While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

Based on the site visits to Luminus’ premises in Amman, and discussions with Luminus management, this project will have limited potential adverse environmental and social impacts which are site-specific, reversible and easily addressed through the measures summarized below in addition to the agreed mitigation measures as outlined in the Environmental and Social Action Plan (ESAP) attached to this ESRS. This is hence a category B Project.

The main E&S issues related to Luminus are land/building acquisition, permits, regulatory compliance; environment, health and safety during construction/renovation/restructuring; building structural safety, life and fire safety, emergency preparedness and response; energy and water efficiency; hazardous materials, wastes, emissions and effluents management and minimization, human resources policy and practices; safety and hygiene control mechanisms both for personnel and students, supply of food and drinking water, engagement with communities.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Luminus Group currently has a separate Management System for each subsidiary, however purchasing operations, administration, IT and maintenance are services that are conducted on the Group level to all companies. SAE Amman has a Management system that is tailored for the international accreditation, while Al Quds College has a different Management system tailored for its own specific needs. Luminus Group will develop environmental, health and safety (EHS) procedures, facility guidelines and maintenance procedures that comply with IFC’s Performance Standards and host country regulations and incorporate them into a Social and Environmental Management System (SEMS) for all of Luminus Group. The SEMS will encompass social, occupational health and safety, human resources, and environmental management associated with the full life cycle of operations from the selection of sites for expansion, the construction of new facilities as well as the operation of existing facilities and associated facilities. The SEMS will be applied and implemented on the Luminus Group level and be rolled out to all subsidiaries. Luminus will nominate a SEMS officer to be responsible for the SEMS implementation, training to staff, and roll out to all subsidiaries of Luminus Group. Luminus catering services the college and school in Amman. Luminus catering is currently ISO 22000 certified in 2011 for food safety and is in the process of getting HACCP certified for food and hygiene.



Construction Activities

Currently there is construction occurring at Luminus facilities to build the new MBC studios for the partnership between MBC and Luminus to commence. While construction activities occur at site, Luminus will ensure that proper oversight of construction activities is provided, including proper Personal Protective Equipment (PPE) usage by laborers, correct demarcation of construction areas and ensuring public safety. Construction Management of building works needs to be explicitly addressed in the SEMS Manual.

Human Resources Policy

Luminus currently has comprehensive HR Policies and Procedures that are adopted on the Group level and consistent for all subsidiaries. These incorporate most elements required including salary structure, working hours, vacation and sick days, anti-discrimination policies etc, for compliance with Performance Standard 2. The minimum age for employment is 18 and at least 36% of its labor force of 437 persons, is female with many women in senior Managerial positions. There are no labor unions at Luminus group currently but staff members are not discouraged from joining unions if they wish to. The HR Policies and Procedures at Luminus group will be updated to meet IFC’s Performance Standard 2 by incorporating workers engaged by third parties including contracted workers ( such as those in construction activities); and Occupational Health and Safety (OHS). OHS aspects are expressed in the Management System but not in the HR policy and procedures and hence should also be updated there.



Regular trainings for proper equipment handling and life and fire safety occur at Luminus for corrective actions. Luminus has outsourced its cleaning to a company with 38 employees ensuring housekeeping on Luminus facilities. Luminus currently has 35 buses to transport their students and employees. Luminus has an official grievance mechanism but also promotes an open-door policy at all times with their staff, management, and students.



Occupational Health and Safety

There have not been any fatalities during construction activities to date or any lost time accidents. Injuries and incidents will be tracked and monitored correctly. Employees are provided with health insurance and are compensated in the case of accidents. During construction, workers are required to adhere to Occupational Health and Safety (OHS) measures that are enforced by the contracting firm. Regulations of industrial security are enforced, including a requirement for all workers to use safety helmets, boots and shoes and other PPE. Sub-contractors are also required to follow all site safety rules and regulations.



There are 33 stations around all the Group’s facilities to monitor workplace conditions including air quality, CO2 concentrations, temperature, etc. These stations are monitored 24 hours a day through an automated computer system. There are 3 boilers powered by natural gas on the premises that are also monitored regularly for workplace conditions.



Life and Fire Safety

Life and Fire safety provisions in all their facilities are in accordance with national regulations, and the Jordanian civil defense inspects the premises every 6 months. Fire drills are currently conducted twice a year at SAE Amman, and once a year at Al Quds College and the remaining facilities. This is due to the difference in requirements for Management systems. These will be made consistent and Luminus will increase to a minimum of three fire drills a year to meet International S
tandards for all facilities. In SAE Amman, the walls are fire retardant and insulated, with smoke detectors and sprinklers in every room. There are four storage tanks of water for fire sprinklers each with a capacity of 1600 m3. The other facilities however are not as highly equipped as SAE Amman, and a higher level of uniformity is needed in meeting International Standards for life and fire safety. Luminus will engage a qualified Fire Safety Consultant acceptable to IFC to review and certify that engineering design of the expansion project is fully responsive to internationally acceptable fire safety standard. As part of this task, the Consultant will also review the current level of Life and Fire Safety at the existing complex, with respect to possible integration issues and common system supplies. Upon physical completion of the building, the Consultant will certify that all fire safety systems are installed in line with the design criteria and good installation practices.  



Going forward, Luminus, with the assistance from the Consultant, will develop a corporate Life and Fire Safety Master Plan, outlining key design criteria to be translated into all new properties’ design. The company will implement a corporate Master Plan at all its new facilities and will engage the Consultant to review the fire safety system design and certify the installation upon physical completion of buildings. Luminus currently has an Emergency Response Plan but this needs to be developed further to account for community risks and needs.

Water and wastewater

There are four water storage tanks of capacity 400 m3 each at the Group’s facilities. Water is purchased from the national grid and goes to service all the facilities including media and education. Water consumption of Luminus facilities approximates 400 - 450 m3/month. Water saving devices is installed in all bathrooms a\t Luminus facilities. Testing for water quality is performed monthly for main water parameters of pH, BOD, COD, etc. There are five pumps that pump the wastewater from the facilities to the main storage pit of 280 m3 to be transported weekly then by a Contractor to a treatment plant for treatment and reuse. There is currently no monitoring or testing of the wastewater. Wastewater generation is approximately 380 m3/month.



Energy

Electricity in Amman can cut up to 3 times per month for approximately 2-3 hours and hence standby generators are necessary for Luminus to run their facilities at all times. There is 1 diesel generator of 460 kVA. This generator is sufficient for all the buildings excluding the HVAC systems. Luminus purchased another generator of 1100 kVA to backup the existing generator. Luminus is currently gradually beginning to switch to energy efficient lighting in all of their buildings. The natural gas fired boilers are used in winter for heating. GHG emissions for Luminus Group facilities are composed of direct combustion of fuel in boilers, generators and mobile vehicles, electricity purchase from the national grid, and operation of air-conditioning equipment. GHG emissions were estimated at 2244 tons CO2 equiv. /year, with electricity consuming almost 64% of the total emissions and the Chillers consuming 50% of the electricity consumption.



Waste and Hazardous waste

Hazardous and non-hazardous waste is not segregated at Luminus and may cause potential harms. In the hospitality and medical sections of Al Quds College contain hazardous materials such as liquid solvents and other detergents that are not stored correctly or disposed of correctly. There is a small quantity of medical waste from the medical training sections. The medical waste is combined with the hazardous waste and non-hazardous waste all together. A waste segregation system will be put in place to eliminate these dangers. Waste generation is approximately 4 m3/day for all the Group’s facilities, and it is collected daily by a Contractor.



Water consumption at Luminus facilities approximates 5100 m3/yr, while electricity consumption is 2,501,470 KWh/yr. As Jordan is one of the most water scarce nations in the world with water and energy demands increasing and supply is either decreasing or stagnant, Luminus Group will develop a water and energy efficiency program at all their facilities to reduce water and energy consumption. Such a program will be mainstreamed into their planning process for efficiency and reduction targets. A series of opportunities for water and energy savings will be identified with a plan o
f action to outline how to implement each action item in this water and energy savings plan. Internal benchmarking for each building for water and energy will be developed to ensure that targets are met. Similar provisions will be done for any new facilities in accordance with all above activities.

Luminus Group has employed 30 security personnel to be on site. Security personnel are unarmed, yet there are metal detectors at the entrances of the gates and inspection is done thoroughly with badge IDs.



There are currently no disability ramps or other conveniences for disabled persons at any of their Group facilities. Luminus do not have disabled students at present but all future facilities will provide for the mobility of disabled persons so that disabled people may attend.

There currently is no grievance mechanism for the surrounding communities, but one will be established in accordance with the attached Action Plan. Luminus maintains an open-door policy with the CEO for the community, staff, and students. Luminus intends to hire a Communications officer in 2 months who will be doing community development work as well as press release and continuous engagement with the surrounding community. Luminus currently provides scholarships for some of their students as a CSR initiative on a small scale but intends to expand this further once the Communication Officer is recruited.

Luminus Group will be posting the ESRS and ESAP on its website in both English and the local language of Arabic http://www.luminusgroup.com.jo . In addition Luminus will also disclose reference to these project documents in the following Jordanidan newspaper - Al Rai newspaper.

Mr. Ibrahim Al Safadi
CEO, Luminus Group
mailto:ibrahim@luminusgroup.com.jo
Tel: +962 6 5799 020/45 ext. 2609  
Fax: +962 6 5799 044
P.O.BOX : 183334 Amman 11118 Jordan

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date
1.Develop environmental, health and safety (EHS) procedures, facility guidelines and maintenance procedures that comply with IFC’s PS and host country regulations and incorporate them into an Environmental and Social Management system (ESMS). ESMS should encompass social, occupational health and safety, human resources, and environmental affairs management associated with the full life cycle of operations from the selection of sites for expansion, the construction of new facilities as well as the operation of existing facilities and associated facilities. The ESMS should be applied and implemented on the Luminous Group level and then rolled out to all its subsidiaries.	5/15/2013
2.Upgrade Human Resources (HR) policy and procedures in accordance with IFCs Performance Standard 2 to include workers engaged by third parties; and Occupational Health and Safety (OHS). The HR Policy and Procedures should be applied on the Luminus Group level and rolled out to all subsidiaries.	5/15/2013
3.Appoint a ESMS Officer to be responsible for all HSE and ESMS related activities.	4/15/2013
4.Develop a Waste Management Procedure to properly ensure the segregation of hazardous and non-hazardous waste at all facilities.	5/15/2013
5.Develop a land acquisition and compensation procedure in keeping with IFC Performance Standard 5 to be followed for all Company land acquisition activities and documentation requirements for all new facilities. AND Ensure screening of all new facilities against IFC’s Performance Standard 5 for Land Acquisition and Involuntary Resettlement. .	11/15/2013
6.Develop a corporate LFS Master Plan. The qualified Life and Fire Safety professional acceptable to IFC will assist the company with the development of a corporate manual, outlining key design criteria to be translated into all new properties’ design. The company will implement a corporate Master Plan at all its new facilities and will engage the Consultant to review the fire safety system design and certify the installation upon physical completion of buildings.	6/15/2013
7.Develop a Community Grievance Mechanism to record, review and respond to any community grievances.	5/15/2013
8.Ensure that future educational and media facilities provide for the easy mobility of disabled persons including ramps and rails in all new facilities	5/15/2013
9.Energy and Water Utilization Efficiency. Luminus will develop an Energy and Water Savings Plan for all its facilities to determine opportunities for implementable energy and water use efficiency improvement measures. Incorporate such efficiencies in design of new facilities upon construction	11/15/2013