The key environmental and social (E&S) issues have been identified as: (i) Triada’s ability to provide systematic and consistent management of E&S issues across different projects including the adoption of necessary mitigation measures; (ii) assessment processes applied to the land acquisition process, to ensure avoidance of adverse impacts on cultural heritage, biodiversity when these are encountered in developments; (iii) the avoidance of involuntary resettlement; (iv) management of occupational health and safety risks during construction, and (v) ensuring adequate services and utilities (electricity, safe water and sanitary facilities) associated with project development.
Triada has presented information on how its current practices and policies address the identified impacts and how it will ensure that the proposed project upon implementation of the specific agreed measures, comply with the environmental and social requirements, which include the Colombian laws and regulations and IFC’s Performance Standards. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment: Triada considers environmental and social issues, such as proximity to water bodies, past use and environmental legacy of the land, and risks of landslides and flooding during the land assessment and acquisition process. However; the company does not have a formal environmental and social due diligence procedure integrated into the assessment process. Triada will formalize an Environmental and Social (E&S) review procedure to identify the potential E&S risks during land acquisition, their management and necessary mitigation measures. The review should include: (i) site-specific environmental issues affecting potential development of the site; (ii) potential economic and physical displacement associated with land acquisition; (iii) site-specific biodiversity assessment (if applicable), and (iv) potential discovery of cultural property.
Specific E&S requirements are identified based on local legislation; for example, projects developed in Bogota follows the recommendations provided in the Environmental Guideline for the Construction Sector from the city’s environmental authority (Secretaria Distrital de Ambiente –SDA), while those projects in Cali follows recommendations provided by DAGMA (Departamento Administrativo de Gestion de Medio Ambiente-Cali). Triada commissions (as needed) and implements the environmental and social programs for new projects; which are based on the identification of potential impacts and risks. The company is in the process of identifying and implementing best practice across different projects to apply these procedures consistently throughout all projects.
Environmental and Social management Systems: Triada has a certified and functional quality management system and is implementing an Occupational Health and Safety (OHS) management system, which is well advance in terms of documented procedures. Triada has a newly developed and well conceived Human Resources program addressing key labor issues. Environmental elements are managed according to local legal requirements as described in the previous section. Triada will develop a formal Environmental and Social Management System (ESMS) at corporate level that include policies, objectives and mitigation measures to manage Environmental and Social (E&S) impacts of the projects including, but not limited to land acquisition and involuntary resettlement; solid waste management; effluent management; occupational health and safety; management of contractors; working conditions; community engagement; biodiversity and natural resource conservation, and; cultural heritage. As part of the implementation, Triada will provide training to employees and develop management programs, procedures, monitoring and reporting protocols.
Management of Contractors: Triada has a well established database of existing and potential contractors who are assessed on quality and safety performance. Contractors are required to adhere to the company’s policies and national law; such requirements are explicitly addressed in the contracts. The company will expand the current conditions in the contracts to cover environmental issues and new requirements derived from the implementation of the ESMS.
Organizational Capacity: Human Resources (HR) at Triada are managed by the administrative and financial coordinator with the support of an external specialized HR consulting company that appoints a permanent professional to Triada. Land acquisition is reviewed by a project manager and approved by the management of the company. Triada does not have a corporate-level function dedicated to address environmental and social issues; those elements are currently addressed by the quality coordinator and by the project manager at each development. As needed the company contracts third party specialized companies to perform environmental studies. Occupational Health and Safety aspects are managed by a safety coordinator who oversees safety inspectors at each project. In addition to safeguard OHS elements in the projects, the safety inspectors have some responsibility for basic environmental management oversight at project level. As part of the implementation of the ESMS, Triada will create an Environmental and Social (E&S) coordination function at the corporate level. The E&S coordinator will ensure compliance on E&S issues for existing and new projects.
Training: Triada defines annually a training program derived from the identified needs, employees’ performance assessment and new projects. Training programs cover quality, environmental and safety elements. An induction program is available for all employees and the company keeps records of the training provided. Triada will reinforce the training provided to employees on OHS elements for high risk tasks (such as assembling and operating tower cranes) and on solid waste management at construction sites. Triada will implement processes to properly manage training and qualifications records throughout the company and ensure that only qualified operators have access to the cranes and can perform high risk tasks. Triada is participating in a pilot program with the Clinton Foundation, the Colombian construction chamber (CAMACOL) and the national technical training institution (SENA) to providing onsite technical and safety training to construction workers aiming to certify them.
Monitoring and Reporting: Project management at construction sites involves various types of monitoring and reporting including assessments of contractor performance, assessment of safety conditions, accident statistics, training and management of construction debris. The monitoring reports are well recorded and made available to Triada’s management through the quality management system.
Land Acquisition: Triada acquires land through different mechanisms (i) commercial transactions directly with the land owners on a willing buyer-willing seller basis, (ii) through partnerships with other developers where the land has been acquired from the government (usually the case of with very large projects), or (iii) through formal contracts where the land owner becomes an associate in the proposed development. Land acquired by Triada up to now has been all in urban settings with no associated economic or physical displacement, or impacts to areas with high biodiversity value, including protected areas. Triada has an informal policy of not acquiring lands with informal occupation, e.g. squatters. Triada will include in the existing protocol for land assessment an evaluation of potential environmental and social issues including: potential economic and physical displacement associated with all land acquisition, legacy issues, potential cultural heritage findings, and biodiversity and natural resource management issues, among others; where such impacts occur the assessment will require the development of appropriate management plans. IFC proceeds are not expected to be used in renovation projects where there is involuntary resettlement. Triada will not participate in projects that have caused involuntary resettlement, unless resettlement and income restoration are managed in a manner compliant with IFC’s Performance Standard 5.
Cultural Heritage: Triada is not expected to encounter cultural heritage as it operates in the urban and peri-urban land, in addition environmental legal requirements oblige the reporting of any potential findings. The Company has agreed to develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage, and the contractual right to apply such a protocol if necessary.
PS2: Labor and Working Conditions
Triada has a total workforce of 226 direct employees. Around 73% of the staff is construction project personnel while the remainder 27% is administrative staff. The company has a significant participation of female employees of around 38%, relatively high for the construction sector. Female employees are found both in operations and at leadership positions.
Human Resource Policy: Triada has a documented policy for the management of employees. The policy together with the internal rules and regulations of the workplace (reglamento interno de trabajo) defines the rights and benefits of the employees as well as the key working conditions. The policy is provided to the employees upon taking employment.
Working conditions and terms of employment: Terms of employment are provided in the contracts the company signs with the employees as well as in the internal rules and regulations of the workplace. Conditions of employment follow Colombian law; that includes minimum age of employment of 18 years, no forced labor, overtime compensation and leave for illness, maternity and vacation period among others. The company has in place procedures for hiring and termination of employment and training. Triada applies principles of Non-Discrimination and Equal Opportunity and there is no evidence of discrimination based on personal characteristics or gender.
Triada operations are related to projects under construction and therefore, contracts for the personnel at the construction sites are established on a project by project , once the project is completed the contract expires. As feasible; depending on availability and location of projects, the company tries to retain the employees to other projects. The company has had a sustained increase of the workforce and retrenchment is not expected from this project.
Non employee workers: Triada verifies that those companies/personnel contracted to do the construction work are legal entities registered under the Colombian labor system and that all employees entering the construction site are affiliated to the social security system (health insurance) and the professional risks insurance (OHS insurance) and have undertaken basic safety training. Triada has included in the contracts with construction companies explicit clauses regarding labor, occupational health and safety, and traffic management (emissions, dust, traffic, etc). The company will review these clauses to incorporate elements such as management of construction debris and any additional conditions derived from the implementation of the ESMS such as reporting in case of finding archeological property.
Workers’ organizations and grievance mechanism: Triada employees do not belong to workers’ organizations or unions, and there has not been such request among the employees. The management team of Triada confirmed that they would not prevent employees to organize or participate in workers’ organizations. Employees’ grievances are managed through the direct supervisor and there is a committee (COPASO) in charge of collecting and re-directing employees concerns. Triada will make employees aware that this mechanism to present grievances is in place. The company maintains an open door policy allowing direct approaches to the management of the company.
Occupational Health and Safety: Triada has documented safety procedures applicable to all construction sites; topics covered include scaffolding, working at heights, operation and maintenance of cranes, equipment safety, training, use of personal protective equipment, among others. As part of the implementation of the ESMS, Triada will review the scope and practical application of the OHS procedures for all project sites, to ensure that the procedures in place are fully understood and reflect the existing risks and controls in place. All construction site workers, including contractors, are required to have initial safety training prior to starting work. In the particular case of crane operators and employees working at height additional training and medical assessment are required. Training on occupational health and safety issues is an on-going process, with training provided by the safety inspectors at each construction site. Appropriate safety measures and use of personal protective equipment were observed during the site visits. OHS staff monitors and collect quantitative and qualitative data on a regular basis, inspections and trainings are documented; retention of records will be reinforced.
PS3: Resource Efficiency and Pollution Prevention
Pollution Prevention, Resource Conservation and Energy Efficiency: Construction activities are associated with well localized and limited pollution risks related to land preparation, air emissions (heavy equipment, vehicles, generators), visual impact (e.g. publicity and cranes), and waste management. Controls for those environmental aspects are addressed following the recommendations of the Environmental Guideline for the Construction Sector produced by the environmental authority for Bogota (SDA). Triada through the implementation of the ESMS will ensure application of proper mitigation measures in all the developments. The company will consider potential opportunities to integrate resource conservation and energy efficiency measures into their low-cost housing projects.
Effluent Management: Triada’s developments have separate piping for sewage and storm water, the sewage is discharged to municipal sewers, and the storm water is discharged to the city-collectors for storm water. As mentioned before, all developments of Triada have been implemented in urban settings with well develop sewage systems. In order to obtain the construction license, the projects must be located in areas designated for urban development aligned with the Colombian Land Use Plans (Planes de Ordenamiento Territorial). Such plans must consider access to public services including sewage management. For projects developed under this transaction Triada will secure confirmation from relevant authorities of the acceptance of effluents as discharged to the sewage systems and will ensure compliance with local requirements for the management of the liquid effluents for each development. Where such confirmation is not obtained, Triada will either incorporate relevant systems into the design of the project or support the development of adequate capacity in the public sector or the lead developer.
Solid Waste Management: Triada has in place solid waste management programs at project level, the company have installed “ecological points” where the company collects and classifies solid waste according to type of materials; recycling was observed on site. At each construction site a well signaled area is assigned to retain waste materials, which are later disposed through the municipality or authorized vendors in the case of construction debris and metal scrap. Triada as part of the ESMS will reinforce training to assure proper implementation of the waste management programs in all the developments as well as proper segregation and disposal of the materials.
Green House gas emissions: emissions derived from the project are limited to the energy used during construction, mainly for illumination and operation of the tower cranes. Use at the headquarters of the company has been considered. The company does not own the vehicles used to provide materials. Total GHG emissions have been estimated around 200 tons of CO2-eq per year.
PS4: Community Health, Safety and Security
Triada designs and builds the properties in accordance with national standards, including the Colombian seismic code (Reglamento Colombiano de Construcción Sismo Resistente NSR 10), local fire protection standards, the Technical Specifications for Construction provided by the ICONTEC and regulatory institutions (e.g. residential gas suppliers, utilities companies), and the local Land Use Plans (Planes de Ordenamiento territorial) among others. The developments consider the access to basic services such as electricity, water and sewage; the projects developed by the company so far has been in urban areas where such services are granted.
During construction Triada considers the potential impacts on the communities and applies mitigation measures. The identified issues include traffic increase due to movement of vehicles to and from construction sites, noise from the operation of construction equipment, generation of dust and other nuisance factors. A traffic plan is implemented on all projects. The company provides information of the project and potential impacts to direct neighbors if that’s the situation of the development. Each project has an emergency response plan during construction. Construction sites are equipped with extinguishers, first aid kits and communication mechanism in case of emergency. Within the E&S management system Triada will verify that potential risks imposed to communities are properly mitigated.
The Company outsources security services at their offices and construction sites with a professionally managed security company, which has a well defined training program that include proper conduct towards community, proper use of firearms and management of general public.
