28566 - Hotel Erbil 2009

Who We Are
Who We Are

IFC is the largest global development institution focused on the private sector in developing countries. By encouraging growth, IFC advances economic development, creates jobs and improves the lives of people.
More About Us
About IFC

Our Leadership

Development Partners
Accountability

Learn more about accountability
Annual Report

Download the Report
What We Do
What We Do

IFC advances economic development and improves the lives of people by encouraging the growth of the private sector in developing countries. We achieve this by investing in impactful projects, mobilizing other investors, and sharing expertise.
What We Do Overview
SOLUTIONS

Our products and services
OUR PRIORITIES

Climate Business

Fragile & Conflict Afflicted Situations

Gender

Mobilizing Private Capital

Sustainability
SECTORS & EXPERTISE

Agribusiness & Forestry

Creative Industries

Education

Financial Institutions

Funds

Health

Infrastructure

Manufacturing

Public-Private Partnerships

Tourism, Retail & Property

Trade & Supply Chain Finance

Venture Capital

Working Upstream
Where We Work
Where We Work

As the largest global development institution focused on the private sector, IFC operates in more than 100 countries around the globe. We apply lessons learned in one region to solve problems in another.
Overview
By Region

Africa

East Asia and Pacific

Europe

Latin America and the Caribbean

Middle East and Central Asia

South Asia
Our Impact
Our Impact

Our impact improves lives. IFC brings a clear set of advantages to the world’s most challenging markets. Including a history of innovation, a global mandate, and a determination to achieve measurable development impact.
Our Impact Overview
PRINCIPLES & MEASUREMENT

Impact Investing at IFC

Measuring and Monitoring (AIMM)

Evaluation

Sustainable Development Goals (SDGs)

Owned by 186 member countries and consistently rated AAA/Aaa. IFC aims to achieve our mission of promoting development by providing debt and equity to the private sector, through a range of benchmark and bespoke products.

For Partners

For Investors

Get in Touch

Environmental & Social Review Summary

Project Number

28566

Company Name

MALIA INVEST HOLDING SAL

Date ESRS Disclosed

Oct 26, 2009

Country

Iraq

Region

Middle East

Last Updated Date

Jun 11, 2022

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Dec 11, 2009
Signed : Dec 14, 2009
Invested : Dec 29, 2009

Sector

City and Business Hotel

Industry

Tourism, Retail and Property

Department

Regional Industry MAS MCT

Project Description

Malia Holding, SAL (Malia or the Sponsor), is financing the development of a greenfield hotel in the city of Erbil in northern Iraq. Hotel Erbil is planned as a five star business hotel, with 201 rooms distributed over 13 floors, 4 restaurants and supporting services. Malia has acquired a 20,000 m2 parcel of land from the regional/local authorities. The hotel will be operated by the Rotana Hotels Management Corporation (Rotana or the Operator), a hotel management company based in U.A.E. The project construction started 2007; concrete structure is completed while façade and electromechanical works are currently ongoing. Malia plans handover to Rotana of the first operational phase for testing of five floors and outdoor restaurants by June 2010.

Overview of IFC's Scope of Review

IFC''s review of this project included meetings with key senior management staff of Malia Holding, and managers of a Rotana operated hotel in Beirut, discussions on an environmental and social questionnaire presented by IFC and review of documents provided by the Sponsor and the Operator, including:

Malia Environmental Policy
Malia HR Policy & Procedures including recruitment, performance management procedures and training report
Life, Fire and Safety design criteria
Emergency Preparedness Procedures
List of Rotana Corporate Policies
Rotana Information Toolkit
Malia Energy Strategy
Malia Policies on Fire, Spills, Accidents, Training and Awareness
Sample of Site safety report and attendance

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; and
PS4: Community Health, Safety and Security.

The key social and environmental issues associated with the project include: management of Environmental, Social, Health and Safety (ESHS) during construction and operation; working conditions during construction and operation; optimization of resource inputs including water, energy efficiency and waste minimization practices; impacts of construction and operations on communities; and life and fire safety of hotel during operations. The potential adverse effects of the project are limited, site specific and reversible and can be readily mitigated. It is therefore concluded that this is an Environmental Category B project according to IFC’s Environmental and Social Review Procedure.

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 country laws and regulations and the IFC Performance Standards on Social and Environment Sustainability and relevant IFC/World Bank 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. Actions are summarized in the attached Environmental and Social Action Plan (ESAP).

PS1: Social And Environmental Assessment And Management Systems:

Malia Holdings has in place a corporate environmental policy and an environmental management system (EMS) that has been certified compliant since 1999 with International Standards Organization (ISO) requirements for ISO 14001. The national environmental requirements of the region were issued after the project construction started in 2007; however, Malia and Rotana have confirmed that the project will comply with all regulatory requirements. Malia will ensure, through an agreement with the hotel operator, Rotana, that the EMS is implemented fully and that all related host country laws, and IFC requirements are met. Rotana will report to Malia on a monthly basis on all aspects of its performance, including environmental, social and health and safety, and Malia will conduct regular inspections of the property to verify compliance. If instances of non-compliance arise, the Sponsor and Rotana will, within 15 days of identifying the non-compliant situation, develop an Action Plan for addressing the situation.

The company has provided IFC an Environmental Management System (EMS) manual that outlines the environmental monitoring program (EMP); environmental training; and accident, fire and spill management. IFC has requested that the EMS system be expanded to include social issues. Malia will revise the existing system to cover all aspects of environmental and social performance required by host country regulations and IFC’s PSs (ESAP item #1). In addition, the company will prepare detailed plans for crisis management, life and fire safety, emergency response, staff occupational health and safety, and food safety (in conformance with Hazard Analysis and Critical Control Points [HACCP] standards). Submission of a revised Social, Health, Safety, Environment (SHSE) system acceptable to IFC is included as an item in the Action Plan (ESAP items #2 and #6).

PS 2: Labor And Working Conditions:

At present, Malia has approximately 500 full time staff working on the construction project in Erbil, plus 22 sub-contracted seasonal staff; 95% of the staff in Erbil are Iraqi nationals. Malia has confirmed that it complies with all host country labor laws, and that its salary and wage scales meet or exceed the minimum wage norms for all types of employees. The Sponsor has established a comprehensive corporate Human Resources (HR) policy, approved by the Board Of Directors, that covers all of its operations and which will be applied to the Erbil operations. Malia has reviewed PS2 and confirmed that it complies with all PS2 provisions, with the exception of having a formal grievance mechanism, although it is Sponsor policy to encourage staff to raise issues of concern to their Managers or HR staff. Malia will amend its current HR policies and procedures to include a formal employee grievance mechanism, and disseminate the existence of the mechanism to all staff (ESAP item #3a). Malia confirmed that labor policies and working condition will comply fully with host country laws and regulations, all PS2 requirements, and Malia’s corporate values and policies. Malia will review Rotana’s performance on a regular basis to document that these provisions are being met (ESAP item #3b).

Malia requires all newly-hired employees to undergo a probation period of three months. Employee benefits include governmental social insurance for all staff. Current HR policies require induction training for all employees. It is Malia’s practice that appropriate personal protective equipment (PPE) is provided to anyone admitted on site during construction, although this practice is not referenced in explicitly in the Sponsor’s SHSE policies. As noted above, the company’s SHSE manual is to be amended to cover all aspects of workplace health and safety required by IFC’s Performance Standards, during both construction and operation. Malia includes requirements in its construction contracts to ensure that activities carried out by sub-contractors comply with local standards. These provisions will be amended to include requirements of IFCs Performance Standard 2 and EHS guidelines (as part of ESAP item #3a).

PS 3: Pollution Prevention and Abatement:

The government in Erbil provides grid power, which will be utilized by the hotel during operation. Power during construction is provided by four diesel generators totaling 435 kVA. Diesel fuel is stored in an underground storage tank equipped with secondary containment; average consumption is approximately 20,000 liters per quarter. Once the hotel is operational, the power transformer will be upgraded to 4 MW; in addition, four standby diesel-fired generators totaling 4000 kVA of capacity will be installed on site. Given the unreliability of grid power, Malia expects that the generators will be in use frequently and will monitor air emissions from all sources to ensure compliance with IFC guidelines.

Hotel utilities during operation will include an air conditioning system consisting of four water cooling chillers of 300 TR cooling capacity, and four diesel-fired boilers of 4.1 million BTU each. Waste water during construction is stored in three septic tanks totaling 80 m3 capacity and is collected by the municipality every two weeks. The Erbil authorities expect to complete the municipal sewage treatment system in the next few years; in the interim, however, Malia is installing a secondary waste water treatment plant to ensure that treated waste water meets international effluent treatment standards. Malia utilizes an energy efficiency approach as part of the EMS; during design, a facility ‘zoning areas’ approach is used to divide the hotel into distinct zones serving different purposes and utilizing different types and volumes of power to optimize energy use. Total power required is expected to be 3000 kVA at full load; the total installed capacity is 4x1000 kVA generators, one of which will be for standby purposes. Power consumption is consistent with international good practice for the hospitality sector.

Water is provided through a single well. Average consumption during construction is 75 m3/day, expected to increase to 250 m3/ day during operation. A dedicated supply of water for the fire system is stored in a 200 m3 tank. The Sponsor plans to install a water treatment system that includes ultraviolet treatment for domestic use and a reverse osmosis treatment unit for potable water and ice cube machines The Sponsor estimates that the domestic water requirements will be approximately ea 250 m3/day and potable water approximately 6 m3 per day.

The Sponsor has agreed to monitor, during construction and operation, wastewater discharge and air emissions from boilers and generators as well as stack emissions from the ventilation system to ensure compliance with IFC General Environmental, Health and Safety Guidelines (ESAP item #4). In addition, Malia has agreed to install secondary containment structures of all hazardous or flammable fluid containers, including diesel fuel.

Construction wastes are segregated by category and stored outside the hotel premises. At present, there are no municipal regulations in place to ensure that wastes are handled and disposed of in a manner consistent with good industrial practice. Given this, Malia has agreed to ensure that construction waste is stored in designated areas on site, and to contract with the relevant municipal authorities for disposal in landfills permitted by local government authorities.

PS 4: Community Health, Safety and Security:

Design of life and fire safety (L&FS) aspects of the hotel has been done in accordance with US National Fire Protection Association (NFPA) standards. Malia has commissioned a L&FS audit of the design and construction that assesses major fire risks; applicable codes, standards and regulations; and mitigation measures. The audit is being prepared by a qualified professional who will certify that the design and construction meets NFPA (or other internationally accepted) standards and local by-laws, wherever applicable, in compliance with the requirements of IFC’s L&FS guidelines (ESAP item #5).

As noted above, the company has agreed to develop and implement a disaster response plan for earthquakes, fires and other large scale emergency situations. Details of these plans will be communicated to any communities located in close proximity to the hotel. The design meets earthquake resistance standards of up to 7.5 degrees Richter and is consistent with accepted international standards. Regular testing has been carried out during construction and the integrity of materials (cement quality, steel framing) has been validated through regular laboratory tests.

Given the current security situation in Iraq, Malia has hired military security personnel equipped with firearms to secure their premises. As part of IFC’s investment requirements, Malia will ensure that third party security forces adhere to PS 4, and will establish a community grievance mechanism as part of its SHSE system. These items are included in the ESAP (item #7).

Stakeholder Engagement

The hotel site, on the outskirts of the downtown area, borders Sami Rahman Park between the Erbil Convention Centre and Erbil Exhibition Fair. At the time Malia acquired the site, the Sponsor carried out extensive discussions with municipal authorities, the Ministry of Labor, and Ministry of Local Affairs, local business associations and other interested parties. The purpose of these meetings was to describe the development, obtain all of the permissions needed, and, specifically, to indicate the number of employment opportunities that the project would create during construction and operation. As this will be the first five start hotel in Erbil, it is expected to attract additional investment and development in the city, and has been greeted positively by local authorities, the media and other stakeholders.

Government requirements stipulate that local residents be given priority for hiring during both construction and operation: before any hiring can take place, the company must notify the Ministry of Labor regarding the numbers and qualifications of all positions. Only if the authorities agree that the skills required cannot be found locally is Malia given permission to hire an expatriate. During construction, 95% of the labor requirement has been engaged locally; all workers have received both health and safety and skills training. Malia has already started its staff recruitment efforts in Erbil. Given the lack of a local hospitality training center in the region, Malia is establishing a hospitality training program to begin training those interested in obtaining employment in the hospitality sector, whether in the Sponsor’s facilities or elsewhere. Details on numbers of people receiving training will be provided in the Annual Social and Environmental Reports (AMRs) submitted to IFC

Malia Holding has carried out a number of corporate social responsibility (CSR) activities through establishment of the Jean & Chariotte Sarraf Foundation (JCSF) in 2006 to support and provide funding for programs that address the needs of disadvantaged groups by providing healthcare services and offering opportunities for further education for those in need. JCSF is currently focused on providing programs for Malia Group staff and families as well as to other nongovernmental and charity organization such as the Red Cross; Malia intends to develop similar JCSF-funded CSR programs in Erbil. The Sponsor will provide details on these programs, as well as the number of people impacted, in the AMRs submitted to IFC.

Translated versions of the ESRS and ESAP will be made available at:

In Lebanon:
Malia Holding
Zone Amaret Chalhoub, Sarraf Bldg, Jdeidet-el-Metn, Lebanon
Contact person: Mr. Chakib Chehab
Tel: +961 1 881212
Fax: +961 1 881313
Email: chakibchehab@maliagroup.com

In Iraq:
Malia CTI Ltd.
Address : Gulan Street – Rotana Erbil Hotel site
Contact person: Mr. Ibrahim Fayad
Tel: +964750 4546719
Email: ibrahimfayad@maliaholding.com

Client Documentation

File Name	Actions
Erbil_28566 _Action Plan_Oct 2009.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).

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.

Projects

Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Environmental and Social Mitigation Measures

Stakeholder Engagement

Client Documentation

Similar Projects

Projects

Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Identified Applicable Performance Standards

Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

Environmental and Social Mitigation Measures

Stakeholder Engagement

Stakeholder Engagement

Local Access of Project Documentation

Press-Release

Related SII

Client Documentation

Similar Projects

Information on E&S Complaints and Grievance Mechanisms

Disclaimer