27348 - Coco Ocean

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Environmental & Social Review Summary

Project Number

27348

Company Name

COCONUT COMPANY LIMITED

Date ESRS Disclosed

Sep 24, 2008

Country

Gambia, The

Region

Africa

Last Updated Date

Nov 30, 2016

Environmental Category

B - Limited

Status

Active

Previous Events

Approved : Dec 9, 2008
Signed : Dec 12, 2008
Invested : May 8, 2009

Sector

Resort Hotel (Including Lodges)

Industry

Tourism, Retail and Property

Department

Regional Industry - MAS Africa

Project Description

Coconut Company Limited (the “Borrower” or the “Company”), currently owns and operates the successful Coconut Residence. The proposed project will set up a new five star hotel, the Coco Ocean Resort & Spa, to be located on Bijilo beach near Banjul. The new hotel will include about 100 suites, 12 villas, 3 Restaurants, Spa and possibly a 250 person Conference room and a small commercial retail complex (“Coco Ocean” or the “Project”). The project is being developed and operated by Coconut Company Limited. Coco Ocean will be the first dedicated Spa hotel on the West African coast.

Overview of IFC's Scope of Review

IFC’s review of the project included:

- a review of information provided in response to a questionnaire submitted to the Borrower,
- visits to both the existing Coconut Residence property and the construction site at Bijilo beach to view the existing social, environmental, health and safety performance of the Borrowing and to understand the physical features of the Coco Ocean Resort, and
- discussions with the Borrower’s management.

E & S Project Categorization and Applicable Standard

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:

- PS1 Social and Environmental Assessment and Management Systems
- PS2 Labor and Working Conditions
- PS3 Pollution Prevention and Abatement
- PS4 Community Health, Safety and Security

Prior to construction, the land was a sandy coastal area with limited vegetation. It permitted only limited opportunities for agriculture without addition of organic matter and fertilizer. The land was acquired in [2005] from the Gambian Tourism Authority. It is part of a tourism development area governed by a master plan. The land was clear of houses and farming at the time that it was acquired for the Project. No prior involuntary resettlement was involved. Thus, risks associated with involuntary land acquisition, as would be managed under PS 5 (Land Acquisition and Involuntary Resettlement), were not present. The land was effectively disturbed natural habitat with little value as habitat. Thus, PS6 (Biodiversity Conservation and Sustainable Natural Resource Management) is not applicable. There are no groups in the project area that would be considered Indigenous People for the purposes of PS (Indigenous People). Thus, that Performance Standard does not apply. There are no cultural heritage sites on the project site and PS 8 (Cultural Heritage) does not apply.

The key social and environmental issues associated with this project are:

- Worker health and safety
- Wastewater treatment
- Fire and life safety

The project itself will have a limited impact on the surrounding semi-urban environment. The additional measures requested following the IFC review will use known and accepted procedures and technologies to avoid or mitigate social and environmental impacts. Thus, this project is a category B under IFC’s Environmental and Social Review Procedures.

Environmental and Social Mitigation Measures

IFC''s early review of this investment has identified the following environmental, social, health and safety issues: environmental and social assessment requirements, environmental and social management of construction and operation, community engagement, labor and working conditions (during construction and operation), opportunities for energy conservation and efficiency, wastewater treatment, solid waste management, application of international standards for life and fire safety (during construction and operation), security, and land acquisition.

PS 1: Social and Environmental Assessment and Management Systems

Assessment: The project does not have a documented social and environmental assessment. However, the company has incorporated environmental and social considerations into the design and operation of the hotel. These include recycling of wastewater for use on hotel grounds, providing only showers in most of the guest rooms to limit water usage, heating water with solar collectors, designing for maximum air circulation to limit the use of air conditioning, and encouraging fishermen to use the beach in front of the hotel to provide a supply of fresh fish for the hotel kitchen.

Management, Organization, and Reporting: The company will identify a person to take responsibility for managing social and environmental issues associated with the new property. This person will, among other things ensure that the attached supplemental action plan is competed, monitor electricity and water use, and consult with neighbors, fishermen and other local stakeholders on the project’s impacts. The person responsible will report on the monitoring results and consultations to senior management at the Company.

Community Engagement: The project maintains informal engagement with the local community. Hotel management has, for example, checked with neighbors on impacts such as potential cones of depression from the bore holes. The hotel will make a practice of publicly displaying information on resource savings from its use of solar power and recycling of water.

PS 2: Labor and Working Conditions

Human Resources Policy: The Company is in the process of formulating a human resources policy. IFC will review this policy before it is made official to ensure that it meets the requirements of PS 2. The Company’s policies will include adherence to national law, including the right to collective bargaining, and non-discrimination. The Project will have a person responsible for human resources management (at the existing hotel these issues are handled by the general manager). Employee grievances will be handled through this person.

Worker Health and Safety: Observations of construction activities indicated that use of personal protective equipment is not generally observed. The problem stems from the construction work force being drawn from casual labor, which is not well trained in the need for or use of such equipment. The use of casual labor is generally the case in The Gambia, even for long-established contractors. At this stage in construction, the major part of overhead work is complete, so the risk of accident has been lessened. All the same, the Company is initiating a continuous education program using signage, posters and other means to increase the number of people wearing protective equipment and following proper procedures.

PS 3: Pollution Prevention and Abatement

Wastewater treatment: The hotel will use a three stage treatment plant. Water from the plant will meet IFC guidelines for discharge to surface waters. Effluent, however, will then be used to water the hotel gardens. Using an international benchmark for hotels with high levels of service, the Project can be expected to use around .9 m3 of water per day per occupied room, which will become effluent. (The actual usage is expected to be below this benchmark because almost all rooms have only showers in order to save water.) Given that the hotel will have eventually 100 rooms, the effluent will be approximately 100 m3 per day when all phases are completed and the hotel is fully occupied. Each hectare of land requires approximately 33 m3 of water per day, particularly during the dry season when the hotel will be full. Thus, the effluent water will be used to water three of the five hectares of hotel grounds. There will be no need to release it to surface waters. Additional water will still be needed for this purpose, though this may be balanced out during the wet season when hotel occupancy is low.

Resource Conservation: The hotel is designed to limit the use of energy. A system of pipes running throughout the roofs of the buildings is used to heat the water for the swimming pools. Hot water for rooms is heated through roof-top solar heaters. Air conditioning use will be reduced by building designs that include extended eaves to prevent room heating by direct sunlight and air circulation through louvered windows. To serve as a basis for future water management efforts, the Company will sub-meter the hotel by area, e.g. spa, bedrooms, kitchen, laundry, etc.

Air emissions: The hotel will use the national grid, but will have three back-up generators: one of 500 kVA and two of 350 kVA. These are of a combined size that is below the level where IFC guidelines on air emissions apply. However, to limit air emissions, the generators will follow a maintenance schedule to ensure that they are operating efficiently. The diesel tanks for the generators are above ground and will have sufficiently high bunds around them to hold a spill should one occur.

Waste: Hotel waste will be collected by a third party for disposal in a government-approved waste disposal site. The waste will be collected daily to prevent attracting pests. The hotel will use organic wastes, with the exception of kitchen food waste, for compost on its vegetable/fruit garden.

Pesticides: The project will use neem tree oil as a pesticide for both its hotel grounds and vegetable/fruit garden.

PS 4: Community Health, Safety and Security

Life and Fire Safety: The hotel will consist of several one to two storey structures. Smoke detectors and alarms in each guest room will be tied to a central control board. Fire extinguishers and hydrants will be placed throughout. The hotel management has worked with the local fire department to insure that the hydrants are appropriately placed for use in case of an emergency. There is an emergency water reservoir with a separate distribution system just for the fire hydrants. The hotel plans will be reviewed by an independent expert for conformity with European Union fire safety standards. As the hotel is still under construction, any needed alterations will be made prior to the hotel opening.

Food safety: The kitchen in the hotel is being constructed to allow separation between fish, meat and vegetables as they are delivered, cleaned and prepared and, thus, to avoid the risk of food contamination. The hotel will use water from two boreholes. The hotel is avoiding using the water from one because it was found to be contaminated. Water can be tested at a neighboring enterprise with the ability to test for both chemical and biological contamination. All the same, the hotel will encourage guests to use bottled water for personal consumption.

Security Personnel: The hotel uses contract security personnel. They are specifically trained for working with hotel guests. The company will include the requirements of PS 4 into its future contracts with the security company.

Stakeholder Engagement

Client Documentation

File Name	Actions
Coco Ocean - Supplemental Action Plan 09.17.08 .pdf

**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:

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).

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