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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because potential adverse environmental and social risks are limited, reversible and may be readily mitigated.
Key issues associated with the Project include: ;i) the building standards applied to schools including those related to life and fire safety; ii) labor and working conditions for staff including occupational health and safety during the construction phase, though the latter is considered of limited significance given the type of structures involved; iii) provision of potable water of an adequate quality and the approach to the disposal of sewage; and iv) security measures implemented at the schools to ensure the safety of learners.
In terms of land acquisition, Bridge has established a consultative and rigorous process for site selection for each school, as described under ‘Client Community Engagement’ below. Further, Bridge only acquires land if it is greenfield or owner-occupied. A process of willing-buyer willing seller is applied and if any crops are being grown on the land, negotiations are held with the landowner as to whether they want to harvest prior to land acquisition or whether compensation for these crops should be built into the price of the land. Bridge has never had to undertake resettlement or undergo an extensive compensation process in relation to loss of livelihood. Thus PS 5: Land Acquisition and Involuntary Resettlement is not applicable to this Project. New schools are generally sited within informal settlements or low income areas where the land is highly degraded and converted. As such, PS 6: Biodiversity Conservation and Sustainable Management of Living Resources also does not apply. Neither does PS7: Indigenous Peoples as the schools are within urban environments where indigenous peoples, as defined by PS7, would not be found. Finally, given the areas occupied by the schools, PS:8 Cultural Heritage also does not apply.

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.

Environmental and social assessment and management system, organisational capacity

Bridge has implemented a number of environmental and social policies, procedures and plans to ensure compliance with national legislative requirements and IFC’s Performance Standards in relation to specific environmental and social issues (e.g., Life and Fire Safety management, occupational health and safety during construction, human resources management, recruitment, designing for health and welfare of teachers and learners etc). Where there are procedures and plans in place each issue has an ongoing auditing and monitoring function to ensure appropriate implementation. The latter is undertaken by the Bridge Quality Assurance team that visit 10% of Bridge’s schools daily. To date an Environmental Impact Assessment (EIA) has been conducted for every school built, and Bridge has a team of EIA professionals licensed by the Kenyan National Environmental Authorities (NEMA) who undertake these assessments.

In response to a requirement in an OPIC (U.S Government’s development finance institution) due diligence for investment in 2012, Bridge is in the process of developing a group wide Environmental and Social Management System (ESMS) so as to integrate various aspects associated with environmental and social issues associated with the Company activities. As defined in the project ESAP, IFC also requires such a system aligned with the requirements of this Performance Standard and which must contain an overall policy, management procedures and plans, clear and adequate organizational capacity and competency, and a processes for monitoring and review. Furthermore, when Bridge expands into other countries, the quality assurance process and EIA/permitting arrangements will need to be defined for each country and included into the ESMS. In addition, Bridge will develop and implement an assessment procedure to identify and manage environmental and social impacts and risks where no EIA is required; this will form part of the ESMS.

Bridge has an Emergency Response Plan (ERP) as contained in their Life and Fire Safety Management Plan (described under PS4 below), and four assembly points per school. This requires the ERP be posted at the Academy Managers’ (AM’s) office. It contains a list of emergency numbers relevant to each school, including the chief, police, medical professionals, and closest hospital; requirements for awareness generation for parents, chiefs and local leaders and children; emergency infrastructure, assembly points, information posters and responsibilities. It also contains fire procedures detailing actions and responsibilities at each stage of an emergency, and some general evacuation response guidelines.

Bridge has a Construction Team and supervisors who are responsible for building the schools. These supervisors generally recruit people directly from the community and apply Bridge’s Occupational Health and Safety (OHS) requirements to those
employed during construction. This is further described below.

Working Conditions and Management of Worker Relationships

Bridge has a group Human Resources (HR) function consisting of a manager and four support personnel. The policies, procedures, practices, benefits, and programs under HR are contained within two employee handbooks, one for staff at Bridge headquarters, the other for staff working at the schools. These were compiled to meet Kenyan legislative requirements as well as best practice in Human Resources. When Bridge expands into other countries, these will need to be assessed against the associated countries’ legislative requirements and amended accordingly. This requirement is included in the ESAP.

All employees, including those contracted during construction, are issued with contracts which set out the details of the working conditions and terms of employment. The handbook also contains a policy on equal opportunity and non-discrimination, amongst others. There are two types of contract: those for permanent employees on indefinite contracts (the majority of employees), and others for a fixed term (such as expatriates who are on a fixed term contract related to the duration of their work permits). Temporary contractors also receive contracts setting out their terms and conditions. Bridge does not restrict staff from joining workers’ unions, although none of its staff have joined a union to date.

Bridge recruits people for construction and to staff the schools from the local community. This is done by sending a recruitment team into the local community and informing them about the job opportunities at the new school. For recruitment of staff for the schools, applicants are assessed in terms of ability to perform the job and tasks required and this process is free from discrimination, as per the Equal Opportunity Policy contained within the Employee Handbook. All those recruited for operations are trained in Bridge’s approach, materials and requirements for teaching and running the school, depending on the position being recruited for.

Bridge operates an open-door policy with staff whereby staff can consult with HR management at any time through the IT technical channels available and through the regular quality audits conducted by the quality assurance team. If an employee feels that s/he has have been discriminated against, the Employee Handbook

states that the employee should report his or her concerns to the Human Resources department. However this procedure needs to be clearly documented into a written procedure noting how grievances will be addressed and include a mechanism for confidential and anonymous reporting. This requirement is contained in the ESAP.

The Employee Handbook describes various offences and associated disciplinary procedures. This refers to a disciplinary committee made up of representatives of the parents committee and the HR committee.

In general, besides the requirement for a formalised grievance mechanism for staff, Bridge meets the requirements of P
S2 on working conditions and management of worker relationships.

Occupational Health and Safety

Bridge has developed an Occupational Health and Safety (OHS) Plan which has been approved by a Kenyan Government-approved Safety and Health Advisor. The plan was developed by Bridge’s Health and Safety Committee which has ultimate responsibility for the effective implementation of the plan. The Committee is a recent initiative and chaired by a member of the Company legal team and has representation from the construction, operations and human resources departments as well; the Committee reports to the CEO. Specific responsibilities for the Committee are yet to be defined, though as per the ESAP the OHS plan will be updated to reflect these.

During construction, implementation of the OHS Plan at a local level is the responsibility of the construction supervisors. Those recruited for construction are provided with a specially designed training programme to ensure quality and safety in the construction process. During operation, the head of the school (‘Academy Manager’ (AM)) and Parent Committee are responsible for the OHS Plan implementation. An annual audit is undertaken of the implementation of this plan and data analysed to determine any OHS non-compliance issues or trends that might be arising.

The OHS plan takes into account all relevant Kenyan regulatory guidelines (including the Occupational Health and Safety Act and Work Injury and Benefits Act and the Building Codes of Kenya) as well as the WBG General EHS Guidelines. This OHS Plan covers both the construction and operation stages of the schools and includes in broad terms; a) identification of potential hazards and protection in general facility design and operation for school staff and construction workers; b) communication and training of construction workers and school staff; c) physical hazards; d) personal protective equipment (PPE) requirements; e) special hazard environments; f) monitoring, documentation and reporting of occupational accidents, diseases and incidents; and e) emergency prevention, preparedness and response arrangements. The latter then refers to the Life and Fire Safety Management Plan.

When Bridge expands into other countries, the OHS Plan will need to be reviewed against the respective countries’ regulatory requirements and revised accordingly. This requirement is defined in the ESAP.

Potential pollution issues during the construction phase are generally minimal due to the nature of the facilities being built, although provision of water, solid and liquid waste management and stormwater management are issues requiring attention. To address these issues Bridge will develop an appropriate, standard Environmental Management Plan (EMP) covering these issues, to be applied during construction for application across all sites. Furthermore, when expanding to other countries beyond Kenya, Bridge will revise this approach based on the relevant authorities and requirements for approvals. This action is defined in the ESAP.

In terms of resource use and management, none of the schools have any electricity or energy provision. Where food is provided (by lunch providers as described under PS:4 below), this is cooked on an open fire which is in a ‘lunch room’ building set apart from the school buildings. Water is procured from the local municipality (in around 20% of the schools) or local water vendors, and provided to all pupils and employees working at the schools. Bridge ensures that potable water is treated with standard water treatment chemicals, while 500 litre tanks with a tap are also provided for hand washing and cleaning. The treatment of the potable water is the responsibility of the Academy Managers (AMs) and is regularly audited by the Bridge quality assurance team who use a smartphone audit tool, with immediate transmission of results to HQ. Any issues raised are flagged in Bridge’s web-based issue tracker, with daily reporting on resolution of the issue. Academy Improvement Managers visit each school around twice a month and the treatment and quality of water is (qualitatively) assessed. Should there be any issues in this regard, the AM is issued with a written warning and appropriate disciplinary action in undertaken. To ensure potable water provided at the schools is of an adequate quality, a water quality monitoring programme will be developed and implemented for all schools aligned with the requirements of the World Health Organization (WHO) and specifically the WHO document World Health Organisation entitled “Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009); this requirement is included in the ESAP.

All schools are fully equipped with toilets within the school grounds and accessible to all pupils and employees. A ratio of 50 pupils per latrine is used to determine how many are provided at each school. Bridge uses a standard design for these toilet facilities, which are pit latrines which may be connected to conservancy tanks depending on the siting requirements e.g., high ground water requirements, and Kenyan Environmental Management Authority guidelines. These are constructed with one block separated into boys and girls toilets, consisting of a pit lined with stonewalling, the bottom left open for seepage and absorption and fitted with craw-vented ventilation pipes (the latter applies
if the latrine is not connected to a conservancy tank). In going forward Bridge will ensure that they have the appropriate number, design, and sitting of latrines as per the WHO document “Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009). This requirement is included in the ESAP.

Latrine waste is removed by contractors as is common in the communities in which Bridge schools are located. Bridge will be required to ensure that contractors produce a waste manifest and are licensed and dispose of this waste in designated sewage disposal areas. This is defined as a requirement in the ESAP.

Virtually no solid waste is produced at the schools. Where food services are provided, food contractors are required to take their waste away with them. Trash cans are provided at schools for non-compostable waste, but the amounts generated are insignificant

Community Health and Safety

Facilities at Bridge Academies are designed and built to meet the Kenyan Building Codes and Regulations. This commits to ensuring that all buildings are safe, provide appropriate protection against the climate, have level floors, and meet the required ventilation and noise conditions. According to management, all buildings are designed by a team of architects and submitted for approval to the relevant authorities.

The site selection process takes into account issues such as stormwater management and elevation in relation to flood risks. The building plan is approved internally by the Construction Team and Bridge management and then certified by the local planning office. Furthermore, the Construction Team has supervisors and managers on site who ensure that all standards are met. According to management, although Bridge tries to address any specific issues associated with flooding, the Company has experienced flooding at some of the schools, which

they have actively tried to minimise. However this is due to the location of schools in informal settlements where the flooding of the broader areas is experienced, and is not unique to the school itself.

To ensure the structural integrity of the buildings after construction, Bridge will develop and implement an audit function to review this aspect. Equally, an approach will be defined for on-going review of the structural integrity of schools. This requirement is defined in the ESAP.

Bridge has a policy that all children should eat lunch daily. Thus Academy Managers (AMs) are required to choose a lunch provider to supply meals in accordance with this policy, and provide parents with the option of sending lunch to school with the children or to purchase inexpensive lunches from the provider. The food providers must provide food in line with the expectations set out in Bridge’s ‘Lunch Provider Management’ guidance document, requiring affordably priced, nutritious meals of healthy proportions. In order to qualify as lunch providers, suppliers need to have a valid health certificate as issued by the municipal council, and a copy of this needs to be sent to Bridge. Food hygiene is inspected and performance in relation to the ‘Lunch Provider Management’ guidance document is monitored by the quality assurance team and AM. The quality assurance team completes a comprehensive assessment covering cleanliness of the kitchen and storage area, cook’s hygiene, quality and quantity of the inventory, and that operational procedures are being followed. This is done using the smartphone survey tool and results are transmitted to Bridge HQ. Any issues that arise are flagged in Bridge’s web-based issue tracker, with daily reporting and a team and Academy Improvement Manager for follow-up. The AM monitors the hygiene standards on a daily basis. The grievance mechanism as described under ‘Client Community Engagement ‘ in this document allows for parents to call in should there b
e any issues associated with the food provision. According to management, no issues with food provision have arisen to date. Nonetheless, in order to manage any risks associated with food hygiene, Bridge will define an approach to undertaking spot checks of food hygiene through random sampling and testing and monitor results. This is included in the ESAP.

Bridge has compiled a Life Fire and Safety Master Plan (LFSMP) which relates to the types of buildings as described above and defines responsibilities associated with different aspects of the LFSMP, applicable codes, standards, regulations and guidelines, and covers; i) fire prevention; ii) means of egress; iii) detection and alarm systems; iv) compartmentalisation; v) fire suppression and control; vi) Emergency Response Plans; and vii) operation and maintenance. It also describes and provides procedures for other hazards such as civil disturbance, natural disasters (flooding, landslides and earthquakes), medical issues/injuries and on-site security issues. While some of the measures for fire and safety are very basic (e.g., there are no fire extinguishers, rather each school is provided with a bucket of sand and water, a whistle, and teachers trained in the requirements of the LFSMP), they are considered appropriate for facilities of this kind. The LFSMP is based on relevant Kenyan regulations and has been approved by a Kenyan Government-approved Safety and Health Advisor.

According to management, traffic safety in relation to learners is not considered an issue. The reasons for this are twofold: i) schools are generally located within neighbourhoods where there is very low, or no vehicular traffic; and ii) consultations held during project siting (as described in ‘Client Community Engagement’ below) ensures that hazards of this type are identified and avoided.

Security Personnel

No security personnel are hired at any of the schools. However, a general labourer is employed at each school and a house is built for them on the premises, providing a constant presence at the school. These labourers are provided with guidance on what to do should a security issue arise, a whistle, the phone number of the chief, the local administration and the parent association. This is considered to provide sufficient security in general. Bridge also builds strong relationships with the local police and administration so that if any security issues arise, these organisations work together with the parent committee to address the problem. As part of the Emergency Response Plan requirements as set out in the LFSMP, parents/guardians are made aware of these procedures, and at the beginning of each year, the AM organises a meeting with the Chief and/ or local leaders to go over emergency preparedness, including those in relation to security issues.

Broad Community Support is not applicable for this project

Task Title/Description	Anticipated Completion Date	Indicator of Completion*
Performance Standard 1 Develop and implement an Environmental and Social Management System (ESMS) at Group level and ensure that it is applied at all Bridge Academy schools across all countries of operation. This must include: • An environmental and social policy; • Procedures to identify and manage environmental and social risks and impacts inclusive of an assessment methodology to be applied to new schools where no Environmental Impact Assessment is undertaken (latter to include assessment of approach to ablutions). • Monitoring and reporting mechanisms including; i) a monitoring plan for potable water compliant with the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines and specifically the WHO document Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009); ii) a procedure defining the assessment of schools prior to opening to ensure their structural integrity is aligned with international best practice. • Procedures to ensure; i) compliance with regulatory requirements in any country in which a school may be developed; ii) contractors collecting sewerage dispose of the material at recognized and licensed disposal points; iii) ongoing monitoring of food and water quality including a system for spot checks, and reporting to headquarters; iv) the approach to ensuring that all schools comply with the World Health Organization document “Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009).	30-Jun-14
Performance Standard 2 Develop an employee-specific grievance mechanism for staff, ensuring a feedback mechanism and closing out of issues arising outside of the disciplinary process. This must ensure that grievances can be expressed in an anonymous manner. Evidence of this grievance mechanism and its implementation must be provided to IFC. When planning operations in a new country, compile and implement a procedure as part of the occupational health and safety plan that i) defines the approach to identifying and ensuring compliance thereto relative to OHS national requirements in which the Company operates; and ii) responsibilities of the Health and Safety Committee and how these are to be achieved.	28-Feb-14
Performance Standard 3 Develop and implement a standard Environmental Management Plan for implementation during construction. This must cover issues associated with; i) liquid and solid waste a management; ii) water provision; and iii) stormwater management. When constructing toilets in new countries of operation, ensure that conservancy tanks are installed where there is a high water level, and/or as determined by the national environment agency for that country.	31-Mar-14