PS1: Social and Environmental Assessment and Management Systems:
Develop and implement an integrated corporate management system (SEMS) for social and environmental affairs, quality, and occupational health and safety management: Grupo Salud will operate following the law and regulations of Peru, including local municipal regulations. As per the Environmental and Social Action Plan (ESAP), Grupo Salud will develop a management system encompassing social, occupational health and safety, human resources, and environmental affairs management for all its operations. The SEMS (Social and Environmental Management System) shall comply with Peruvian regulations and IFC Performance Standard 1, and WBG Environmental Health and Safety General Guidelines (WBG EHS General Guidelines). The SEMS will also specify operating policy requirements as well as basic procedures that must be in place for quality control and compliance during construction and operational phases (during construction, the SEMS will address occupational health and safety of the workers; life and fire safety master plan design and certification; community engagement procedures to address impacts resulting from traffic, dust, and noise from construction equipment; generation of waste; chance finds procedure; and quality safety assurance during construction of the oncology facilities). During the operational phase, the SEMS will encompass procedures for labor relations, including implementation of good hospital management practices, employee health and safety and radiation exposure monitoring; life and fire safety implementation, emergency contingency plan; food safety and hygiene; water conservation management procedure, pretreatment, adequate emergency level of potable water; hazardous and non-hazardous waste management including disposal of radioactive waste as per Peruvian Regulation and International Atomic Energy Agency international Standards; establish procedure to ensure efficient energy and water use; community engagement and handling of grievances; pest and rodent management system.
Prepare Environmental and Social Impact Assessment (ESIA): Following PS1 guidance note, Grupo Salud will present to IFC for review and approval the environmental and social impact assessment (ESIA) and the environmental and social Management Plan for the construction and operational phase. It will include all applicable WBG General EHS guidelines and IFC performance standards.
Establish Standalone Environmental and Social Management Unit: Grupo Salud agrees to appoint a corporate social and environmental resource-person with managerial responsibilities for environmental and social issues. This person will report to Grupo Salud’s senior management.
Training: As part of their staff capacity building at induction of new employees, Grupo Salud will prepare and institutionalize a management system procedure addressing a training programme for all employees and contractors to ensure knowledge on Environmental and Social issues, including community grievance procedures.
Community Engagement: Consistent with the requirement of Performance Standard 1, Grupo Salud will develop a corporate formal management system procedure for community engagement and grievance mechanism, and will ensure it is clearly communicated by posting on Grupo Salud’s website and included in relevant written public communications at the facilities.
Quality Safety Assurance during Construction of Oncology Facilities: Grupo Salud will provide a detailed plan to IFC for approval, to develop and implement a management system procedure (consistent with international standards for the safety of radiation sources) for the construction phase. The procedure shall specify operating policy requirements for the system as well as basic procedures that must be in place for quality control and compliance during construction as well as during the operation of the oncology facilities. Will give particular consideration to avoid potential exposure to natural hazards, especially where the structural elements are accessible to members of the affected community or where their failure could result in injury to construction workers or the community. The management system will include stipulations for monitoring of environmental, social, health and safety of radiation sources, and for reporting back to IFC. It will also include comprehensive yearly evaluations to verify whether the project expectations have been met, and determine corrective measures that Grupo Salud will apply. The Company will retain a radiation protection scientific/technical expertise, satisfactory to IFC, preferably from the Peruvian Institute of Nuclear Energy (IPEN), to supervise the construction of the oncology facilities.
Senior Management Reporting and Monitoring: The Client will implement a process for monitoring and periodic reporting to senior management and monitoring activities that have been identified to have potentially significant impacts on social issues and the environment, during normal operations and upset conditions.
As a whole, the SEMS will provide adequate assurance of Grupo Saluds’s ability to manage all aspects of operations and the means to communicate management-approved decisions to employees.
PS2: Labor and Working Conditions: Grupo Salud will operate within the Peruvian labour law and IFC Performance Standard 2, to maintain and promote fair treatment and safe and healthy working conditions to employees.
Human Resources (HR) Procedures: Grupo Salud will present to IFC for review and approval the HR policy and associated procedures to comply with the Peruvian law, and incorporate all the requirements described in IFC Performance Standard 2. The policy will indicate that subcontracted employees will be required to comply with all Grupo Salud HR policy procedures and policies applied to permanent employees. The HR policy will include references to non-discrimination, freedom of association and collective bargaining, child labor and forced labor.
Grievance Mechanism: Grupo Salud will present to IFC for review and approval, a grievance policy for employees, to include steps to be taken, mediation process, responsible persons, publicize the procedure, response time, record keeping, and how feedback will be given.
Occupational Health and Safety: The Client will present to IFC for review and approval satisfactory evidence that a management systems procedure has been implemented to manage health and safety hazards, including employee training of safety awareness and in house capability for job hazard analyses during the construction and operational phase of the hospital, to comply with the WBG General EHS Guidelines and corresponding personal protection equipment. The procedure will provide protocols for nosocomial or hospital-acquired infection to prevent healthcare-associated infection for the staff, patients and visitors. Employees assigned to critical areas including intensive care, operating theatres, dialysis, etc. as well as in nutrition and food services will participate in epidemiological surveillance for specifically notifiable diseases. In addition, Grupo Salud will provide specialized training and appropriate personal protective equipment (PPE) for employees handling infected clothing, linens and hazardous health care waste.
Radioactive Protection and Monitoring: Grupo Salud will develop and implement a management system for monitoring radiation levels exposure of personnel during the operational phase. The procedure will be presented to IFC for review and approval.
Emergency Contingency Plan: Comprehensive emergency and disaster plans will be developed by Grupo Salud. The Client will develop and implement a management system procedure including a training plan to ensure that employees are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes. The emergency procedures will be communicated to the surrounding community by direct communications and by posting on Grupo Salud’s website.
Implementing food safety and hygiene monitoring: Grupo Salud will develop and implement a management system procedure for food safety and hygiene monitoring during the operational phase, satisfactory to IFC.
Life and Fire Safety System Design: Grupo Salud will develop and implement a management system procedure and Master Plan for Life and Fire Safety identifying major fire risks, applicable codes, standards and regulations, fire drills, and mitigation measures. The Master Plan must also be responsive to the elements described in the WBG General EHS Guideline (e.g. Fire Prevention, Means of Egress, Detection and Alarm Systems, Compartmentation, Fire Suppression and Control, and Emergency Response Planning. The procedure shall be presented to IFC for review and approval. Grupo Salud has agreed to engage professional services of a qualified Life and Fire Safety Engineer acceptable to IFC to prepare Master Plan (engineering design) and post construction inspections to verify that the system was installed as designed. Life and fire safety design shall be responsive to one international life safety code, and the Peruvian life safety code. The design shall comply with the Life and fire Safety requirements of the WBG General EHS Guideline. The Client will provide third party certification by a qualified professional acceptable to IFC, that the design and construction of life and fire safety systems for the Hospital complies with the specifics of IFC life and fire safety guidelines.
PS3: Pollution Prevention and Abatement: Grupo Salud plans to operate within the Peruvian environmental regulatory framework and IFC Performance Standard and WBG General EHS Guidelines. Potable water will be provided by the national water system (SEDAPAL) and Grupo Salud will perform further treatment to ensure the potability of water for hospital operations and critical applications. Daily water requirements have been estimated as 164 cubic metres. The Clinica Delgado will discharge sanitary wastewater (estimated in 131 M3 per day) to public sewerage under permit that municipal government-owned treatment works will treat and disinfect. The Client will comply with all effluent pre-treatments required by the municipal and national requirements. Electric power will be provided from the Peruvian grid. Engine-driven generators will provide standby electric power and these will be isolated adequately to prevent local noise impacts.
Waste Management: The Clinica Delgado will segregate wastes from hospital operations into one of the following classifications: municipal solid waste, dangerous biological or infectious waste, and hazardous waste. Grupo Salud will develop a health care waste management system procedure, to manage and monitor both hazardous and non-hazardous waste streams, and secondary containment in case of spills, that will meet the more stringent of national laws and regulations and IFC’s Performance Standard requirements, including those of the WBG General EHS Guidelines. The Client will present a plan for IFC’s approval to dispose all solid waste in an environmentally sound manner, including the waste segregation strategy, pre-treatment and monitoring of waste.
Radioactive Waste: Grupo Salud will develop a management system procedure to ensure that the activity and volume of any radioactive waste that results from the sources for which they are responsible be kept to the minimum practicable, and dispose of in accordance and in agreement with the Peruvian national regulatory authority (IPEN) and following the International Atomic Energy Agency international Standards for safety use of radiation sources. The Company will ensure that the waste managed will be segregated if appropriate by differences in factors such as radionuclide content, half-life, concentration, volume and physical and chemical properties, taking into account the available options for waste disposal. The procedure will ensure that radioactive substances are not discharged to the environment, unless it is within limits of the national and international standards.
Provide Emergency Power Generation Design Certification: Grupo Salud will design enclosure and noise dampening facilities for emergency power generation adequate to comply with Peruvian and applicable WBG EHS guideline limits.
Energy management: Grupo Salud will develop a management system procedure to ensure efficient energy use.
Sustainable water resource use: Grupo Salud will develop a water conservation management procedure that shall focus on reducing water use. The plan shall be captured in management system procedures addressing enhancement of water resource management sustainability and include modern innovations. Grupo Salud will provide IFC with detailed plan components, implementing management system procedures, and proposed activities schedule.
Water pretreatment: Grupo Salud will implement a water treatment facility to ensure that characteristics of the water entering the hospital water supply, from the national water distribution system and from emergency vehicle pipes, are in compliance with all international standards of WHO for potable water, and equipment operational requirements. The management system will include a potable water quality monitoring and reporting to IFC procedure.
Emergency Water: Grupo Salud will provide to IFC satisfactory documentary evidence that an adequate level of potable water, based on Client estimates, will be available as emergency during water shortages.
Design and implement pest and rodent management system procedure in accordance with Performance Standard 3: Grupo Salud will prepare a management system procedure to implement pest and rodent management during the operational phase: The procedure will aim to eliminate the use of WHO Class 1a and 1b chemical formulations in their premises. The Company will modify service contracts to require contractors and suppliers to provide training to workers and adequate PPE based upon MSDS and/or ICSCs for the chemical formulations used.
PS4: Community Health, Safety and Security: Clinica Delgado will operate a waste management programme, employee training and internal disease prevention programs that aid in protection of communities and maintain safety of patients. During construction, dust generated from vehicle movements and excavation activities, as well as exhaust from vehicles and engines can impact on air quality and be a nuisance to other road users and neighbouring communities to the site and access road. Grupo Salud will prepare management system procedure addressing community engagement including a mechanism for receiving, addressing and resolving community grievances and complaints. Procedure content shall be guided by IFC Stakeholder Engagement Good Practice Manual.
5.0 PS8: Cultural Heritage: The land where Clinica Delgado will be built is located 30 metres from the Huaca Pucllana, regarded as a cultural heritage site of Peru. Following an archeological investigation at the construction site, on April 26, 2010, the Peruvian Institute of Culture (Instituto Nacional de Cultura of Peru-INC), has granted the project a “Certificate of non existence of Archeological Artifacts (CIRA). The certificate has a restriction for final approval of the CIRA, that calls for monitoring and surveyance of archeological artifacts or architecture by a certified archeologist. This, at the onset of excavation and construction works. The Client is required to present to INC, prior to construction, a monitoring plan during construction works, developed by a certified archeologist. Final analysis and report will be endorsed by INC, as required.
Grupo Salud will prepare and implement a management system Chance Finds procedure. The procedure will be implemented in full compliance with INC requirements and as described in IFC’s Performance Standard 8.
The Client will recruit an archeologist, registered both at the Colegio de Arqueólogos del Peru, and at the Registro Nacional de Arqueólogos of the Instituto Nacional de Cultura of Peru (INC), and acceptable to IFC, to conduct the chance finds procedure during the excavation phase. At the end of the Chance Finds study assessment, Grupo Salud will present to IFC the report duly approved and endorsed by Peru’s INC.
