31433 - A & C Mixed Use

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Environmental & Social Review Summary

Project Number

31433

Company Name

A & C Development

Date ESRS Disclosed

Jan 27, 2012

Country

Ghana

Region

Africa

Last Updated Date

Dec 1, 2016

Environmental Category

B - Limited

Status

Active

Previous Events

Approved : Jun 13, 2012
Signed : Jun 15, 2012
Invested : Mar 11, 2013

Sector

Retail (Including Supermarkets, Grocery Stores, etc.)

Industry

Tourism, Retail and Property

Department

Regional Industry - MAS Africa

Project Description

A&C Development Company Limited (“A&C Development” or the “Company”) is a privately held real estate development company based in Accra, Ghana. The A&C Square was conceived as a one-stop mall concept consisting of a shopping mall, a fuel station, fitness centre/office block building, a pool area, two multi-purpose business plazas and a children’s play ground. The first phase of the project comprising the shopping mall and an adjacent fuel station was built over 4 years (commissioned in 2006). The second phase, or the expansion, which started in 2007 included fitness center/office block, pool block, children’s playground area and Business Plaza I (an office block) all of which were completed by May 2010. The proposed IFC loan will be used to fast track the completion of the third phase or expansion program of the A&C Mixed Use Complex (“A&C Square”) comprising the construction of an additional office blocks (Business Plaza II) and the refurbishment of the existing retail area (“A&C Mixed Use” or the “Project”).

Overview of IFC's Scope of Review

IFC''s review for this project included meetings with the management team of A&C Development Co; the executive team of the property management company in charge of the existing A&C Square development; and the design team, including representatives from the architects and the refrigeration and air conditioning engineers. In addition, a visit to the existing A&C Square which includes the site of the proposed project was conducted.

The following information was also reviewed: (i) responses to an IFC environmental and social appraisal questionnaire; (ii) existing operation licenses including Fire and Safety inspections by local authorities; (iii) contractual documentation between A&C Development and the management company and other contractors; and (iv) A&C Development’s human resources policies and procedures. The proposed project is in an early planning stage; therefore, detailed information on the design and environmental assessment of the project will be reviewed as the information become available.

E & S Project Categorization and Applicable Standard

While all Performance Standards (PS) are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment may 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
PS4: Community Health, Safety and Security

The project will be developed within the footprint of the existing A&C Square, land was acquired more than a decade ago by the sponsor on a willing buyer-seller basis and no involuntary physical or economic displacement occurred. The site is located in the urban area of East Legon in Accra, in a commercial and residential neighborhood well developed; therefore, impacts related to PS6: Biodiversity and Natural Resource Management, PS7: Indigenous Peoples and PS 8: Cultural Heritage are not expected.

This is a Category B project according to IFC’s Environmental and Social Review Procedure because of the limited number of possible adverse impacts, the site specific nature of these possible impacts, and that these potential impacts can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key environmental and social issues of this project include impacts during both construction and operation of the project; the following potential impacts were analyzed: (i) site location in an urban setting; (ii) identification of environmental and social impacts; (iii) life and fire safety aspects of project design and operation; (iv) management systems in place to address environmental and social issues; (v) labor and working conditions, including occupational health and safety of employees and construction contractors; (vi) solid waste management and disposal; (vii) tenants and visitors health and safety issues such as potable water and emergency response; and (viii) refrigerant selection.

Environmental and Social Mitigation Measures

The company has presented plans to address the potential environmental and social impacts to ensure that the project will, upon implementation of the specific agreed mitigation measures, comply with applicable national laws and regulations and the IFC’s Performance Standards. The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow, and in the attached Action Plan ESAP.

PS1: Social and Environmental Assessment and Management Systems
The proposed project is an expansion of the ongoing A&C Square development, and will be located in the footprint of the existing site. The company has been granted the permit to develop the entire project and therefore additional environmental studies might not be required; the project is not expected to require a formal Environmental Impact Assessment from the local authorities. A&C Development will assess the impacts of the project and will develop an Environmental and Social Management System (ESMS) to define measures to be adopted to mitigate environmental and social impacts throughout (i) construction (for example, mitigation measures can be related to access, excavation, noise, materials storage, construction safety); (ii) post-construction (for example landscaping, traffic plan); (iii) design standards (life and fire safety); (iv) routine operations (for example, waste management, monitoring of potable water, monitoring of utilities use); and (v) emergency response. The ESMS may consist of documented operational procedures, practices, plans, and related supporting documents managed in a systematic manner.

The construction of the project will be undertaken by A&C Development under the coordination of a project manager, following the approach implemented in the construction of the existing facilities of the A&C Square. The approach embraces sub-contracting well established firms and having a strong coordination by A&C Development to program the construction and manage procurement of key materials. A&C Development is in the process of commissioning an architectural firm and sub-contractors for the structural, mechanical and electrical design and construction of the project. The project will comply with Ghanaian building regulations related to architecture, structural and civil works, access to disabled persons and life and fire and safety; in addition, the project will have modern air-conditioning and fire protection systems. As it has been done with the existing development, the company will obtain the required permits to construct the project; such permits include a concept of the Environmental Protection Agency of Ghana and routine inspections from the local Fire Department to verify compliance with the Ghana National Fire Service Regulations.

A&C Square has recently incorporated the external professional property management company Broll Ghana Ltd. to coordinate the operation of the property. Broll is a well recognized and experienced operator throughout Europe and Africa. The current operation of A&C Square considers management of quality elements including procurement, maintenance and customer service (including tenants) which are associated to some extend with the management of environmental, labor, occupational health and life & fire safety elements. Those elements will be reinforced through the implementation of the environmental and social management plan.

PS2: Labor and Working Conditions
A&C Development has currently 39 employees and Broll (the property management company) has 4 permanent staff assigned to manage the current operations of A&C Square. Activities such as housekeeping, security, gardening and maintenance are outsourced. During construction a peak of around 50 workers might be expected, mostly sub-contractors.

Both A&C Development and Broll have extensive and well detailed Human Resources (HR) policies. Topics covered in the HR policies include non discrimination and equal opportunity, provisions for no child labor and no forced labor, avoidance of harassment at work and grievance mechanisms. Broll’s human resources policies are in accordance with South African labor legislation, which is consistent with the requirements of this Performance Standard. Working conditions are communicated through formal contracts and the employee handbook that is handed out to all employees upon taking up of employment. The employee handbook includes provisions on schedules, leave benefits (vacation, sick and maternity leave), access to medical care, salary increases, disciplinary procedures, and the company’s approach to training and development of employees.

Existing services contracts with maintenance providers and the management company requires compliance with Ghanaian labor laws in its contracts. A&C Development will include clauses in the contracts with construction contractors for the new development and key subcontractors directly engaged with A&C Square to manage labor, environmental, and occupational health and safety issues in a professional manner compliant with Ghanaian law and IFC’s Performance Standards requirements.

The minimum age for employment at A&C Development is 18 years; the company reviews personal records to ensure workers are above 18 years. A&C Development employees do not belong to workers’ organizations or unions. By law, all contracted employees have a right to join a workers union; however there has not been such request among the employees. The management team of A&C Development confirmed that they would not prevent employees to organize or participate in workers’ organizations. Employees’ grievances are managed through the direct supervisor who addresses the concern and might refer the grievance within 48 hours to the executive chairman. In addition, the executive chairman has open door policy, so any employee can address concerns directly to him.

A&C Development will formalize the occupational health and safety (OHS) requirements to construction contractors by including OHS clauses in the contracts and by implementing safety training and inspections. A formal safety plan will be submitted to IFC before construction starts and it will be implemented during the construction phase. As part of the implementation of the E&S Management System A&C Development will address OHS elements during operations including management of electrical hazards, falls and trips and safety during maintenance operations.

PS3: Pollution Prevention and Abatement

The preliminary design of the project prioritizes the use of natural light and natural ventilation over artificial lighting and cooling. In the current operations electricity use in common areas of the property is relatively modest and use within the retail areas and offices, including air conditioning, is the responsibility of tenants. The company has implemented a small solar panel in the gym area to provide warm water to the gym showers. The project has considered the use of dual flush systems for the toilets and the use of energy-saving bulbs; the company is considering in the proposed design the use of storm water to flush toilets and for irrigation of the gardens.

The electricity consumption of the existing common areas of A&C Square is approximately 15,000 kWh per month. This equates to approximately 80 kWh/m², which compares favorably with global benchmarks for office and retail facilities, which range between 200 and 300 kWh/m². Green house gas emissions of the proposed project have been estimated to be around 300 tons of CO2-equivalent per year.

The existing facilities have a small standby generator, which operates few hours per month when electricity from the grid is not available. The new project will include an additional small standby generator (or alternatively the project might include the upgrade or the existing generator), its size will be below the threshold at which IFC or local regulators require emissions monitoring.

Effluents from the new project will be limited to domestic effluents from common areas and offices’ sanitary facilities; the project plans to install a two stage septic tank system with sufficient capacity and the sewerage will be disposed of via the Accra sewerage works which are operated by the ACA Metro Sewerage Unit. The existing facilities have a similar system and effluents are in compliance with Ghana’s national waste water requirements. The existing facilities include grease traps for the food court/restaurants area.

Waste produced at A&C Square is collected through on-site containers and then located in a designated area which is enclosed and ventilated. Waste is collected daily and disposed of at the municipal waste disposal site. The company will upgrade the waste collection area and ensure proper maintenance to avoid generation of odors and proliferation of pests. Recyclable waste will be made available to recycling contractors depending on demand for these materials. Solid waste during construction operations will be collected in dedicated containers and in particular construction debris will be disposed trough authorized vendors.

Air conditioning units throughout the existing facilities consist of individual units per office or retail unit. The new project will use also individual units using refrigerants R-410/404. In the existing installations phase out of HCFC-22 refrigerant in air conditioning systems has commenced, it s being replaced by a drop-in non ozone-depleting substitute R407 and eventually to R410. Maintenance of the gardens require the use of pesticides on occasion and the facilities will also be fumigated according to a predefined schedule, the company provides proper protection to employees and has committed to assess the use of products to minimize risks to workers and visitors.

PS4: Community Health, Safety and Security

The project will be designed, constructed and operated in accordance with internationally accepted life and fire safety (L&FS) standards and local fire department regulations. A&C Development will submit to IFC an L&FS Master Plan that will identify, among other things, major fire risks, applicable codes and mitigation measures. The L&FS Master Plan will be prepared by a suitably qualified professional, acceptable to IFC, who will certify that the design meets the requirements of IFC’s L&FS guidelines. The qualified professional will also undertake a review at the time of L&FS systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design. The existing A&C Square site includes a fuel station, fully operational and completed by 2009. The station is operated by a recognized gas company and has specific safety procedures during loading the fuels and protocols for the monitoring of underground storage tanks.

A&C Development confirmed that the project will be designed to comply with the Ghana Building Code and that structural/seismic requirements are adequate for the level of risk. The seismic risk zoning of the site’s location will be factored into the design of the building, in accordance with local codes and regulations A&C Development will provide a formal concept prepared by a suitably qualified professional who will certify that the design meets the structural requirements.

In addition to the above, A&C Development will establish and maintain an emergency preparedness and response system. Preparation and planning shall include identification of areas where accidents and emergency situations may occur; communities and individuals (tenants and visitors) that may be impacted; response procedures; provision of equipment and resources; maintenance and operation of equipment (alarms, pumps, hydrants, extinguishers, etc); designation of responsibilities; communication; and, periodic training to ensure effective response.

The construction phase will have limited impacts to the surrounding community, given that the project will be in the existing premises of A&C Square. A&C Development will restrict access to the site only to workers and authorized personnel and will ensure proper management of dust and noise through the environmental management plan defined under the Social and Environmental Assessment and Management System section of this report.

Water is provided by the Ghana Water Company which is expected to comply with WHO requirements. A&C Development will test the water quality before the site opens to the public and at least annually thereafter, if needed additional treatment should be introduced.

Stakeholder Engagement

This Environmental and Social Review Summary (ESRS) and the attached Environmental and Social Action Plan (ESAP) will be posted at A&C Square, East Legon, Accra, Ghana within the public view; and at:
Environmental Protection Agency
P.O. Box M326
Accra, Ghana
Telephone: 0302 664 697/8

Please contact the following for inquiries or concerns about the environmental and social impacts of this project.

Andrew Asamoah
Phone: 0244644810
Address: A&C Development Company Limited
A&C Square
14 Jungle Road, Christian Center
East Legon, Accra
P.O. Box 17506
Accra, Ghana
E-mail: asamoaha@aandcdevelopment.com

A&C Development will make adequate public disclosure of this transaction in the Ghanian business and trade press.

Client Documentation

File Name	Actions
ESAP AC Mixed Use to disclose.xls

**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.

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