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 System; PS2 – Labor and Working Conditions; PS3 – Pollution Prevention and Abatement; and PS4 – Community Health, Safety and Security. The project appraisal assessed the applicability of PS6: Biodiversity Conservation and Sustainable Natural Resource Management; and PS7: Indigenous Peoples, and PS8: Cultural Heritage. In regard to PS6, the new hospital is located in an urban area designated for hospitals and no impact on biodiversity is therefore expected. With respect to PS7 and PS8, no indigenous peoples or cultural heritage resources will be affected by development of the project. PS5: Land Acquisition and Involuntary Resettlement is not applicable because land acquisition was undertaken on a willing buyer willing seller basis. There was no involuntary resettlement. The site of the new hospital is in the Hospital Square, an area designated for hospitals. It was previously the site of a commercial warehouse. Asiri Group of Hospitals is in compliance with all applicable national and local laws on land acquisition and has confirmed that all requisite permits, consents and approvals have been obtained.

The project has been classified as Category B according to IFC’s Environmental and Social Review Procedures. The key social and environmental aspects associated with the project include: emissions to air and water; ambient air quality; and employee and community environment, health, safety and security. While the impacts are diverse, they are not unprecedented, are not large scale; are largely limited to the project site; and are not likely to impact environmentally sensitive areas. Further, it is possible to readily design and implement engineering and management measures to mitigate adverse impact due to: emissions to air and water; management of hazardous materials and wastes; employee and community health and safety during construction and operations.

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 host country laws and regulations, IFC’s social and environmental Performance Standards, and relevant environmental, health and safety (EHS) guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. PS1: Social and Environmental Assessment and Management Systems: The Group currently has no formal environmental, social and health and safety (ESHS) management system or standard operating procedures. Currently, responsibility for environmental management and fire safety lies with the Group Manager Maintenance and the Fire Consultant, although no formal reporting structure has been defined. All staff have received training in waste segregation, infection management, fire safety, amongst other issues. The laboratory has ISO 9001:2008 accreditation and the Human Resources (HR) Department intends to work towards ISO 9001:2008 over the coming year. After the move to the new hospital, the Group intends to work towards Joint Commission International (JCI) accreditation to demonstrate continuous improvement in quality and safety of health care. The Group has agreed to develop a corporate Social and Environmental Management System (SEMS) compatible with ISO 14001. Although Environmental Impact Assessments (EIAs) are not required by the Government of Sri Lanka for healthcare facilities, national law requires that a number of environmental consents and clearances be obtained to ensure that key environmental impacts have been assessed and accounted. These clearances are necessary to receive regulatory approval to commence construction and for receipt of a license to operate. The Group has received all requisite clearances for its existing facilities and provided copies of clearances for construction for Central Hospital to IFC. The Group will forward to IFC consents to operate for all its facilities. PS2: Labor and Working Conditions: Asiri Group of Hospitals employs over 2500 permanent staff, approximately 75% of which are female. In addition, it has locum/substitute doctors and consultants on its pay roll and external security for the hospitals is undertaken by contractors. With the opening of Central Hospital the permanent staff number will increase to over 3000. Management has no restrictions on unions, although there are none that are active. There is provision for collective bargaining in Sri Lanka. The Group has a Human Resources policy and procedures manual which includes a grievance mechanism, non-discrimination, disciplinary policy and termination process, performance appraisal, working hours, overtime and leave arrangements. The Group HR Department intends to work towards ISO 9001 accreditation and has agreed to ensure that elaboration of HR policies and procedures meet IFC PS 2. The Group has a safety policy that iterates its commitment to ensuring that all safety devices are working properly and the responsibility of the Employee to use such safety devises and report any accidents. However, the training plan is not prescriptive on occupational health and safety and no procedures have yet been developed. There is a safety manual for medical laboratories and diagnostic centers. The sponsor has agreed to ensure that the SEMS adequately addresses OHS implementation, monitoring and reporting throughout the hospitals. PS3: Pollution prevention and abatement: The Hospitals in Colombo utilize grid power supplemented by back up diesel generators. Noise levels are monitored by the maintenance contractor to ensure that they do not exceed local regulations. Monitoring of emissions from the generators is not required by Sri Lankan authorities. All hospitals use a mixture of mains water, bottled water and permitted groundwater resources. Borehole and treated water quality is monitored with respect to Sri Lanka specification for potable water. Effluent from laboratories, theatres, Out Patients Department, the kitchen and laundry is treated in chemical treatment plants and disposed off into the main sewers. The effluent is tested periodically by the plant maintenance engineers and treatment is adjusted to ensure local regulations are met. Solid and hazardous waste at all hospitals is segregated by category and transferred to the incinerator (see below) at least once a day. Domestic waste and biodegradable waste is collected separately by the Colombo Municipal Council. The Group has agreed to prepare a comprehensive waste management plan which will comply with IFC guidelines, with standard operating procedures for each hospital, ensuring that storage and disposal of all hazardous wastes meet IFC Performance Standards and local regulations. The medical waste from hospitals in Colombo is incinerated in the Asiri Surgical Hospital incinerator. A new incinerator is being installed at Central Hospital in compliance with Government regulations. The Asiri Matara Hospital has a small locally fabricated incinerator. Currently emissions from incinerators are not monitored. Monitoring of emissions from the incinerators is not required by Sri Lankan authorities. The Group has agreed to provide the specifications of the effluent treatment plants and incinerators of all its hospitals together with monitoring data, and if necessary, a statement of how liquid and solid waste treatment facilities will be brought up to IFC standards. The Group has a detailed Infection Control Policy and Procedures Manual in place, implementation of which is the responsibility of the Medical Director of each hospital. There is a programme of awareness raising and training of staff, backed up with periodic monitoring by the Medical Director. The Group is currently looking to recruit an infection control specialist. PS4: Community health, safety and security Asiri Group of Hospitals currently does not have policies or procedures for community health, safety and security. The Group will prepare an emergency response plan which provides an integrated approach to address emergency needs and protect the health and safety of workers, the public and the environment. It will include evacuation plans and training provisions for each of its hospitals, and it will be disclosed to the relevant government agencies and community. Asiri Group of Hospitals has agreed to revise its hospital entrance signage and information desk placards to include contact details (name, phone number and email address) of staff at each of its facilities who are responsible for receiving and responding to questions, concerns or complaints raised by communities or other stakeholders. Each hospital will maintain a register of such enquiries and how they have been addressed. The Group’s own security staff provide security services inside the hospital and a contractor to provide these services outside the building. The security staff do not carry fire arms and receive training in customer care and public relations. The Fire Service Department has specified detailed requirements for the new hospital, which are based on the British Standards. Before issuing a Certificate of Conformity, Fire Precautions Adequacy Inspection will be carried out by the Fire Chief Officer and all Fire Protection Systems will be tested to ensure satisfactory operation to the approval of the Chief Fire Officer. The Group has training programmes for all staff that cover fire prevention and response, and designates trained fire responders throughout the organization and there are procedures in place in case of fire. The Group has agreed to undertake an independent assessment of the life and fire safety design, management and monitoring in each hospital to ensure that they comply with International or British Standards.

The Group has a CSR programme that provides support to two institutions. It has contributed to construction of accommodation for outpatients visiting the National Cancer Institute, Maharagama; and provided free MRI scans to a selected group of poor people who have been referred by the National Cancer Hospital. It has also financed the renovation/rebuild of a psychiatric ward at the Anuradhapura Hospital. While these are discrete projects, the Group intends to develop a more comprehensive CSR policy and carry out programmes in the area of health and hygiene. As yet, the client has no formal procedure for local community grievance redressal. However, the Group has a good record of handling local communities’ representations. In response to local residents dissatisfaction with having a hospital in their residential neighbourhood, directors of the Group gave an undertaking that when they shift from Asiri Central Hospital they will not sell the land for another hospital.

Ms Sharmini Nimalasuriya Director Finance Asiri Surgical Hospital PLC # 21, Kirimandala Mawatha Colombo-05. Email : sharmini@asiri.lk