Risks discussed in this ESRS consist of those associated with the operation of Imaging Diagnostic Centers that includes Labor and Occupational Health and Safety issues related to exposure to hazardous agents such as radiation and magnetic waves; Solid and Hazardous wastes disposal (biological and radioactive);life and fire safety; E&S management capacity and management systems.
Key mitigation measures are described in the Environmental and Social Action Plan (ESAP) and includes building Alliar corporate management capacity; enhancing OHS prevention measures, enhancing life and fire safety protection and developing specific EHS management programs.
PS1: Social and Environmental Assessment and Management System
Alliar manages its environmental and social aspects seeking compliance with national and local laws and regulations. Axial, one of Alliar subsidiaries in Belo Horizonte, MG has an integrated management system covering Quality Assurance, Health and Safety and Environmental aspects. Axial was the first non hospital institution in Brazil to get ONA (Organização Nacional de Acreditação) certification (level 3). Axial is also certified under ISO 9001 and 14001 standards.
Alliar will implement an integrated EHS Management system covering Environmental, Occupational Health and Safety and Quality assurance at a corporate level and consistent with IFC PS1 requirements.
Alliar will appoint a manager at a corporate level that will be responsible for E&S issues, to develop Alliar own corporate standards and support all of its subsidiaries to implement the management system and related programs.
Environmental and Social Assessment: Axial has identified all Hazards and Risks to its employees under the Health and Safety Risk Prevention Plan (PPRA), as well as the environmental aspects and impacts. Under the management system implementation, Alliar will spread its experience and best practices developed in Axial to the other subsidiaries and potential new acquisitions or expansions.
Management Program: Alliar’s diagnostic centers currently have some E&S mandatory programs in place, such as OHS risk prevention, OHS health management and solid waste management programs. As part of the above mentioned integrated EHS management system implementation, Alliar will further develop all necessary management procedures and programs to deal with the possible gaps identified during the preparation of the EHS risk assessment.
Organization: Currently, Alliar E&S aspects are managed by the respective operational managers of each subsidiary. Axial has two OHS technicians and a consulting firm that helps them to develop and implement all mandatory OHS programs. As mentioned above, Alliar will appoint a manager at a corporate level that will be responsible in identifying the staffing needs at its subsidiaries to implement the E&S management system and related programs.
Training: Axial provides a basic EHS training for all workers during their induction program. As part of the integrated EHS management system implementation, Alliar will further structure and consolidate a comprehensive training program for each business unit.
Monitoring: Axial monitors relevant E&S aspects/risks, such as water consumption, energy consumption; solid wastes generation/disposal and accident rates. Alliar subsidiaries also monitor workers exposure to radiological agents and workers health under the mandatory worker’s health monitoring program. As part of the integrated EHS management system implementation, Alliar will enhance all subsidiaries’ monitoring programs covering all relevant E&S performance indicators.
Reporting: Axial reports internally selective E&S performance indicators, such as water consumption, energy consumption; solid wastes generation/disposal and accident rates. As part of the integrated EHS management system implementation Alliar will further structure and develop a formal corporate standard for E&S reporting to managers and Directors showing key E&S impacts and risk indicators.
PS2: Labor and Working Conditions
Human Resource Policy and Management: Although Alliar does not have a formal General HR policy yet, their subsidiaries have their own HR policy and follow Brazilian labor regulations, which are consistent with the International Labor Organization (ILO) standards (Brazil is a signatory of most relevant ILO conventions). The terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday, are established by national labor regulations and applicable sector specific collective bargaining agreements. Alliar manages HR issues in compliance with local laws. All workers have to sign a formal contract with the terms of employment and retain a copy of that. Workers also have a worker’s labor book (“carteira de trabalho”), provided by the Brazilian Ministry of Labor, in which all information related to the terms of employment in the contract is registered, including hiring period, compensation, leave, promotions, salary increase and termination of contract.
As set forth in the ESAP, Alliar will develop a formal corporate HR policy statement with a commitment of compliance with local law, non discrimination and equal opportunities, to provide a safe and respectful workplace and to stand against forced labor, child labor, sexual or other forms of harassment. Alliar will also develop and put in place a series of formal HR policies, such as hiring and termination of contract policy, duties and compensation policy(ies), performance assessment and promotion policy, Benefits policy, Occupational Health and Safety policy.
Worker’s Organizations: As defined by law in Brazil, all workers have to contribute to their respective sector workers’ union. Annual salary increase, sector specific minimum wage, profit sharing and some benefits are negotiated directly with the unions under collective bargaining agreements, but respecting the minimum standards defined by the Federal Administration. Alliar has some union representatives working in their facilities and there is no evidence that the Company restricts workers’ freedom of association.
Non-Discrimination and Equal Opportunity: Alliar has confirmed that the employment relationship is based on the principle of equal opportunity and fair treatment. Alliar currently hires 1,065 permanent workers of which 29.6% are male and 70.4% female, which is consistent with the nature of the work and other industries benchmarking. During the field visit, no evidence of discrimination based on workers’ personal characteristics unrelated to the job requirements, such as race, gender, religion or region of birth was identified.
Retrenchment: No retrenchment is expected for this project
Protecting the Work Force: Alliar ensures that no forced or child labor is used at their operations by direct hiring all workers (no intermediaries) and following national laws, as described above, and the minimum worker’s age is 18. Alliar also hires students under a internship program sponsored from Brazilian Ministry of Labor called “Jovem Aprendiz” in which students from 14 to 18 years old are hired to perform non hazardous work and part time job.
Occupational Health and Safety: Alliar manages OHS risks in a manner compliant with national and local regulations. Alliar has developed and implemented individual OHS mandatory risk prevention plans for each plant, identifying the work related risks, the workers exposure to hazards agents and the need for protection. Axial also has individual health monitoring program and specific procedures on the safe work practices.
Alliar will enhance existing monitoring program to assess workers’ exposure to radiological agents and adherence to prevention measures, including more thorough periodic inspections, internal corporate audits and reporting. Alliar will conduct an ergonomic assessment of work places and develop a related ergonomic program following Brazilian OHS standard (NR17). Alliar will also conduct an electrical safety assessment of its facilities according to Brazilian OHS standard (NR10), and will put in place a corrective action plan covering the gaps identified in the assessment.
Alliar will review, at a corporate level, individual OHS risk prevention and OHS health monitoring plans/ programs of its local subsidiaries to ensure minimum quality standards.
PS3: Pollution Prevention and Abatement
Resource Conservation, Energy Efficiency: Alliar purchases electricity from the grid and the total annual consumption is 790,000 kWh. Alliar is replacing old stand alone air conditioning equipments to modern and more efficient chillers.
Solid wastes – The solid wastes are mainly paper and paperboard, plastic material and metal scarps, sanitary and organic waste. Hazardous wastes include biological material (laboratory wastes, in Belém), used needles, chemical materials, radiological agents and materials such as primary packaging that have been in contact with pharmaceutical products. Biological material from the laboratory are treated in an autoclave before final disposal. Alliar facilities have a contract with a licensed waste management contractor; which has a waste segregation program and disposes of the varied types of waste in licensed facilities according to local regulation.
Air emissions – no direct air emission was identified.
Wastewater – Wastewater from Alliar facilities are mainly sanitary wastewater and laboratory (only in Belém) wastewater. All wastewater is collected and discharged to the local sewage systems. In Belem, all clinical exam machines use dry technology and only the parasitological exams are done manually, which results in less hazardous wastewater generation.
Hazardous Materials – Alliar storages and handle radiological products used as contrast agent in some specific exams (low radioactivity, max 0,017 mSv/MBq), some of the machines are radio transmitters (X ray; Tomography machines) and contain radioactive elements. Under the Integrated management system implementation described above, Alliar will develop a specific procedure in accordance with Brazilian legal requirements and ONA standards to storage, handle and disposal radioactive elements. Radioisotopes will be returned to their suppliers when no longer effective.
Greenhouse Gas Emissions- Alliar emissions are mainly related to the use of electrical energy from the grid, and eventual loss of chillers refrigerant gas. As mentioned above Alliar is replacing old stand alone air conditioners to more efficient chillers. As part of the management system implementation Alliar will monitor energy consumption from its facilities and identify potential areas of energy savings.
PS4: Community Health, Safety and Security
PS4 Community Health and Safety and Security
Alliar is a health service provider and, as such, safety is a key aspect of its operations, in particular those aspects related to the safe operation of imaging equipments such as X-Ray, Tomography and Magnetic Resonance Machines. All rooms that contain equipment emitting ionizing radiation have appropriate lead-based protection and periodic protection tests are conducted. In addition, the life and fire safety aspects of Alliar’s facilities are very important in relation to its own employees and clients safety.
Emergency Preparedness and Response - Axial has specific emergency response procedures covering different scenarios such as fire fighting and response, workers accidental exposure to biological or chemical hazards. They also have Emergency Brigades and perform periodic emergency drills.
Alliar will develop emergency response and preparedness plans covering emergency scenarios and risks, for all facilities and will set up and train the emergency brigades for each facility and conduct periodic emergency drills.
Life and Fire Safety: Alliar currently operates in several states of Brazil. The Company, which has grown in part by acquisition, is compliant with the fire safety requirements of the jurisdictions in which its facilities operate. The fire safety protections of its buildings vary according to local requirements and do not always correspond to internationally recognized standards. As set forth in the ESAP, Alliar will adopt an internationally recognized life safety code, and progressively audit its existing buildings against this code and update fire protection in accordance with the findings of the audit.
Alliar will commission a life and fire safety professional to develop corporate fire safety specifications, which shall be adopted in all new facility construction or substantially remodeled buildings used by Alliar and which shall be responsive to an internationally recognized fire safety code. Post construction, a life and fire safety professional shall certify that the buildings were constructed in a manner compliant with this corporate specification and taken appropriate account of site-specific conditions. Alliar will also review the life and fire safety conditions of SOM operations in Pará, in accordance with the same internationally recognized life safety code.
