health care facility standards. Current Magrabi’s hospital in Sana’a is located in a leased building on first four floors with limited options for establishing proper health care facility EHS management systems.
Electric power is supplied via national grid and back up diesel generator. The generator is placed in a separate storage room at the building parking lot. Bedsides Magrabi Eye hospital, there are a number of other lease holders located in the same building.
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.
Wastewater system in the hospital is a mixed one i.e sanitary and process waste water is discharged to a city sewer and treated in the city waste water treatment plant.
- Solid Waste and Hazardous Materials
- Magrabi Eye Cairo:
The management of hazardous, clinical wastes is controlled through Magrabi JCI-compliant management system in coordination with the infection control team. Clinical and hazardous wastes are collected in specially identified yellow bags and disposed off in a locked temporary storage area within Magrabi Eye hospital premises. This storage area needs to be upgraded to meet IFC guidelines. Housekeeping staff wear appropriate protective equipment and follow Magrabi infection control policy when disposing of clinical waste. All wastes, including solid waste, are removed regularly from the storage area by a government-approved contractor Cairo Teaching University Hospital “Kasr Al Aini”. The contractor is responsible for the offsite incineration of all clinical and hazardous waste. No incineration is conducted on-site.
- Magrabi Eye Sana`a:
Clinical and hazardous wastes are collected in specially identified containers within Magrabi Eye hospital premises and removed by the housekeeping staff and placed inside bins in a locked temporary storage area. Waste disposal is performed regularly by an authorized contractor and finally disposed off outside the city Sana`a at the disposal site. Magrabi management is considering the building of on-site incinerator for infectious medical waste, and IFC will provide technical guidance on appropriate technology.
Emergency Preparedness and Response
- Magrabi Eye Hospital Cairo:
As part of its effort to approximate to the JCI accreditation, the system, policies and procedures are in place to specifically address life and fire safety issues in compliance with n ational and IFC guidelines. Mandatory fire safety training is provided for all new and existing hospital employees but drills are not carried out regularly in accordance with the plan. Magrabi Eye Hospital has duty engineers and safety manager available on-site 24 hours per day who are in charge of monitoring fire safety equipment. Magrabi Eye Hospital’s operations and facilities are in compliance with all local fire safety laws and regulations and the local government monitors compliance annually.
- Magrabi Eye Hospital Sana`a:
In spite of the extended efforts of the Magrabi Group to bring the current operations of the Hospital in Sana`a in compliance with the Group`s health care operating standards there are still some outstanding issues that specifically relate to life and fire safety. The Hospital is located in a building that originally was designed and built as an apartment building, so that the Group had to refurbish the original design of the leased premises at first four floors of the building to fit the health care operations` requirements. Due to this fact the existing emergency preparedness and response plan has been designed within these limitations. Most of the current operations will be transferred to the new hospital when it is built. Two floors of the current premises will be retained as a clinic center and as such will need to be upgraded to comply with the life and fire safety requirements of IFC. That will require construction of alternative escape stairways and additional fire fighting equipment.
The new hospital will need be designed and built to satisfy the best international best practice in health care industry, local applicable regulatory requirement and IFC EHS requirements.
For both hospitals in Cairo and Sana`a, 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.
- Greenhouse Gas Emissions:
Magrabi Eye Hospital’s operations do not generate GHGs in excess of 100,000 tons of CO2 annually.
Magrabi Group has committed to bring all its hospitals and clinics that are part of the Project in to the compliance with local regulatory requirements and IFC guidelines for air quality, wastewater discharges, ambient noise and workplace conditions.
- PS4: Community Health, Safety and Security
- Community Health and Safety:
Both Cairo and Sana`a Mgrabi Eye hospitals have facilities and management procedures in place to prevent and manage health and safety aspects of their operations starting from design phases, construction, operations and decommissioning and closure. Several outstanding issues that IFC has observed during the appraisal visit will be adequately addressed by the management of Magrabi as the management of the Group has expressed commitment to bring them into the compliance with the best international practice and IFC EHS requirements for health care facilities.
Magrabi Group will evaluate health and safety (including L&FS as mentioned above, and occupational health and safety) risks and impacts that could affect the local communities during the design, construction, operation and decommissioning stages of the project in various countries where the developments are planed, and will establish measures to prevent or mitigate such risks and impacts commensurate with the identified risks and impacts.
Contractors for design of the new buildings and the construction will apply sound principles of environmental engineering and safety engineering during the sitting and construction phase, and these principles will be stipulated between the contractors and Magrabi Group in their contracts, to prevent and/or avoid any reputation or other risk for Magrabi Group associated with potential adverse environmental and social performance of the contractors activities. Structural elements will be designed and constructed by qualified and experienced professionals and certified and approved by competent authorities or professional to IFC, similar to the L&FS requirements, as per the L&FS guidelines.
- Emergency Preparedness and Response:
An emergency preparedness and response plan covers potential incidents associated with the current operations. 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 heath and environmental authorities as needed.
- Security Personnel Requirements:
Professionally managed and trained security personnel are hired to guard Magrabi Eye Hospitals 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 the hospitals and clinics to ensure the safety of patients.
Specific to the Hospital in Sana`a, guards are instructed to request from all visitors which wear a traditional knife “gambia” to deposit it to a safety locker while visiting the hospital. So far, as reported by the management of hospital, there were very few incidents with those visitors who did not want initially to leave their knife at the reception area.
- PS5: Land Acquisition and Involuntary Resettlement
- Compensation and Benefits for Displaced Persons:
No persons have been displaced either physically or economically by the current facilities.
- Consultation and Grievance Mechanism:
The developer(s) of Magrabi Group’s proposed sites has/will continue to consult with local government authorities and any potentially affected owners regarding its acquisition of land use rights for its future sites.
The company will establish grievance mechanisms for receiving and addressing grievances raised by the local community.
- Resettlement Planning and Implementation:
No resettlement has been needed so far in Magrabi’s operations.
- Physical Displacement:
Magrabi Eye Hospital in Sana’a is located in leased premises, in a building that did not involve physical or economic displacement of local business or communities. The Group has yet to confirm the final location for its expansion facility in the urban center of Sana`a. Sites under consideration are clear of any ownership disputes and there will be no physical or economic displacement as there are no people living on the site.
For any other development the Group is committed to follow local laws and IFC PS5: Land acquisition and involuntary displacement and in arranging for future developments.
Magrabi is committed to update IFC on the land acquisition process once future development sites are confirmed, and provide records of consultations undertaken and compensation provided to demonstrate compliance with PS5.
- PS1: Social and Environmental Assessment and Management Systems
- Environmental and Social Assessment:
In the establishment of its existing and planned facilities, Magrabi conducts environmental and social assessments in compliance with requirements of the host countries i.e., Egypt, Yemen, Sudan and Saudi Arabia. For any economic or physical displacement that may be expected to occur as part of various site developments, Magrabi has committed to address the consultation and disclosure requirements of PS1, as well as the land acquisition and involuntary resettlement requirements of PS5.
The company has considerable in-house capacity and project management expertise to develop, construct and operate its healthcare facilities. The designs for the future developments are referenced by a number of international and national health care standards such as JCI (international standards for hospitals), CDC (center for disease control and prevention), National Laws and Regulations and National IC guidelines. These guidelines and regulations will specify building and operational standards including but not limited to:
- sustainable materials in the construction process;
- design requirements for fire safety, disease prevention and isolation;
- clean fuels for on-site electricity generation;
- energy-efficient plant and systems; and
- segregation of medical and other wastes.
- Management Program and Organization:
Magrabi Group currently has management system and capacity to manage their health care facilities in different countries where they operate. Internal capacity in (Magrabi Eye Cairo) to manage EHS issues is the responsibility of:
- Facility Safety Unit, managed by the Engineering and Safety manager,
- Patient safety is the responsibility of all staff and
- Occupational (employee ) safety is managed by an internist with the IC officer.
Services provided by these Units include construction and renovation, utility system management (water–HVAC–electrical power supply), safety and security, fire safety, emergency preparedness, biomedical system management, hazardous material management. Work done by these units is supervised by Safety Committee.
The Magrabi Eye hospital in Cairo is applying for certification 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, Magrabi will develop policies, systems and procedures to manage environmental, health and safety and social issues and general 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.
Magrabi is planning for its other facilities, existing ones as well as the new expansion facilities, to gradually develop health care management standards according to both national and IFC guidelines and obtain certification to JCIA standards within the first years of their operation.
Management systems and internal capacity vary in different countries where the Group operates. In their current operations in Sana`a, Yemen, there is currently inadequate capacity to address EHS issues. However Magrabi is planning to establish an appropriate EHS management structure and capacity in their new expansion hospital in Sana`a. The long experience that the Group has in managing hospitals and clinics and the experience that the Group will derive from the certification process by JCIA standards will provide an excellent template for their current facilities as well as for their new expansions. In order to manage EHS issues in their eye centers across the region the Group will need to expand its existing EHS system in Magrabi Eye hospital in Cairo to other developments that are part of the Project.
- Training:
Magrabi 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; and
- patient rights.
Doctors and nurses are trained and certified in providing life support. Supervisors conduct regular meetings with staff to discuss and review performance. In addition, periodic trainings are provided to Magrabi medical staff by some affiliated US based hospitals e.g. John Hopkins, through Visiting Professor Programs. Magrabi Eye Cairo hospital is a referral training center for other hospitals of the Group.
For other facilities, for example in Sana`a, the training is organized for doctors and nurses by Magrabi Group Eye hospital doctors, which spend couple of months in Sana`a providing on the job training. Also, due to the cultural gender sensitivities, Magrabi Eye in Yemen is planning to employ experienced nursing staff from abroad with international experience.
- Community Engagement:
Prior to the establishment of its facilities, the company consults with local governments, surrounding businesses and communities. The business enabling framework differs from country to country in which Magrabi operates, ranging from very well established to very weak or non existent requirement for community engagement. Depending on local legal requirements, Magrabi keeps open communication channels and consults regularly with local authorities. Each existing facility implements, with the given local legal requirements, grievance mechanisms for receiving and addressing grievances raised by the local community. No complaints have been received from the local communities near its existing sites.
- Monitoring and Reporting:
Monitoring of air emissions, liquid effluents, and water quality varies from country to country in which Magrabi operates i.e. in Yemen there seems not to be specific Health Care Law that defines the monitoring requirements whereas Magrabi Eye facility in Cairo, as a part of gradual certification by JCIA, conducts regular internal monitoring of air emissions, wastewater discharges and the disposal of medical and other wastes. The Quality team of Magrabi Eye hospital in Cairo has already developed a set of documents as a preparation for JCIA certification and various EHS monitoring reports will be assessed during the pre-certification audit.
Results are reported to management and local environmental authorities who also conduct their own inspection of Magrabi’s electricity, sewage and water, fire protection and lighting systems, elevators, boilers, pressure containers and measuring devices.
Magrabi`s Safety Committee reviews the monitoring results and identifies corrective action. Similar reporting mechanisms will need to be established in the Group’s current and future developments in Yemen, Sudan, Egypt and Saudi Arabia.
- Magrabi is committed to:
- Update IFC on its development and use of its planned Environmental and Social Management System template for integrating environmental and health and safety issues into the design, construction and operation of its current and new healthcare facilities, and provide a copy of the ESMS template to IFC.
- Update IFC on the implementation and certification of its integrated management system for environmental, health and safety, life and fire safety and social issues at its existing and new facilities to the Joint Commission International Accreditation (JCIA) standard.
- PS2: Labor and Working Conditions
- Human Resource Policy and Management:
Magrabi Eye hospital in Cairo has a comprehensive human resources (HR) policy and documented procedures for managing HR issues, ranging from recruitment and retention, working hours, maternity and paternity leave, training and staff development, performance assessments and organization climate and culture. The company’s HR policies, management system, conditions of employment and working conditions are in compliance with national law and PS2. The HR policy provides options for flex time, compressed work hours or part time work. A number of regular trainings are held i.e on-job, in-house (patients care, time management, managing stress, team work, selling skills), and external (basic management skills and academic certificates for finance, IT, HR, Sales and Marketing). Performance management practice is a basis for awarding a wide range of regular and fringe benefits i.e Health, Social and life insurance, Education Assistance plan, Management Bonus, Incentive Scheme, Retirement Plan. Staff engages 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.
Magrabi Eye hospital in Yemen has developed an HR policy according to the Yemeni Labor Law and Magrabi Group HR policy. Due to the different management structure, different HR/Admin issues, such as performance measurement, bonuses allocation or grievances are being dealt by a senior management and on an individual basis. The salaries are high for local Yemeni standards and every year there is an average salary increase of 7-15%, based on a worker’s performance, which is assessed by a HR/Admin manager. Two years ago a law on social requirements has been enacted in Yemen requiring each employer and employee to contribute 15 % total from the annual gross salary (9% and 6% respectively) into the “employer’s social / pension package”.
- Worker’s Organization:
Magrabi Eye Hospitals comply with national laws in the countries they operate. Although the work force in Magrabi have individual contracts, establishment of workers association is not prohibited or discouraged by the Magrabi and if so requested by workers Magrabi will establish a staff union in compliance with local and IFC requirements.
The Group’s developments in other countries should be ready to set up similar arrangements.
- Non-Discrimination and Equal Opportunity:
Magrabi’s policies and procedures outline the company’s human resource policy, commitment to non-discrimination and equal opportunity.
- Retrenchment:
Magrabi will be hiring new employees, primarily local physicians and staff, for its expansion facilities. Also, due to the cultural gender sensitivities, Magrabi Eye in Yemen is planning to employ experienced nursing staff from abroad with an international experience. Staff turnover is higher in, for example Cairo that in Sana`a, as a reflection of existing / non existing market for the doctors / nurses in these cities. In case of retrenchment, a worker is provided with a package of 2-6 months salary
- 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 minimum required age of 18.
- Occupational Health and Safety:
Magrabi Eye hospital in Cairo and its JCIA -compliant management system includes policies and procedures for managing occupational health and safety issues within its facilities. Major components of occupational health program are administrative policies and procedures and operational policies and procedures:
- screening -periodic testing for all personnel,
- health education and counseling - training for occupational hazards, posters and newsletters, hand disinfection tools availability,
- occupational illness and injury treatment - personnel protective equipment, needle stick injury prevention, tracking and follow-up, vaccination program,
- non occupational illness treatment - health insurance system,
- environmental assessment and control - high risk areas biological monitoring, water quality monitoring,
- record keeping - employee health records, needle stick injury logbook.
For other Group’s existing hospitals and new expansions in different countries in development of OHS system the Group will need to use the template that is developed for Cairo operations.
Magrabi will use its well developed HR policy and documented procedures for managing HR issues and implement it in its future expansions so that the Group HR policies, management system, conditions of employment and working conditions are in compliance with PS2 and with national laws of countries in which Magrabi will expand its operations.
- PS3: Pollution Prevention and Abatement
- Pollution Prevention, Resource Conservation and Energy Efficiency:
Magrabi Group is developing a template to be used for the design, construction and operation of all of its new healthcare facilities. The template will be consolidating the Group’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, and its appropriate management.
- Magrabi Eye Cairo:
For the company’s existing facilities in Cairo electricity is provided from the grid and generated on-site from diesel generator. Electricity is available for all hospital areas 24 hours daily and uninterrupted in high risk area as operating theatre, recovery room and outpatient clinics through main power supply (2 high voltage lines, 2 medium voltage switch gears, 2 transformers, a pass coupler (connecting both lines in case of power disruption), generator, power factor correction, UPS unit, earthing cables for electrical and biomedical safety). Diesel generator is Caterpillar model with high energy efficiency. Energy-efficient systems and equipment are incorporated into the design of all of its current facilities, and for all future developments. Air emissions are compliant with local and IFC requirements at Magrabi’s existing facilities.
Bottled water is used for drinking or medical purposes. City Utility supplies the Hospital with the potable water. There are three water tanks available for main hospital (80 cubic meters), operating room (12 cubic meters), low pay hospital (64 cubic meters).
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 storage tanks are cleaned regularly according to hospital policy and the quality of water is sampled periodically to check for bacterial contamination.
Wastewater discharges are pre-treated with chlorine disinfectant prior to their discharge to municipally-operated sewage and water treatment plant in Cairo. Wastewater discharges are compliant with local and IFC requirements.
- Magrabi Eye Sana`a:
Magrabi Group is planning to construct new eye hospital in Sana`a with all the latest health care facility standards. Current Magrabi’s hospital in Sana’a is located in a leased building on first four floors with limited options for establishing proper health care facility EHS management systems.
Electric power is supplied via national grid and back up diesel generator. The generator is placed in a separate storage room at the building parking lot. Bedsides Magrabi Eye hospital, there are a number of other lease holders located in the same building.
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.
Wastewater system in the hospital is a mixed one i.e sanitary and process waste water is discharged to a city sewer and treated in the city waste water treatment plant.
- Solid Waste and Hazardous Materials
- Magrabi Eye Cairo:
The management of hazardous, clinical wastes is controlled through Magrabi JCI-compliant management system in coordination with the infection control team. Clinical and hazardous wastes are collected in specially identified yellow bags and disposed off in a locked temporary storage area within Magrabi Eye hospital premises. This storage area needs to be upgraded to meet IFC guidelines. Housekeeping staff wear appropriate protective equipment and follow Magrabi infection control policy when disposing of clinical waste. All wastes, including solid waste, are removed regularly from the storage area by a government-approved contractor Cairo Teaching University Hospital “Kasr Al Aini”. The contractor is responsible for the offsite incineration of all clinical and hazardous waste. No incineration is conducted on-site.
- Magrabi Eye Sana`a:
Clinical and hazardous wastes are collected in specially identified containers within Magrabi Eye hospital premises and removed by the housekeeping staff and placed inside bins in a locked temporary storage area. Waste disposal is performed regularly by an authorized contractor and finally disposed off outside the city Sana`a at the disposal site. Magrabi management is considering the building of on-site incinerator for infectious medical waste, and IFC will provide technical guidance on appropriate technology.
Emergency Preparedness and Response
- Magrabi Eye Hospital Cairo:
As part of its effort to approximate to the JCI accreditation, the system, policies and procedures are in place to specifically address life and fire safety issues in compliance with n ational and IFC guidelines. Mandatory fire safety training is provided for all new and existing hospital employees but drills are not carried out regularly in accordance with the plan. Magrabi Eye Hospital has duty engineers and safety manager available on-site 24 hours per day who are in charge of monitoring fire safety equipment. Magrabi Eye Hospital’s operations and facilities are in compliance with all local fire safety laws and regulations and the local government monitors compliance annually.
- Magrabi Eye Hospital Sana`a:
In spite of the extended efforts of the Magrabi Group to bring the current operations of the Hospital in Sana`a in compliance with the Group`s health care operating standards there are still some outstanding issues that specifically relate to life and fire safety. The Hospital is located in a building that originally was designed and built as an apartment building, so that the Group had to refurbish the original design of the leased premises at first four floors of the building to fit the health care operations` requirements. Due to this fact the existing emergency preparedness and response plan has been designed within these limitations. Most of the current operations will be transferred to the new hospital when it is built. Two floors of the current premises will be retained as a clinic center and as such will need to be upgraded to comply with the life and fire safety requirements of IFC. That will require construction of alternative escape stairways and additional fire fighting equipment.
The new hospital will need be designed and built to satisfy the best international best practice in health care industry, local applicable regulatory requirement and IFC EHS requirements.
For both hospitals in Cairo and Sana`a, 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.
- Greenhouse Gas Emissions:
Magrabi Eye Hospital’s operations do not generate GHGs in excess of 100,000 tons of CO2 annually.
Magrabi Group has committed to bring all its hospitals and clinics that are part of the Project in to the compliance with local regulatory requirements and IFC guidelines for air quality, wastewater discharges, ambient noise and workplace conditions.
- PS4: Community Health, Safety and Security
- Community Health and Safety:
Both Cairo and Sana`a Mgrabi Eye hospitals have facilities and management procedures in place to prevent and manage health and safety aspects of their operations starting from design phases, construction, operations and decommissioning and closure. Several outstanding issues that IFC has observed during the appraisal visit will be adequately addressed by the management of Magrabi as the management of the Group has expressed commitment to bring them into the compliance with the best international practice and IFC EHS requirements for health care facilities.
Magrabi Group will evaluate health and safety (including L&FS as mentioned above, and occupational health and safety) risks and impacts that could affect the local communities during the design, construction, operation and decommissioning stages of the project in various countries where the developments are planed, and will establish measures to prevent or mitigate such risks and impacts commensurate with the identified risks and impacts.
Contractors for design of the new buildings and the construction will apply sound principles of environmental engineering and safety engineering during the sitting and construction phase, and these principles will be stipulated between the contractors and Magrabi Group in their contracts, to prevent and/or avoid any reputation or other risk for Magrabi Group associated with potential adverse environmental and social performance of the contractors activities. Structural elements will be designed and constructed by qualified and experienced professionals and certified and approved by competent authorities or professional to IFC, similar to the L&FS requirements, as per the L&FS guidelines.
- Emergency Preparedness and Response:
An emergency preparedness and response plan covers potential incidents associated with the current operations. 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 heath and environmental authorities as needed.
- Security Personnel Requirements:
Professionally managed and trained security personnel are hired to guard Magrabi Eye Hospitals 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 the hospitals and clinics to ensure the safety of patients.
Specific to the Hospital in Sana`a, guards are instructed to request from all visitors which wear a traditional knife “gambia” to deposit it to a safety locker while visiting the hospital. So far, as reported by the management of hospital, there were very few incidents with those visitors who did not want initially to leave their knife at the reception area.
- PS5: Land Acquisition and Involuntary Resettlement
- Compensation and Benefits for Displaced Persons:
No persons have been displaced either physically or economically by the current facilities.
- Consultation and Grievance Mechanism:
The developer(s) of Magrabi Group’s proposed sites has/will continue to consult with local government authorities and any potentially affected owners regarding its acquisition of land use rights for its future sites.
The company will establish grievance mechanisms for receiving and addressing grievances raised by the local community.
- Resettlement Planning and Implementation:
No resettlement has been needed so far in Magrabi’s operations.
- Physical Displacement:
Magrabi Eye Hospital in Sana’a is located in leased premises, in a building that did not involve physical or economic displacement of local business or communities. The Group has yet to confirm the final location for its expansion facility in the urban center of Sana`a. Sites under consideration are clear of any ownership disputes and there will be no physical or economic displacement as there are no people living on the site.
For any other development the Group is committed to follow local laws and IFC PS5: Land acquisition and involuntary displacement and in arranging for future developments.
Magrabi is committed to update IFC on the land acquisition process once future development sites are confirmed, and provide records of consultations undertaken and compensation provided to demonstrate compliance with PS5.
Stakeholder Engagement
Prior to the establishment of its facilities, the company consults with local governments, surrounding businesses and communities. The Group maintains communication channels and consults with local authorities. No complaints have been received from the local communities near the Group’s existing sites. There has been and will be a point of contact at Magrabi Eye Hospitals in case of any complaint or grievance in the future.
As part of its corporate responsibility and community engagement initiatives the Magrabi Group performs in its Yemen hospital approx 25 cataract surgeries during the months of Ramadan. Magrabi Eye in Egypt performs s regular promotional caravan in rural, difficult to access, areas and provides either cost free or low cost services.
The Chairman of the Group, Dr. Akef El Magrabi is well-known for his charitable work. Back in 1999 Dr. Akef established Al Noor–Magrabi Foundation with the primary aim to combat blindness and visual disability. The Foundations’ main goals are to provide high quality medical services to the population, to conduct surveys, develop training curricula for all eye care cadre particularly to those who are working in the field, and run community based health awareness activities. The foundation has performed more than 90 medical outreach caravans covering 22 governorates in Egypt, providing medicinal services for free (screening over 31000 patients, distribution of medicine, performing visual acuity assessment and prescribing glasses for more than 3500 patients ) and performing cataract and other eye surgeries. The Foundation serves as a referral center for WHO in Egypt and the Ministry of Health.
The Magrabi Group will make available for the public this ESRS in local languages, at the local building sites in Egypt, Yemen, Sudan and Saudi Arabia (at the time if the development), and publish an advertisement about the ESRS in a local newspapers and on the Magrabi Group website.
After disclosure of this ESRS, Magrabi Group will initiate communications with the local communities and its representatives and local authorities to address any critical concerns that may arise during the project’s construction phase, such as noise, dust, working hours, increased local traffic and congestion due to heavy vehicles traveling into and out of the site, construction-related water supply and wastewater discharge/treatment, solid waste disposal, storage and containment at the site of hazardous material if any, as well as during the operational phase of the campus.
Questions or comments can be directed to:
Mr. Khairy Abdullatif
Senior Vice President – Financial & Legal
Jeddah – Saudi Arabia
Telephone: +966 2 636 9822
Fax: +966 2 637 0987
E-mail: khairy@magrabi.com.sa
The environmental documents will be made available at the following locations:
- Magrabi Hospital Cairo: El-Sayeda Nafisa Sq, Cairo Egypt
- Magrabi Hospital Sana''a: Al Zubairy St., Sana''a Yemen
As part of its corporate responsibility and community engagement initiatives the Magrabi Group performs in its Yemen hospital approx 25 cataract surgeries during the months of Ramadan. Magrabi Eye in Egypt performs s regular promotional caravan in rural, difficult to access, areas and provides either cost free or low cost services.
The Chairman of the Group, Dr. Akef El Magrabi is well-known for his charitable work. Back in 1999 Dr. Akef established Al Noor–Magrabi Foundation with the primary aim to combat blindness and visual disability. The Foundations’ main goals are to provide high quality medical services to the population, to conduct surveys, develop training curricula for all eye care cadre particularly to those who are working in the field, and run community based health awareness activities. The foundation has performed more than 90 medical outreach caravans covering 22 governorates in Egypt, providing medicinal services for free (screening over 31000 patients, distribution of medicine, performing visual acuity assessment and prescribing glasses for more than 3500 patients ) and performing cataract and other eye surgeries. The Foundation serves as a referral center for WHO in Egypt and the Ministry of Health.
The Magrabi Group will make available for the public this ESRS in local languages, at the local building sites in Egypt, Yemen, Sudan and Saudi Arabia (at the time if the development), and publish an advertisement about the ESRS in a local newspapers and on the Magrabi Group website.
After disclosure of this ESRS, Magrabi Group will initiate communications with the local communities and its representatives and local authorities to address any critical concerns that may arise during the project’s construction phase, such as noise, dust, working hours, increased local traffic and congestion due to heavy vehicles traveling into and out of the site, construction-related water supply and wastewater discharge/treatment, solid waste disposal, storage and containment at the site of hazardous material if any, as well as during the operational phase of the campus.
Questions or comments can be directed to:
Mr. Khairy Abdullatif
Senior Vice President – Financial & Legal
Jeddah – Saudi Arabia
Telephone: +966 2 636 9822
Fax: +966 2 637 0987
E-mail: khairy@magrabi.com.sa
The environmental documents will be made available at the following locations:
- Magrabi Hospital Cairo: El-Sayeda Nafisa Sq, Cairo Egypt
- Magrabi Hospital Sana''a: Al Zubairy St., Sana''a Yemen
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.