Social and Environmental Assessment and Management Systems (PS1)
CGC in Kuwait has obtained an International Quality Management System Certificate of ISO 9001:2000 for its public transportation operations and its commitment to adhere to the required technical specifications based on international standards.
The Managing Director of CGC is primarily responsible for the management of compliance with environmental, health and safety (EHS) and social requirements for existing and proposed project operations. Department Heads, primarily the Operations Director, Engineering Director and Human Resources (HR) Director are responsible for their area of operations to ensure that EHS and social issues are managed in accordance with the CGC’s management system under the guidance of the Managing Director. Resources required to manage EHS and social issues are identified and discussed by senior management on an ongoing basis. Individual department heads identify training needs and communicate these to the HR Department for consideration and incorporation into the annual training plan. EHS performance is monitored through regular safety audits and audit recommendations from internal auditors, as well as by regular ISO audits and regulatory inspections carried out by third parties.
As a result of both internal and external assessments, a number of areas of improvement have been identified and CGC is in the process of upgrading its operations in Kuwait. Priorities include gradual renewal of fleets, construction of new maintenance facilities, upgrading fuel and other hazardous materials storage and handling areas, and life and fire safety installations. An effective preventive maintenance system, which is expected to contribute to improvements in occupational and public safety, operational efficiency, pollution control and resource conservation has been recently introduced and will be extended to all locations of operations.
CGC will provide IFC with the details of the investment program for ongoing upgrading of the facilities in Kuwait, will regularly report on the progress status and will ensure that the upgraded facilities comply with local, and where feasible, international standards as well as with IFC’s requirements.
Significant need for upgrades has also been identified at Amman City in Jordan. In addition to renewal of the fleets, a new facility for fleet maintenance, fuel storage and transfer facility will be constructed in accordance with local and, where feasible, with international standards. At the time of IFC’s field appraisal, CGC and CMTC were processing the leasing of 13 hectares (ha) of land to be used for this purpose.
CGC is planning to formalize the assessment and management process through establishment of an agreed, documented procedure for social and environmental impact assessment (SEIA) to be systematically conducted by agreed qualified professionals, both for its proposed expansion projects as well as for lands and/or facilities to be closed down. Accordingly, EHS and social management programs will be developed prior to any construction, rehabilitation, closure or transition in accordance with local, and, where feasible, international standards as well as IFC’s requirements within a time frame to be agreed. This will first apply to the operations in Jordan.
In addition to other performance standards identified, cultural heritage will be part of the environmental impact assessment process prior to commencement of any construction activities. This will primarily apply to developments in Jordan. Even if no presence of cultural heritage is identified during the assessment process, CGC will develop a ‘chance find” procedure to be included in the construction contracts in order to protect cultural heritage which can be encountered during excavation activities.
CGC has recently acquired 175 buses for the dual purpose of upgrading the current fleet and supporting ongoing local and regional expansion efforts. CGC currently operates a fleet of 585 buses operating on 21 lines in Kuwait City. In Jordan, CMTC and its subsidiaries currently own 464 buses and transports approximately 65,000 passengers per day, operating approximately 65 public transport lines in and out of the Jordanian capital, Amman. The average age of the fleet is 6 to 8 years. A portion of the proposed investment will finance replacement and upgrading of CMTC’s fleet of buses. The new fleet is expected to improve operating and environmental efficiency and services offered by CMTC.
As part of its management systems, CGC is planning to formalize a documented Purchasing procedure so that, where feasible, safety and environmental considerations are taken into account in future purchases of technical equipment, material and vehicles.
In addition to ISO 9001, CGC is considering the implementation of EHS Management Systems that comply with ISO 14001 and OHSAS 18001, to obtain certification at each country and location of operation within a timeframe. CGC has recently strengthened its management team to ensure efficient execution of EHS and operational improvements. The Company is also planning to further review its organizational structure to establish a formal corporate EHS and social sustainability function and define responsibilities at the corporate level in order. Doing so will ensure that resources are adequately provided and responsibilities assigned for effective implementation of the consistent EHS and social management programs in all countries of operations.
Labor and Working Conditions (PS 2) / Community Health, Safety and Security (PS4)
Labor Relations / Human Resources Policy and Practices
Currently, CGC has approximately 1,425 employees and CMTC, with its sub-companies, has 650 employees. The percentage of drivers employed among the total workforce is 80% and 60% respectively. CGC employees in Kuwait include a large percentage of non-Kuwaiti nationals, whereas Jordanian regulations require that drivers for local public buses must be Jordanian citizen
Most of the core ILO Conventions have been ratified by both countries, with the exception of Convention 100 on equal remuneration in Kuwait, and Convention 87 on freedom of association in Jordan, although Convention 98 on the right to organize and collective bargaining is effective in Jordan.
There is no issue related to forced labor and child and the minimum age of employment is 18 for both CGC and CMTC.
In Kuwait, the employees are not unionized and working conditions are set up on an individual contract basis. In Jordan, a collective agreement is made with the drivers union where CMTC reported that the membership to the union is encouraged by the company.
At both CGC and CMTC, Human Resources (HR) procedures are in place to cover key aspects of working conditions, terms of employment and grievance mechanisms.
Subject to financial considerations and local labor laws, CGC and CMTC will endeavor to avoid or minimize retrenchment and will introduce a documented procedure to appropriately conduct unavoidable retrenchment activities. In the case of unavoidable retrenchment, the employer will strive to create job opportunities in different areas/sectors, wherever possible, for affected employees.
CGC regularly utilizes contracted workforce particularly for security, cleaning services, and during construction activities. CGC and CMTC will develop documented contractor supervision and inspection mechanisms to oversee contractor labor issues related to timely payment to employees, working hours, social security/insurance coverage, provision of protective equipment and implementation of other health and safety rules in all countries of operations.
CGC will also review its current HR policies and procedures to formally establish a corporate HR policy and procedures for both its direct and indirect workforce, in line with IFC’s Performance Standard 2. These will be revised where needed, taking into account, where feasible, all core ILO Conventions. The Company will also systematically assess labor conditions at each country of operation to minimize gaps between labor practices and continuously improve working conditions.
Occupational Health and Safety / Community Health, Safety and Security
CGC and CMTC reported that experienced drivers are employed at all operations and comprehensive health and safety trainings are held as part of the induction program. The drivers at CGC attend a 33 to 47 day training period in which they are provided both classroom and practical training. CMTC is sponsoring a driver academy in Jordan to improve driver qualifications and skills. In addition to safety trainings, language courses are offered to the foreign workforce at CGC. Furthermore, the Company is planning to incorporate first aid and emergency response courses into the training programs. The existing workforce will be regularly provided with ‘refresher’ trainings at regular intervals as needed.
In order to ensure further driving safety, route inspections are systematically conducted by in-house auditors both at CGC and CMTC. Safety records are among the Key Performance Indicators for drivers.
In accordance with national labor laws, normal working hours are 48 per week based on a 6-day working schedule with permissible overtime of up to 2 hours per day. TWG and CMTC are planning to review working hour’s policies and practices including maximum allowable overtime working and comfort breaks in line with local, and where feasible, internationally agreed standards and good practices.
Employee medical examinations are currently required at the time of hiring. The Company will establish an appropriate regular check-up program for the existing workforce within a defined timeframe. CGC will ensure that all employees are covered with medical insurance in all countries of operations.
CGC provides accommodation for its foreign workforce, which is drawn primarily from India, Egypt, Bangladesh and Sri Lanka. IFC observed that the conditions were, in general, adequate; however, space dimensions provided per employee need to be reviewed. The Company reported that the accommodation facilities were regularly audited by the local authorities and the Company will continue to ensure that it remains compliant with all applicable regulations and international good practices. CGC will review provision of space per employee and make enlargement as necessary within a defined timeframe.
As noted, workplace safety for the maintenance workforce is being upgraded, as part of the new facilities that are either construction or planned. In Kuwait, CGC has introduced strong preventive maintenance programs adopted from systems commonly used in the UK, and these will be extended to the operations in Jordan and other countries of operations in the future.
CGC conducts detailed accident investigation and records are kept particularly for the purpose of insurance related activities. The Company will adopt a system similar to the one used by CMTC in order to enable tracking of lost time incidents and injury rates, in addition to material damage track records.
In each country of operation, CGC will ensure that life and fire safety design, equipment and signage are incorporated in all of its maintenance and other facilities, warehouses, battery charging areas, fuel charging/discharging areas, administrative buildings and employee housing as needed in line with local and internationally agreed standards. Robust preventive maintenance programs will be established and executed as referenced above. The Company is also planning to review emergency management programs in line with best practices, where feasible.
All of CGC’s operating vehicles are already equipped with air conditioning systems. Where feasible, CGC will ensure that its new fleet meets EU noise standards and is accessible for people with disabilities, through the provision of, for example, single step access and retractable ramps on buses serving network operations. ABS systems will be part of safety features of newly acquired buses.
Pollution Prevention and Abatement (PS3)
Resource Efficiency, Control of Greenhouse Gas Emissions and Pollution Prevention:
In 2009, CGC and CMTC used about 25 million and 8 million liters of diesel fuel respectively, which translates to estimated emissions of 90,610 tons of carbon dioxide (CO2) equivalent.
The new buses being acquired at CMTC in Jordan are expected to have better fuel efficiency. In Kuwait, in addition to replacement of old buses with new ones with better fuel efficiency, CGC is in the process of introducing technical control measures such as leakage prevention devices, fixed speed limits and new pumping systems using to optimize fuel and oil consumption. These measures will be extended to operations in other countries where feasible. Oil and water separation systems are under development for pollution control and to increase resource efficiency. The Company will develop water conservation programs and, as part of its annual reporting to IFC, will report on overall resource conservation programs as well as benefits to control greenhouse gas emissions.
Diesel currently used in vehicles in the Middle East has a high sulfur content, which makes it difficult to meet air emissions standards consistent with good international practices. Countries like Jordan are aiming to harmonize their fuel and emissions regulations with those of the EU and are developing refineries that will produce fuel of superior quality. Exhaust emissions from CMTC buses in operation currently exceed regulatory limits. CGC will establish regular air emissions monitoring program for all its vehicles and develop a roadmap to gradually reduce air emissions from its operations and to become fully compliant at each country of operation, within a timeframe to be agreed with IFC.
The minimum utilization period of current vehicles will be defined and, where feasible, the Company will ensure that all new vehicles acquired with IFC funds will be equipped with required NOx, CO, hydrocarbons and particulate matter control devices to meet host country regulatory limits.
Where feasible, the use of alternative fuels such as biodiesel, or of hybrid and/or full electric vehicles, will be taken into account in the longer term as part of the Company’s continuous improvement principles.
Point source emissions from combustion heating systems serving the technical and administrative facilities will be monitored as necessary in accordance with local regulations and, where feasible, international requirements.
Hazardous Materials and Waste Management
CGC has an ongoing program to reduce hazardous chemicals used in all of its operations. For example, air conditioning systems in all new buses use R-134a which is an allowable (non-ozone depleting) refrigerant under the Montreal Protocol. In addition, through the use of higher quality diesel engine oil, oil consumption has been reduced by 50%. CGC will continue to review all maintenance chemicals and other hazardous substances used in its operations with an eye towards replacing such materials with non-hazardous substitutes or - if this is not possible - with less hazardous alternatives wherever feasible.
Comprehensive spill prevention programs need to be established at both CGC and CMTC facilities. Ongoing renovation at CGC facilities in Kuwait will properly address this issue with appropriately bounded aboveground fuel and oil storage tanks, appropriate fuel charging and discharging areas, oil recovery systems, and pavement of these areas. At CMTC facilities, immediate action will be taken, where feasible to minimize spills and leaks to be effective until new facilities come into operation. Appropriate environmental due diligence will be conducted at the time of closure of current facilities, prior to any transition to third parties or usage for other purposes.
CGC will formalize a procedure to inventory the presence of hazardous materials such as asbestos, PCBs and CFCs - which are most likely present in old buildings and obsolete equipments. the results of the inventory will be used to develop a systematic plan for the safe removal and disposal of these materials by qualified professionals before any construction, refurbishment or reuse activities.
Oil and water separation systems will be installed and used oil will be recovered for reuse. Obsolete batteries will be considered as hazardous waste and disposed of in a safe manner.
Other Wastes and Effluents
All non-hazardous recyclable wastes are separately collected and sold in both countries. In Kuwait, wastewater from technical and administrative facilities are collected in septic tanks and collected daily by a certified body. This practice will continue until drainage systems are constructed. To the extent feasible, the Company will adopt appropriate waste and effluent management as a standard practice in current operations and future expansion projects.
