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;
PS2: Labor and Working Conditions;
PS3: Pollution Prevention and Abatement; 
PS4: Community Health, Safety and Security;
PS5: Land Acquisition and Involuntary Resettlement.Malls are built in urban areas, close to underserved retail markets and typically on brownfield sites and these very locations makes issues related to other Performance Standards unlikely.

The key environmental and social (E&S) issues for this multi-site property development and operation transaction relate to Persianas’ assessment of potential adverse environmental and social impacts ahead of site acquisition, development of appropriate plans to mitigate such impacts in construction and operation. Future issues of concern are the manner of land acquisition, so as to minimize or mitigate possible economic or physical displacement; engagement with communities adjacent to mall sites, if any; environmental issues such as noise, dust and erosion control during construction; safety in construction; and in the operational phases, provision of safe and fair working conditions, occupational health and safety, energy efficiency and management of greenhouse gas emissions arising from energy use and release of refrigerants, solid waste management, and life and fire safety.

These issues may all be readily mitigated and are relatively minor and reversible. This is therefore an environmental and social Category B project.

The company has presented plans to address the environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with local laws and regulations, IFC’s Performance Standards on Social and Environmental Sustainability and IFC’s applicable Environmental, Health and Safety Guidelines. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow.

PS1: Social and Environmental Assessment and Management System

Social and Environmental Assessment and Management Systems

Social and Environmental Assessment

Environmental Impact Assessments (EIAs) following the legal requirements of the national and local authority are prepared for each proposed mall development. Persianas secures all the relevant building permits, before construction. While the EIAs reviewed give a basic understanding of the projects, they do not always review all issues anticipated by the Performance Standards. Persianas will develop a standard Terms of Reference for future project assessments that shall include reference to the Performance Standards, and therefore social as well as environmental aspects of possible adverse project impacts.

Notwithstanding the above, malls are designed and constructed to a high standard, generally being responsive to British and/or South African standards as well as all relevant local codes, by professional architects and designers with considerable sector experience.

Social and Environmental Management
Persianas’ social and environmental management efforts to date have been undertaken on a development-by-development basis, and there is now a need to develop a more systematic approach reflective of the increasing scale and ambition of the Group.

The Group will develop a social and environmental policy statement covering its future business activities and committing that these will be developed and operated in a manner compliant with the Performance Standards.

Project-level environmental and social management has been contractually assigned as the responsibility of the main contractor, and the same main contractor has been used for both the Enugu and Ilorin projects. Persianas’ E&S oversight has been one of the responsibilities of the Group’s construction and projects manager. This management structure will be enhanced and formalized. A Group Environmental and Social (including safety) officer will be appointed, with the objective to provide more active supervision of E&S matters during construction. The officer’s tasks will include development of corporate specifications to be used in future invitations to tender for construction work, and enforcement of these through oversight of site-based construction through appointment of a full-time E&S supervisor at each construction site. Group guidelines on minimum standards to be required in buildings to be developed will also be developed.

A Persianas Construction and Environmental Management Plan was prepared to guide construction of the Enugu mall. Among other things, this Plan defines the responsibilities of the Project Manager, Environmental Management Representative and the Site Contractor Project Manager. And includes plans for management of noise and vibration, air quality, soil and water quality, solid waste, hazardous materials, (within site) transport, health and safety, and emergency situations. In support of the health and safety aspects of this Plan, the main contractor prepared a safety management manual which on paper was broadly satisfactory, but was not closely followed on the construction sites. The Group E&S Officer will undertake a risk assessment of ongoing and readily forseeable construction activities and will develop safe working guidance for these and other relevant issues within the corporate specifications referred to above.

At the present time, mall operation is contracted to a well known South African company active in this area in Nigeria. This management company has developed and implements appropriate procedures for E&S management of the mall sites, such as maintenance of fire safety systems and solid waste management and reports on these regularly to the Group.

Training
Future contracts will require contractors to train their employees in the key requirements of the Group’s environmental and safety specifications as they relate to each employee’s place of work. Contractors will be asked to address and cost for methods for safety in construction in their tenders, and to enforce these during the construction program.


PS2: Labor and Working Conditions
Worker Relationships
In its current state of development, Persianas is essentially a start-up, with few employees, and few formal human resources policies or procedures.

The Group will develop a formal human resources policy, and a suite of operational procedures whose observance will, at a minimum, bring about the Group’s compliance with Performance Standard 2.

In addition to these basic policy requirements the Group will also formalize definitions of job descriptions and competencies, which will include “seasoned professional”, “professional” and “junior” levels.

Persianas will add a contractual requirement to future construction contracts that the main contractor, and through the main contractor the project subcontractors apply performance standard requirements to their own employee relationships.

Occupational Health and Safety (OHS)
Occupational Health and Safety will be promoted through Persianas’ inclusion of the matter at the invitation to tender stage, as an issue requiring attention, through contractors’ compliance with Persianas’ specifications relating to OHS precautions to be observed during certain high risk construction activities and by Persianas’ supervision of these matters during construction.

PS3: Pollution Prevention and Abatement
Liquid effluents
Sanitary waste water and process effluent arising from store operations is collected and directed to small on-site waste water treatment facilities before discharge.

Air Emissions
Air emissions arise as exhaust from diesel generators used as (frequently operating) standby machines at all malls. The Groups does not currently have air emissions data for these engines; emissions will be monitored and reported to IFC. Future generators will be specified to be compliant with World Bank Group (WBG) General Environmental Health and Safety Guidelines emissions guideline values.

Energy Efficiency and Greenhouse Gas Emissions
Mall designs to date have not been prepared with great emphasis on energy efficiency. The majority of the electricity consumption in the malls’ common areas is accounted for by common-area air conditioning, which is provided by roof-mounted air handling units and by lighting which is typically based upon fluorescent luminaries. Electricity for the malls is provided by the national electricity system, though standby generators are provided to ensure continuity of supply in the event of power cuts.

For future malls, Persianas will explore additional energy efficiency opportunities. Certain of these may be universally applicable, for example heat recovery for absorption cooling from generators, or use of solar energy, while others, such as shading of south-facing glazing may be sight specific.

In all malls currently operational or planned, Shoprite is an “anchor tenant” and supplies its own air conditioning and food retail refrigeration systems as well as its own electrical distribution and generation systems that are not connected to the main mall systems.

The greenhouse gas footprint of The Palms mall, plus the three malls currently planned or under construction is estimated at 20,000 tonnes per annum CO2 equivalent.

Solid Waste Management
Solid waste is gathered in service areas at each mall, compacted, and removed by authorized contractors.

PS4: Community Health, Safety and Security

Life and Fire Safety
Malls are compliant with all applicable local regulations. In addition, mall design follows British or South African fire safety design standards. Malls feature sprinklers and smoke detectors throughout, in the fully enclosed malls, there are adequate emergency exits while one of the properties will be a strip-mall design with ready egress from stores, and with additional exits at the rear of the large stores. Persianas will provide a formal statement from a fire safety professional confirming that the malls do meet as applicable the British or South African fire safety codes, as stated above.

Water Quality
Water for the properties is sourced either from the municipal water company or from the property’s own boreholes. Borehole water is filtered and dosed with disinfectant before distribution to the mall. One tenant monitors water quality, which is of potable standard, and Persianas has relied upon this monitoring for its own purposes. Persianas will institute its own potable water quality monitoring.

Security
Physical security of the properties is provided by private security companies, with the highly respected Mobile Police (“MoPol”) service providing security patrols outside the premises, especially at night.


PS5: Land Acquisition and Involuntary Resettlement
Land Acquisition and Involuntary Resettlement
Construction of the Ibadan mall, and in particular the access road to the mall, which shall run for a short distance parallel to the existing road, will cause displacement of a small number of informal businesses that have been established in this area, including a vehicle repair facility (sets of ramps were observed), very small scale brick-making businesses and some snack bars / soft drinks vendors. While it is likely that these businesses can be relocated a small distance from their existing locations, and all are likely to benefit from the mall construction and later its operation, construction of the road will cause loss of the physical assets developed.

Persianas has surveyed these businesses and is preparing a Resettlement Action Plan (RAPs) which lists assets to be displaced by the mall, persons to be compensated and monetary sums involved, in compliance with Performance Standard 5 objectives.

The Group will prepare similar RAPs when future site acquisition may cause economic or physical displacement of businesses or residential accommodation.

It has been Persianas’ experience during its construction projects to date that mall plans are well known to local communities, and a community representative emerges and takes an active and constructive role in liaison between the construction project and the local community. These persons, for example, have a helpful role in communicating the projects’ need for local labor, as construction progress demands.

Once operational, the malls by their very nature as the focus of retail, food service and recreation (cinemas) to the local communities, means that the malls have ongoing programs of communication with these communities.

This informal system of community engagement will be enhanced to provide a formal grievance mechanism.

This summary will be made available for public review at the following locations:

Polo Park Mall: Polo Ground, Abakaliki Road, Old G R A, Enugu North, Enugu State
The Palms Mall: The Palms Shopping Mall off The British International School Way, off Lekki-Expressway, Maroko, Victoria Island, Lagos State
Ibadan Mall: along M.K.C. Aboila Road, Ibadan in Ibadan South West Locate Government Area, of Oyo State
Kwara Mall: Plot 1, Fate Road, Ilorin, Government Area of Kwara State

For further information about the project please contact:

Mr. Adetayo Amusan
Persianas Investment Limited
Plot 999A, Danmole Street,
Victoria Island, Lagos,
Nigeria.
Telephone: +234 1 741 9100